Combating Bioterrorism: Actions Needed to Improve Security at Plum Island Animal Disease Center
Published: 2003-09-19T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Scientists at the Plum Island Animal Disease Center are responsible for protecting the nation against animal diseases that could be accidentally or deliberately introduced into the country. Questions about the security of Plum Island arose after the 2001 terrorist attacks and when employees of the contractor hired to operate and maintain the Plum Island facilities went on strike in August 2002. GAO reviewed (1) the adequacy of security at Plum Island and (2) how well the contractor performed during the strike. The Department of Homeland Security (DHS) assumed the administration of Plum Island from the Department of Agriculture (USDA) on June 1, 2003. While DHS is now responsible for Plum Island, USDA is continuing its research and diagnostic programs.
section_title: What GAO Found
paragraphs: Security at the Plum Island Animal Disease Center has improved, but fundamental concerns leave the facility vulnerable to security breaches. First, Plum Island's physical security arrangements are incomplete and limited. Second, Plum Island officials have been assuming unnecessary risks by not adequately controlling access to areas where pathogens are located. Controlling access is particularly important because pathogens are inherently difficult to secure at any facility. Although this risk may always exist, DHS could consult with other laboratories working with pathogens to learn different approaches to mitigate this risk. Third, Plum Island's security response has limitations. For example, the guard force has been armed but has not had the authority from USDA to carry firearms or make arrests. Moreover, Plum Island's incident response plan does not consider the possibility of a terrorist attack. Fourth, the risk that an adversary may try to steal pathogens is, in our opinion, higher at the Plum Island Animal Disease Center than USDA originally determined because of hostilities surrounding the strike. Also, when USDA developed its security plan for Plum Island, it did not review their defined threats with the intelligence community and local law enforcement officials to learn of possible threats--and their associated risks--relevant to the Plum Island vicinity. Although these reviews did not occur, USDA subsequently arranged to receive current intelligence information. Despite a decline in performance from the previous rating period, USDA rated the contractor's performance as superior for the rating period during which the strike occurred.

section_title: Letter
paragraphs: The Plum Island Animal Disease Center—located in Long Island Sound off  the coast of New York—researches contagious animal diseases that have been identified in other countries.  The mission of the facility is to develop  strategies for protecting the nation’s animal industries and exports from  these foreign animal diseases, which could be accidentally or deliberately  introduced into the United States.  Scientists at Plum Island—often with  the assistance of scientists from other countries—identify the pathogens  and toxins (hereafter called pathogens) that cause these foreign animal  diseases and then work to develop vaccines against them.  Some of the  pathogens maintained at the Plum Island Animal Disease Center, such as  foot-and-mouth disease, are highly contagious to livestock and could cause  catastrophic economic losses in the agricultural sector if they were  released outside the facility.  A few can also cause illness and death in humans.  For this reason, research on these pathogens is conducted within a sealed biocontainment area that has special safety features designed to  contain the pathogens.
Until recently, the Department of Agriculture (USDA) administered Plum Island, but in June 2003, it became the responsibility of the Department of  Homeland Security (DHS). DHS officials told us that during a transition period that will last until September 31, 2003, they will review USDA’s policies and procedures for Plum Island and determine how best to administer the facility.  USDA will continue to have access to the facility to  perform its research and diagnostic programs.
Concerns about security at the Plum Island Animal Disease Center were  heightened after the terrorist attacks of September 11, 2001, because of  fears that someone might try to steal certain pathogens from the facility to  conduct bioterrorist activities.  As a result, USDA contracted with Sandia  National Laboratories—experts involved in a range of national security  areas, including ensuring the safety of nuclear weapons—to evaluate the  effectiveness of, and make recommendations to improve, Plum Island’s  security program.  USDA worked with Sandia to develop a risk  management approach to improve security on the island.  Some other  agencies employ this method for their security planning, including the  Department of Energy; we have also endorsed a risk management  approach for addressing security risks.
Risk management is a deliberate process for determining risk: that is, how  likely it is that a threat will harm an asset and how severe the consequences  would be if the asset were harmed, and then deciding on and implementing  actions to create a certain level of protection or preparedness.  Risk  management acknowledges that while risk generally cannot be eliminated,  enhancing protection from known or potential threats can reduce it.  A  facility adopting this approach should document in a security plan the  assets the facility is protecting as well as the likely adversaries and their  capabilities (the threat), the probability that an adversary will attempt to  threaten those assets and the consequences of the adversary succeeding  (the risk), and the weaknesses that might allow an adversary to be  successful (the vulnerability).  The identified threats, risks, and  vulnerabilities are used to design the physical security system.  Because  security systems cannot protect against all threats, the facility should also  develop an incident response plan that clearly lays out the actions to be  taken if an event occurs that exceeds the capability of the security system.  The risk management process is ongoing; as new information develops or  events occur, security is reevaluated and corrective actions are taken.
In August 2002, congressional concerns about the security of pathogens at  the Plum Island Animal Disease Center arose when 71 employees of the  contractor USDA had hired to operate and maintain the facility, LB&B  Associates Inc., went on strike.  You asked us to determine (1) the  adequacy of security at Plum Island and (2) how well LB&B Associates  performed from August 2002, the month that its workers went on strike,  through January 2003.  To address the first question, we visited Plum Island  several times to gain an understanding of the work performed there, the  operation of the facilities, and to examine the security measures and plans.  We also spoke with officials from DHS, USDA, Sandia National  Laboratories, the National Institutes of Health, the U.S. Army Medical  Research Institute of Infectious Diseases, the Central Intelligence Agency,  the Defense Intelligence Agency, the Federal Bureau of Investigation (FBI),  USDA’s Office of Inspector General, and government officials of localities  near Plum Island.  To address the second question we, among other things,  reviewed LB&B Associates’ contract; interviewed pertinent officials; and  reviewed USDA’s ratings of LB&B Associates’ performance, the  qualifications of its employees to perform certain tasks, and costs that  LB&B Associates incurred, but we did not independently rate the  contractor’s performance.  Before the administration of Plum Island  transferred to DHS, we briefed USDA and DHS officials on our preliminary  findings and made suggestions for improvement so that they could take  immediate corrective measures.  Additional details about our scope and  methodology are contained in appendix I.
subsections: section_title: Background
paragraphs: Plum Island is a federally owned 840-acre island off the northeastern tip of  Long Island, New York.  It is about 1.5 miles from Orient Point, New York  (see fig. 1), and about 12 miles from New London, Connecticut.  Access to  Plum Island is by a ferry service operated by a contractor that transports  employees from Orient Point and Old Saybrook, Connecticut.
The U.S. Army used Plum Island during World War II as a coastal defense  artillery installation until it was declared surplus property in 1948.  In 1952,  the U.S. Army Chemical Corps constructed a biological research  laboratory, but it was never used.  Then, in response to a foot-and-mouth  disease outbreak in Canada, the Congress transferred all of Plum Island to  USDA in 1954 for the purpose of researching and diagnosing animal  diseases from other countries, including foot-and-mouth disease, which has  not been seen in the United States since 1929.
Foot-and-mouth disease is the most feared foreign animal disease because  it is highly contagious and can have serious effects on the economy.  Slaughtering susceptible animals and quarantining both animals and  humans in affected areas helps limit the spread of the disease, but it can,  nevertheless, have devastating economic consequences, as demonstrated  during the 2001 outbreak in the United Kingdom.  By the time the disease  was eradicated, about 8 months later, the United Kingdom had slaughtered  over 4 million animals and sustained losses of over $5 billion in the food  and agricultural industries, as well as comparable losses in tourism.
Many other types of animal diseases are also studied at the Plum Island  Animal Disease Center, such as classical swine fever; rinderpest; and a  variety of pox viruses, including goat, camel, and deer pox.  Some of the  diseases are caused by pathogens that are zoonotic—that is, they can  infect, and possibly cause death, in both animals and humans.  Zoonotic  pathogens maintained at Plum Island Animal Disease Center include West  Nile virus, Venezuelan equine encephalitis, Rift Valley fever, and vesicular  stomatitis.  Because of the importance of the livestock industry to the U.S.  agricultural sector and economy, protecting livestock from these diseases  is an important responsibility.
To prevent pathogens from escaping the Plum Island Animal Disease  Center and infecting livestock, wildlife, or humans, all research is  conducted within a specially designed and sealed biocontainment area  within the research facility that adheres to specific safety measures.For  example, the biocontainment area has air seals on its doors and operates  with negative air pressure so that air passes through a special filter system  before leaving the facility.  In addition, employees and visitors must change  into protective clothing before entering the biocontainment area and  shower when going between rooms containing different animal diseases  and before leaving the biocontainment area.  USDA’s procedures require all  people and material leaving the biocontainment area to be decontaminated.
The Plum Island Animal Disease Center’s biocontainment area totals  approximately 190,000 square feet, and it is unusual because it houses a  laboratory facility with 40 rooms for large animals.  The three-level  laboratory also contains the machinery, such as the air filtration system,  necessary for the biocontainment area to function, and the pathogen  repository.  Individuals entering the biocontainment area have access to all  three floors.  In contrast, biocontainment areas of other laboratories  usually consist of a series of smaller rooms, housing smaller laboratory  animals, making it easier to control access to the pathogens.
As a result of the September 11, 2001, terrorist attacks, Plum Island Animal  Disease Center is now required to abide by new laws and regulations that  were generated to help reduce the possibility of bioterrorism.  These laws  and regulations limit access to pathogens to only approved individuals—  those whom USDA has identified as having a legitimate need to handle  agents or toxins and whose names and identifying information have been  submitted to and approved by the U.S. Attorney General.  Specifically, the  USA Patriot Act of 2001 prohibits restricted people—such as criminals or  those individuals from countries that the Department of State has declared  to be state sponsors of terrorism—from shipping, receiving, transporting,  or possessing certain dangerous pathogens.  In addition, the Agricultural  Bioterrorism Protection Act of 2002 requires that USDA develop an  inventory of potentially dangerous pathogens.  Furthermore, individuals  who possess or use pathogens must have background checks and must be  registered with the U.S. Attorney General.  Implementing this law are  regulations that became effective on February 11, 2003, which state that  laboratories must be in compliance with the regulations by November 12,  2003.  USDA also requires employees to have favorably adjudicated  background investigations before working unescorted in the  biocontainment area.
When USDA contracted with Sandia in October 2001, Sandia evaluated the  effectiveness of security at the Plum Island Animal Disease Center and four  other USDA laboratories.  Using a risk management approach, USDA first  identified generic lists of assets, risks, and threats for all five laboratories.  Sandia then used USDA’s generic threat definitions to assess the security  and vulnerabilities at each laboratory.  Sandia officials found that Plum  Island’s existing security system was inadequate for protecting against the  generic threats that USDA had selected and that it required significant  improvement.  Sandia officials also found that the biocontainment building  was not designed to be a highly secure facility.  USDA and Sandia agreed,  however, that modifying the facility to withstand an assault would be cost- prohibitive and that, because pathogens occur naturally and are available  at other laboratories throughout the world, the risk that a terrorist would  try to steal them from Plum Island was not perceived as significant (and  their perception has not changed).  Consequently, Sandia recommended a  limited physical security system designed to deter and detect a security  breach and, with assistance from local law enforcement, respond to  incidents exceeding the capability of the guard force on the island.
DHS assumed formal administration of Plum Island from USDA on June 1,  2003, as provided by the Homeland Security Act of 2002.  During a  transition period that will last until October 1, 2003, DHS will review  USDA’s policies and procedures and determine how best to administer the  functions of Plum Island.  Until the transition is complete, DHS will  administer the facility under the same policies and regulations established  by USDA.  Ultimately, the two agencies will work together to address  national biodefense issues and carry out the mission of the Plum Island  Animal Disease Center.  While DHS is now formally responsible for  security, scientists and support staff of two USDA agencies, the  Agricultural Research Service (ARS) and the Animal and Plant Health  Inspection Service (APHIS), will continue to implement the Plum Island  Animal Disease Center’s research and diagnostic mission.  ARS scientists at  Plum Island are responsible for research on foreign livestock diseases,  while APHIS scientists are responsible for diagnosing livestock diseases.  APHIS conducts diagnostic training sessions several times a year to give  veterinary health professionals the opportunity to study the clinical signs of  animal diseases found in other countries, such as foot-and-mouth disease.  According to USDA, scientists from other countries are an integral part of  the Plum Island Animal Disease Center’s workforce because they are well  qualified and well situated to study the diseases researched there, many of  which are endemic to their own countries.  These scientists are sponsored  by USDA and obtain visas that permit them to work for the department.
DHS currently uses USDA’s independent contractor to carry out operations  and maintenance functions for Plum Island.  The services under the  contract include, among other activities, operating the ferries, providing  security and emergency fire and medical services, providing buildings and  grounds services, meeting utility requirements, and performing custodial  functions.  On August 13, 2002, 71 of these employees went on strike.  The  contractor at that time, LB&B Associates, was responsible for handling the  strike.  On January 6, 2003, LB&B Associates’ contract expired.  USDA had  initially awarded that contract under a small business program when LB&B  Associates still qualified as one.  Since that initial award, LB&B Associates  had grown so that it no longer was eligible to compete for contracts set  aside for small businesses.  As a result, USDA awarded the new contract to  North Fork Services, a joint venture between LB&B Associates and  Olgoonik Logistics LLC, a small minority company of Anchorage, Alaska.  Under this arrangement, the more experienced LB&B Associates serves as  a mentor to North Fork Services, and most of the employees who worked  for LB&B Associates continue to work for North Fork Services.  DHS  officials told us that they would not renew the contract with North Fork  Services.  DHS stated that the current terms and scope of the contract are  insufficient to operate the facility in accordance with its view of the  standards and mission of the Plum Island Animal Disease Center.
section_title: USDA Has Taken Strides To Improve Security at Plum Island, but Fundamental Concerns Remain
paragraphs: Before the September 2001 terrorist attacks, the Plum Island Animal  Disease Center, like many other federal laboratories, was less conscious of  security and focused primarily on the safety of its programs and  operations. Since then, USDA intensified its focus on security and has  taken strides in developing and installing a security system.  However,  Plum Island remains vulnerable to security breaches because its security  arrangements are incomplete and limited.
subsections: section_title: USDA Has Taken Strides To Improve Security at Plum Island
paragraphs: Security at Plum Island has improved since the fall of 2001.  USDA hired a  physical security specialist to oversee its efforts to improve security,  including the implementation of Sandia’s recommendations, and to provide  direction for the security measures being taken for Plum Island.  As of July  2003, completed security upgrades include the following: taking measures to prevent unauthorized access to Plum Island by  allowing only sponsored visitors on the ferry and island; identifying  those sponsored individuals, and allocating passes, when they board the  ferry; and staffing Orient Point, New York, with a security guard as well  as installing an access gate that can be opened only with an  identification card assigned to Plum Island federal personnel; hiring armed guards to patrol the island and observe personnel and  visitors entering and leaving the facility.  When the nation is on high  terrorist alert (code orange) armed guards are added to monitor access  to the biocontainment area and to better secure the island’s perimeter.  This also allows armed guards to remain in the building while the other  armed guards go to the harbor to inspect vehicles unloaded from the  ferry and ensure that individuals departing the ferry onto Plum Island  have permission to be there; conducting a background check for government staff and contractors  working on the island and performing more rigorous checks for  individuals with access to the pathogens;  installing some video cameras to (1) increase the probability of timely  detection of an intruder and (2) monitor the activities of those inside the  biocontainment area when they remove pathogens from the storage  area—or the repository;  installing intrusion detection alarms in the administrative building and  the biocontainment area;  limiting access to pathogens by installing certain access control devices;  and  improving pathogen control and accountability by completing and  maintaining an inventory of pathogens at the facility, submitting names  of those with access to pathogens to the U.S. Attorney General, and  creating security and incident response plans, as required by law.
section_title: Despite Improvements, Security Arrangements at Plum Island Are Incomplete and Have Serious Limitations
paragraphs: Although security at the Plum Island Animal Disease Center has improved  over the past few years, fundamental concerns remain.
subsections: section_title: Plum Island’s Physical Security Is Incomplete and Limited
paragraphs: Plum Island’s physical security system is not yet fully operational.  For  example, the facility does not yet have in place all the equipment necessary  to detect intruders in various places.  DHS officials agree that these  physical security measures are important and anticipate they will be in  place by December 2003.
In addition, our Office of Special Investigations identified physical security  limitations.  For example, we found that lighting is inadequate to support  the cameras outside of the research complex and vehicles are not properly  screened.  (See app. II for other limitations identified by our Office of  Special Investigations and observations on how they could be addressed.)
Moreover, the physical security measures that USDA chose to implement  on Plum Island are largely limited to the biocontainment area, where  pathogens are located.  Consequently, other important assets remain  vulnerable.  For example, the continued operation of the Plum Island  Animal Disease Center is dependent on its infrastructure, which has limited  protection.  Protecting the infrastructure is particularly important because  the Plum Island Animal Disease Center is the only facility in the United  States capable of responding to an outbreak and researching foot-and- mouth disease.  Therefore, if the infrastructure was damaged, no other  facility could step in and continue this foot-and-mouth disease work.
Furthermore, Plum Island is the only facility in North America that has a  foot-and-mouth disease vaccine bank.  This bank represents years of  cooperative research performed by Canada, Mexico, and the United States,  yet the room containing it has a window opening covered with only  plywood.  USDA officials said they intend to improve the physical security  of the vaccine bank but have not yet decided on the approach to take.  In  addition, DHS officials agree that the Plum Island Animal Disease Center is  vital to combating bioterrorism, and they are evaluating the physical  security on Plum Island.
section_title: Access to Pathogens Is Not Adequately Controlled
paragraphs: Access to pathogens at the Plum Island Animal Disease Center is not  adequately controlled.  For example, as of July 2003, eight scientists from  other countries were working in the biocontainment area without  completed background investigations. According to FBI officials,  allowing anyone who does not have a completed background investigation  access to the biocontainment area—in particular, a scientist from another  country—represents a significant security risk.  USDA officials told us  these scientists were allowed into the biocontainment area to enable  research to continue.  Furthermore, they stated that background  investigations had been initiated for these individuals, and it was assumed  that these scientists were being escorted, which USDA policy permits for  those with pending background investigations.  However, Plum Island  officials told us that due to resource constraints, it has not been possible to  continually escort and monitor scientists while they are in the  biocontainment area.  When we brought this concern to the attention of  DHS officials, they told us they are developing a more restrictive policy for  allowing scientists from other countries to have access to pathogens.
In addition, USDA policy does not require background checks on students  who attend the foot-and-mouth disease classes that are regularly held in the  biocontainment area.  In 2002, USDA held six classes with an average of 32  students per class and anticipates continuing these classes in the future.  According to USDA’s policy, individuals may enter the biocontainment area  without background checks if an approved individual escorts them.We  believe this policy warrants reconsideration for several reasons.
Allowing students who do not have background checks into  biocontainment for purposes of attending foot-and-mouth disease  classes, with or without an approved escort, may not be consistent with  the regulations implementing the Agricultural Bioterrorism  Preparedness Act.
These same regulations do not provide an exception for unapproved  students or other visitors who may be handling or have access to  pathogens.
USDA officials told us that maintaining constant visual contact with  even one escorted individual is very difficult because of the size and  floor plan of the biocontainment area.
USDA officials told us that they believe escorting students is sufficient to  meet the intent of the regulations.  However, DHS officials said that all  students should have completed background checks before entering the  biocontainment area and told us they will develop a policy that will ensure  that this occurs once the transition period is complete.
Although USDA’s regulations specifically allow unapproved individuals into  the biocontainment area with an approved escort, we found unescorted  maintenance workers in the biocontainment area.  The regulations provide  for unapproved individuals to conduct routine cleaning, maintenance,  repair, and other nonlaboratory functions in the biocontainment area if  they are escorted and continually monitored by an approved individual.However, early in our investigation we found that as many as five such  individuals were working in the biocontainment area without escorts.  When we brought this to the attention of USDA officials, they provided an  escort for these individuals.  DHS officials added that the operating  contractor would soon provide security escorts.
Controlling access to pathogens is important because no security device  can currently ensure that an insider, such as a scientist, will not steal  pathogens from the Plum Island Animal Disease Center or other  laboratories.  According to the director of the Plum Island Animal Disease  Center—while under USDA’s administration—and officials from Sandia,  the National Institutes of Health, and the U.S. Army Medical Research  Institute of Infectious Diseases, pathogens are more difficult to secure than  other materials that could be used as weapons, such as nuclear material.  This is because there is no existing mechanism capable of detecting the  theft of a microgram of pathogenic material and a tiny quantity can be  multiplied.  Thus, a scientist could covertly generate or divert a pathogen  during the normal course of work, remove it from the laboratory  undetected, and potentially develop it into a weapon for spreading disease.  This inherent problem leaves all facilities with pathogens vulnerable to  serious security breaches.  Also, the existence of the foot-and-mouth  disease pathogen at the Plum Island Animal Disease Center is a particular  concern because an undetected theft, followed by the spread of the  disease, would have serious economic consequences for the nation.  In  addition, the presence of zoonotic diseases at the Plum Island Animal  Disease Center is worrisome because of the potential for adverse health  affects on humans, and two such pathogens are of particular concern.  First, U.S. government research has shown that Venezuelan equine  encephalitis virus can be developed into a human biowarfare agent.  Second, USDA believes that because of the genetic similarities of two pox  strains, it may be possible to manipulate camel pox into an agent as  threatening as smallpox. Although USDA created an inventory list of the  pathogens at the Plum Island Animal Disease Center, as required by law,  such a list cannot provide an accurate count of pathogens because  quantities of pathogens change as they replicate.
Thus far, Plum Island officials have secured pathogens by restricting access  to the island itself and to the biocontainment area where the pathogens are  located and by locking the freezers containing the pathogens.  But DHS  officials have not yet had the opportunity to fully consider actions other  laboratories are taking to mitigate the likelihood that pathogens could be  stolen.  Officials at the U.S. Army Medical Research Institute of Infectious  Diseases at Fort Detrick, Maryland, told us they are taking several steps, in  addition to physical security measures and inventory control, to better  safeguard pathogens against theft.  For example, they plan to use trained  personnel as roving monitors to ensure that unauthorized laboratory work  is not being performed, and they will randomly inspect all personnel exiting  laboratories.  Moreover, they are interviewing scientists periodically and  requiring that background checks be updated every 5 years in order to  evaluate the continued suitability and reliability of those employees  working with pathogens.  Although USDA told us background checks were  updated every 5 years, according to Plum Island records as of July 2003,  12 current Plum Island employees, some of whom have access to  pathogens, had not had their background checks updated in more than  10 years.  According to Sandia, other potentially helpful safeguards include  creating, implementing, and enforcing strict policies, including those that  prohibit researchers from continuing work in the biocontainment area if  they do not follow security procedures.  DHS officials stated that they have  started to work with other laboratories and that measures such as these,  while not necessarily a panacea, could help improve the security of  pathogens at Plum Island.
section_title: Incident Response Capability Is Limited
paragraphs: Plum Island’s incident response capability is limited in four ways.  First, the  security guards on each shift carry firearms, although Plum Island does not  have statutory authority for an armed guard force. USDA operated the  guard force on Plum Island without authority for the guards to carry  firearms or make arrests.  Furthermore, Plum Island officials have not  approved a policy that addresses the use of weapons, and, as a result, the  guards do not know specifically how they are expected to deal with  intruders on the island and when or if they should use their weapons.
When we informed DHS officials of these problems, they agreed to resolve  them as soon as possible and raised the possibility that the Federal  Protective Service could be assigned to guard Plum Island.  The Federal  Protective Service, now under DHS, has the authority to carry weapons and  make arrests.Since DHS has taken responsibility for the island, the  Federal Protective Service has visited Plum Island to assess its security  requirements.
Second, according to the observations of our Office of Special  Investigations, Plum Island has too few guards to ensure safety and  effectiveness.DHS officials agree with this observation and said that they  have requested funds to hire additional guards.
Third, arrangements for local law enforcement support are also limited.  According to Sandia’s recommended security plan, in the event an incident  exceeds the response capability of the Plum Island guards, they would first  contact Southold town police, the closest and primary responding law  enforcement agency.If still more resources were needed, Southold town  police would contact Suffolk County police, the secondary responder.  Because of liability issues, however, arrangements with local law  enforcement have not been finalized even though there have been  continuing discussions with local law enforcement.  The result is that Plum  Island officials cannot predict the extent to which the Southold town police  will provide backup during an incident.  On the other hand, officials of  Suffolk County, which includes both Plum Island and Southold, told us that  although it takes longer for them to respond than Southold police, they  could respond with an adequate number of officers, if necessary. In  addition, they have requested a map of the island and a tour of the  biocontainment area to become more knowledgeable about the facility and  its surrounding terrain.  Suffolk County officials pointed out, however, that,  for geographical reasons, Southold remains the primary responder.  In this  vein, Plum Island officials have never defined an adequate response time,  nor have they conducted exercises with local law enforcement officials to  determine how effectively Plum Island and local officials can address an  incident on the island.  DHS officials agree that the arrangements for local  law enforcement support are limited, and they are trying to overcome this  problem as quickly as possible by first resolving the issue surrounding the  authority to make arrests and carry weapons.  In addition, these officials  concur that it is important to develop a better understanding of the  response times and capabilities of local law enforcement assistance and to  conduct exercises to test the adequacy of arrangements once they are  completed.
Fourth, according to Sandia officials, the incident response plan for Plum  Island is not sufficiently comprehensive.  Plum Island’s incident response  plan contains certain elements required under law, such as how to respond  to an inventory violation or a bomb threat. However, because USDA  selected a risk management approach to security, Plum Island officials  need an incident response plan that clearly lays out the actions to be taken  if events occur that exceed the capability of the facility’s security system.  For example, Plum Island officials do not have a road map for actions to be  taken in the event of a terrorist attack—who gets notified, in what order,  and the responsibilities of staff for responding.  This is a critical  shortcoming because, according to DHS, the nation faces a significant risk  of a terrorist attack.  Sandia officials also said that the incident response  plan for Plum Island requires significant additional development to  properly prepare for the complete range of threats.  Moreover, the incident  response plan does not identify the security steps that should be taken in  the event of an outbreak of foot-and-mouth disease or take into  consideration any increased risks to the facility, which could severely  impede the nation’s capability to contain an outbreak.
Finally, according to the FBI and local law enforcement officials, the  island’s incident response plan may need to be coordinated with the  incident response plans of such nearby facilities as the Millstone nuclear  power plant, the Brookhaven National Laboratory, and the laboratories at  the State University of New York at Stony Brook because a terrorist attack  on any of these facilities could also involve Plum Island. This type of  coordination has not yet taken place.  DHS officials agree that the incident  response plan needs to be more comprehensive and coordinated with  national and local law enforcement agencies.
Plum Island’s Security Plan Does  The risk that an adversary might try to steal pathogens is, in our opinion,  Not Address All Risks and  Threats  higher than USDA believed it to be in 2001, when it defined the same risks  for all of its laboratories, including Plum Island.  USDA considered the risk  that an adversary would try to steal pathogens from any of its laboratories  to be relatively low compared to materials found at other laboratories, such  as nuclear material or pathogens of a higher consequence to the human  population.  Since its evaluation in 2001, however, the level of risk at Plum  Island has increased because of the strike that occurred in August 2002 and  the hostility surrounding it.  For example, one striker has been convicted of  tampering with the island’s water distribution and treatment system as he  walked off the job the day the strike began. USDA officials suspect that  this individual did not act alone.  In addition to this incident, USDA asked  the FBI and USDA’s Office of Inspector General to investigate the  possibility that a boat engine had been tampered with.  USDA also asked  the FBI to investigate why backup generators failed to come on when Plum  Island lost power for more than 3 hours in December 2002.
After the backup generators failed to provide power, New York’s ABC news  station broadcast an interview with a disguised worker, at that time  employed at Plum Island, who discussed his unhappiness with USDA and  the contractor and blamed replacement workers for the power outage.In  addition, several of the striking workers returned to work for LB&B  Associates and are still employed on the island under the new contractor,  North Fork Services.  In response to the strike, USDA prevented striking  workers from accessing Plum Island and it added guards at Orient Point to  assure the security of employees as they were arriving and departing near  the union picket line.  However, USDA did not reevaluate the level of risk,  the assets requiring protection, or its incident response plans in light of the  strike and accompanying sabotage.  USDA believed that this was not  necessary because its security plan anticipated a disgruntled worker at any  of its laboratories.  We disagree because there is a difference between  addressing security problems caused by one employee and addressing the  hostilities resulting from the strike, which could include several employees  working together.  We believe that the implications of a disgruntled work  force should be taken into account when reevaluating the extent of risks,  threats, and assets requiring increased security.
Furthermore, Sandia had originally recommended that USDA review the  defined threats with the intelligence community and local law enforcement  officials to ensure that threats particular to Plum Island and its vicinity  were taken into consideration, but this was never done. FBI and Suffolk  County officials told us that they consider this step to be very important  because if there were such threats, federal and local officials may be aware  of them and the risks they pose to the Plum Island Animal Disease Center.  In addition, if local law enforcement entities were involved in planning  Plum Island’s security, they would be in a better position to respond to  incidents on the island.
DHS officials agree that rehiring workers who walked off the job could be  problematic but told us they are under pressure from the local chapter of  the union and the community to rehire those who lost their jobs as a result  of the strike.  DHS officials also said they recognize the importance of  working with local law enforcement and the intelligence community to  better define the threats and associated risks for Plum Island.
section_title: USDA Concluded Its Contractor’s Performance Declined during the Strike but Operations Continued and Overall Performance Was Superior
paragraphs: Regarding the contractor’s performance, despite a decline from the  previous rating period, USDA rated LB&B Associates’ performance as  superior for the rating period during which the strike occurred.  When the  strike occurred, LB&B Associates, with the assistance of USDA employees,  maintained operations at Plum Island.  For example, LB&B Associates  implemented a strike contingency plan, brought in qualified individuals  from its other work sites, and hired subcontractors with the required  licenses and certifications to operate certain Plum Island facilities and its  boats.  Also, as a result of the strike, LB&B Associates exceeded its  estimated budget by about $511,000, or approximately 5 percent, for fiscal  year 2002 and the first quarter of fiscal year 2003.  USDA was aware of and  approved the cost increases.  Further information about LB&B Associates’  performance, employee qualifications, and costs is contained in appendix  III.
section_title: Conclusions
paragraphs: Despite improvements, security arrangements at Plum Island are not yet  sufficient.  Further actions are needed to provide reasonable assurance  that pathogens cannot be removed from the facility and exploited for use in  bioterrorism.  Until DHS fully implements the physical security measures  and addresses those vulnerabilities identified by our Office of Special  Investigations, Plum Island’s security system will not provide physical  security commensurate with the importance of the facility.  Additionally,  the Plum Island Animal Disease Center will remain more vulnerable than it  needs to be if the physical infrastructure that supports it is not afforded  better protection.  Similarly, it is important to better secure the foot-and- mouth disease vaccine bank to ensure its availability for combating an  outbreak.  Also, the lack of comprehensive policies and procedures for  limiting access to pathogens unnecessarily elevates the risk of pathogen  theft.  Moreover, because physical security measures alone are not  adequate to secure pathogens, all laboratories containing these materials  face the challenge of developing other approaches to mitigate the risk of  theft.  By consulting with other laboratories to discover methods they are  using to mitigate the risk to pathogens, Plum Island officials can learn more  about safeguards being employed elsewhere.  Furthermore, Plum Island  officials cannot effectively respond to security breaches until DHS resolves  issues that impede Plum Island’s response capability, such as the authority  of the guard force to make arrests, which makes it difficult for the guards  and local law enforcement agencies to address criminal situations on the  island.  Finally, because we believe the level of risk at Plum Island is higher  than USDA originally determined, and because USDA did not validate  threats with intelligence agencies or local law enforcement officials, DHS  cannot be assured that Plum Island’s security, including its physical  security system and response plans, is sufficient to address the full range of  events that could occur on the island.
section_title: Recommendations for Executive Action
paragraphs: To complete and enhance Plum Island’s security arrangements, we  recommend that the Secretary of Homeland Security, in consultation with  the Secretary of Agriculture, do the following:
Correct physical security deficiencies by (1) fully implementing the  physical security measures, (2) addressing the specific security  shortcomings identified by our Office of Special Investigations, (3)  better securing certain features of the physical infrastructure that  supports the continued operation of the Plum Island Animal Disease  Center, and (4) better securing the foot-and-mouth disease vaccine  bank.
Limit access to pathogens by further developing and enforcing specific  procedures, including internal control checks, to ensure (1) that all  individuals involved in laboratory activities in the biocontainment  area—including students and regardless of citizenship—have been  approved, in accordance with the law; (2) that background checks of  these individuals are updated regularly; and (3) that cleaning,  maintenance, and repair staff entering the biocontainment area are  escorted at all times by individuals with completed background checks.
Consult with other laboratories to identify ways to mitigate the inherent  difficulty of securing pathogens.
Enhance incident response capability by (1) resolving the issue of the  guards’ authority to carry firearms and make arrests; (2) developing and  implementing a policy on how guards should deal with intruders and use  weapons; (3) increasing the size of the guard force; (4) completing an  agreement with local law enforcement agencies to ensure backup  assistance when needed; (5) defining an adequate response time for law  enforcement to respond to incidents; (6) developing an incident  response plan that includes precise detail about what to do in the event  an incident occurs that exceeds the capability of the security system,  such as a terrorist attack; and (7) conducting exercises with local law  enforcement to test the efficiency and effectiveness of Plum Island’s  response capability.
Reconsider the security risks at Plum Island, taking into account recent  acts of disgruntled employees.
Consult with appropriate state and local law enforcement and  intelligence agencies to revisit the threats specific to the Plum Island  Animal Disease Center.
Revise, as necessary, security and incident response plans to reflect any  redefined, risks, threats, and assets.
section_title: Agency Comments
paragraphs: We provided DHS and USDA with a draft of this report for their review and  comment.  Both agencies provided written and clarifying oral comments.  The agencies also provided technical comments, which we incorporated  into the report as appropriate.  Overall, DHS agreed with the report and  stated that it has started to implement our recommendations, and USDA  stated that the report was very useful but also raised several concerns.
In its written comments (see app. IV), DHS agreed that fundamental  concerns leave the facility vulnerable to security breaches and stated that  the report is factually accurate.  DHS also commented that it accepts and  supports our recommendations.  In addition, DHS stated that since it  assumed administrative responsibility for Plum Island on June 1, 2003, it  has taken the following actions, among others, to address the  recommendations in this report:
DHS is working with USDA to develop corrective actions to address the  physical security deficiencies identified in our report.
DHS is working with USDA to develop an access control policy for all  personnel who are required to enter the biocontainment area.
DHS is working with other federal agencies to develop security policies  and procedures to limit access to pathogens.
DHS is working with the Federal Protective Service to enhance security  at the facility and bring arrest and detention authority to the island.  In  addition, DHS stated that funds have been requested to increase the  guard force.
DHS is working with local law enforcement agencies to coordinate  incident response plans, mutual aid agreement requirements, and joint  exercises to test security response capabilities.
DHS is reviewing the island’s entire security plan and will revise the  threat assessment as necessary.  DHS stated that it expects to complete  this assessment in early 2004.
In its written comments (see app. V), USDA addressed several aspects of  our report.  These specific comments and our responses follow.
USDA suggested that the report should make judgments about the need  for enhanced security against a risk assessment-based approach that  considers both the probability and the consequences of specific types of  attacks.  However, as we report, DHS is now responsible for performing  such an assessment, and DHS stated that it has undertaken a review of  USDA’s threat statement, which it will complete early in 2004.  Our  objective was to evaluate the status of security on Plum Island.  That  evaluation included, among other steps, a review of USDA’s risk-based  security plan for Plum Island and its implementation.  Our report details  substantive flaws in both the planning and the execution of that plan.
USDA also commented that the report did not recognize that USDA had  a contract to improve security at Plum Island prior to September 11,  2001.  We added to the report that USDA contracted with the U.S. Army  Corps of Engineers in 2000 to improve security at Plum Island, but noted  that few of the Corps’ recommendations had been implemented.  Also,  USDA officials told us that in light of September 11, 2001, and the  subsequent dissemination of anthrax through the postal system, they  made a concerted effort to improve security at USDA’s laboratories.  The  officials added that Sandia was hired to provide USDA with a consistent  approach to evaluating security at the department’s major laboratories.  Sandia officials told us that they did not agree with the approach taken  by the Corps, and they concluded that Plum Island’s existing security  system was substantially inadequate for protecting against the threats  that USDA defined as relevant.
USDA indicated that it took various actions to safeguard pathogens in  response to the strike.  USDA stated that it increased and armed the  guards on Plum Island; added guards at Orient Point, Long Island, where  the strikers were picketing; and excluded the strikers from Plum Island  facilities.  We agree that USDA responded with immediate measures and  have revised the report to reflect these steps.  However, we believe that  USDA’s responses to the strike were insufficient.  Although USDA  increased the number of guards at Orient Point, this was a temporary  measure primarily put in place to ensure the safety of the employees as  they passed the union picket line.  Also, Plum Island officials told us that  the number of guards on Plum Island itself did not change as a result of  the strike and that these guards had been armed since 2001.  More  importantly, USDA’s comments do not recognize that there is a  difference between addressing security problems caused by one  employee and addressing the security problems resulting from the  strike, which could include several employees collaborating to cause  problems.  We believe that the implications of having a disgruntled work  force should be taken into account when reevaluating the extent of  risks, threats and assets requiring increased security.
USDA stated that it appropriately used armed guards on Plum Island  and were in communication with local law enforcement.  While we  agree that armed guards are necessary for security on Plum Island, our  concern is that the guard force did not have authority from USDA to  carry firearms and make arrests.  Furthermore, USDA never developed a  policy instructing its guards when and how they could use force,  including the firearms they were carrying.  Plum Island officials said  they were unable to resolve these important matters with USDA  headquarters officials, including the Office of General Counsel.  Finally,  we noted in the report that while Plum Island officials have  communicated with local law enforcement, no agreement was reached  to assist Plum Island guards in the event a criminal act occurred on the  island.  DHS stated that it is working to resolve these issues.
USDA stated that it is an accepted practice for a person with an  appropriate background investigation to escort those who do not yet  have a clearance.  USDA also acknowledged that it had problems  implementing its escort procedures at Plum Island but now believes its  escort procedures are reliable.  We agree that the practice of escorting is  used in other laboratories that contain pathogens.  However, Plum  Island officials and scientists repeatedly told us that this procedure is  not practical at Plum Island because of staffing considerations.  For  example, they explained that the escorts were Plum Island employees  who had other duties, which compelled them to leave those they were  escorting for periods of time.  Furthermore, we believe that internal  control checks should be established to ensure implementation of  escort procedures, and we have added this to our recommendations.  DHS commented that more will be done to address this issue—it is  planning to develop, in concert with USDA, a limited use policy to  identify access control requirements for all personnel who are required  to enter the biocontainment area.
USDA said that several of the employees we identified had not had their  background checks updated in the last 5 years, but that some of those  we identified had.  We reported based on the actual records of  background checks maintained at the Plum Island Animal Disease  Center.  We also recognize that there may be differences between the  records maintained on the island and other USDA records, and that the  background checks of several of these individuals may have been  updated since the time of our review.
As we agreed with your office, unless you publicly announce the contents  of this report earlier, we plan no further distribution of it until 30 days from  the date of this report.  We will then send copies of this report to the  Secretaries of Homeland Security and Agriculture, appropriate  congressional committees, and other interested parties.  We will also make  copies available at no charge on the GAO Web site at http://www.gao.gov.
If you have any questions about this report, please call me or Charles M.  Adams at (202) 512-3841.  Key contributors to this report are listed in  appendix VI.
section_title: Scope and Methodology
paragraphs: To determine the extent to which USDA has addressed security for Plum  Island, we visited the facility several times to examine current physical  security measures and to review plans for further security actions.  In  addition, two security experts from our Office of Special Investigations  toured the facility to identify possible vulnerabilities and actions that could  be taken to reduce them.  We also reviewed numerous security documents,  such as Sandia’s assessment of Plum Island security; Plum Island’s draft  security and response plans; draft memorandums of understanding with  local entities; physical security implementation plans; and policies and  procedures for guards, employees, visitors, students, and others with  access to pathogens.  In addition, we worked closely with Sandia officials  to understand how they applied a risk management security approach to  Plum Island.  We also interviewed numerous officials from Plum Island,  including the physical security specialist, scientists, the center director,  and others responsible for security changes under both the Agricultural  Research Service and the Animal Plant and Health Inspection Service;  officials of USDA’s Offices of Homeland Security, Procurement and  Property Management, and General Counsel; and officials of the  Department of Homeland Security, which assumed the administration of  Plum Island.  To gain a better understanding of possible threats to Plum  Island, we spoke with officials from the Federal Bureau of Investigation,  Defense Intelligence Agency, Central Intelligence Agency, Suffolk County  police and fire departments, and USDA’s Office of Inspector General.  To  understand the cooperation between local governments and Plum Island  that might be needed if an incident were to occur on the island, we  interviewed government and law enforcement officials from Suffolk  County, the town of Southold, and the village of Greenport.  Finally, we  toured the laboratories at and interviewed officials from the National  Institutes of Health and the U.S. Army Medical Research Institute of  Infectious Diseases to understand how they are handling security  challenges since the terrorist attacks of 2001.  To determine Plum Island’s  compliance with new laws and regulations, we reviewed the USA Patriot  Actof 2001, the Agricultural Bioterrorism Protection Act of 2002 and its  regulations that went into effect as a final interim rule on February 11,  2003, as well as USDA’s policies and procedures for security at biosafety  level 3 facilities.  We also considered the Office of Management and  Budget’s Circular A-123, Management Accountability and Control, and  the standards in our Internal Control: Standards for Internal Control in  the Federal Government.
To determine how well LB&B Associates performed from the time the  strike began on August 13, 2002, to January 5, 2003, we (1) reviewed LB&B  Associates’ contract with USDA and identified LB&B Associates’  performance requirements; (2) interviewed officials of USDA, LB&B  Associates, and the International Union of Operating Engineers to get their  perspective on LB&B Associates’ performance; (3) reviewed USDA’s  ratings of LB&B Associates’ performance since 1999 and, in particular, the  Award Fee Determination Board’s report on LB&B Associates’  performance during the period the strike took place; (4) reviewed the  qualifications of LB&B Associates employees, such as the boat operators  and water distribution and treatment system operators, all of whom are  required to meet certain qualifications for performing their duties; (5)  analyzed 3 years of contract cost data provided by LB&B Associates to  learn which items increased as a result of the strike; and (6) validated the  contract cost data by spot-checking it against the bills LB&B Associates  submitted to USDA.  While we took these steps to determine how well  LB&B Associates performed, we did not independently rate LB&B  Associates’ performance.  In addition, we interviewed officials involved in  investigating strike-related incidents, including officials of the Federal  Bureau of Investigation and USDA’s Office of Inspector General.
Our work was conducted in accordance with generally accepted  government auditing standards from January through August 2003.
section_title: Additional Observations on Plum Island’s Security System by GAO’s Office of Special Investigations
paragraphs: The security force reports directly to the Administrative Contract  Officer and not to the Security Director—it is important for the security  force to report directly to the Security Director of Plum Island to ensure  that security-related issues are handled promptly.
There are no name checks or record checks given to contractors and  visitors going into the biocontainment area.  Contractors and visitors  entering the biocontainment area could be checked for criminal charges  (through the National Criminal Information Center) before they are  granted access.
The area outside of the biocontainment and administrative building is  surveilled by stationary closed-circuit television cameras, which are  insufficient.  Installing pan, tilt, and zoom closed-circuit television  cameras in certain areas would enhance surveillance capabilities.
The island is easily accessible to the general public by boat, and there  are limited “no trespassing” signs present on the island to advise the  public that it is a government facility—more “no trespassing” signs in  those areas of the island that are easily accessible to the public by boat  would address this condition.
In the event of a fire, Plum Island is not always able to respond  appropriately because the fire brigade has limited hours of operation.  The security force could be cross-trained for fire rescues and therefore  provide 24-hour coverage.
The building used for overnight accommodations lacks panic alarms for  emergency response.  Panic alarms could be installed in the building  and, when visitors are present, security guards could drive by on a  regular basis.
Control for keys and master keys of the facility is deficient.  The security  department could be assigned the responsibility for all keys and master  keys.  A key log could be created to better track possession of keys.
section_title: LB&B Associates’ Performance, Employee Qualifications, and Costs
paragraphs: USDA concluded, in an evaluation of LB&B Associates’ performance,  which included the time period involving the strike, that LB&B Associates’  overall performance was superior, although its performance had declined  compared to prior rating periods.  When the strike occurred, LB&B  Associates, with the assistance of USDA employees, continued to perform  and maintained operations at Plum Island.  LB&B Associates implemented  a strike contingency plan, brought in qualified individuals from its other  work sites, and hired subcontractors with the required licenses and  certifications to operate certain Plum Island facilities and its boats.  Also,  as a result of the strike, LB&B Associates exceeded its estimated budget by  about $511,000, or approximately 5 percent, for fiscal year 2002 and the  first quarter of fiscal year 2003.  USDA was aware of and approved the cost  increases.
subsections: section_title: Performance
paragraphs: Although LB&B Associates’ performance declined during the strike relative  to previous rating periods, overall, LB&B Associates performed at a  superior level during the evaluation period that included several months  when workers were on strike, maintaining—and in some cases even  improving—operations critical to the functioning of the island, according  to Plum Island officials.  Plum Island’s Award Fee Determination Board  regularly rated LB&B Associates’ performance using a system described in  its contract to calculate a composite performance score. According to the  board, LB&B Associates’ performance was outstanding—the highest  level—for more than 2 years, until the rating period in which the strike  began.  The board faulted LB&B Associates in several rating categories  resulting in a decline in its performance rating.  For example, according to  the board, LB&B Associates’ strike contingency plan, which describes how  essential operations would be continued in the event of a strike, was  outdated.  As a result, implementation of the plan was slowed because it  took up to 48 hours before all of its temporary workers arrived on the  island.  Moreover, some subcontracts cost more than anticipated.
According to the board, LB&B Associates overcame initial problems in  implementing its contingency plan and, overall, performed at the superior  level.  For example, temporary workers and subcontractors hired by LB&B  Associates quickly repaired the water system that had been sabotaged on  the first day of the strike.  Furthermore, according to the board, some  activities improved after the onset of the strike, including the maintenance  of steam pipes, an important component of the process used to  decontaminate laboratory waste contaminated with pathogens.  Also, boat  maintenance and cafeteria services—both of which, according to the  Board, had been problematic before the strike—improved after  replacement workers were hired.  Figure 2 shows the composite scores the  board gave LB&B Associates from fiscal year 2000 through the first quarter  of fiscal year 2003, which includes the time during which the strike  occurred.
More details about how the board evaluated LB&B Associates’  performance are contained in table 1.
section_title: Employee Qualifications
paragraphs: To maintain operations at Plum Island after the strike began, LB&B  Associates brought in temporary replacements from some of its other contract sites, hired subcontractors, and subsequently hired permanent  replacement workers, as described in the strike contingency plan.  We  confirmed that workers in certain positions, including boat operators and  operators for the wastewater treatment system, were licensed as  prescribed by LB&B Associates’ contract with USDA.  In addition, many of  the replacement workers appear to have significant and relevant work  experience for the positions for which they were hired.
Although LB&B Associates and USDA staff worked together to maintain  vital functions, operations were affected at times by the strike because of  the reduced workforce and the loss of some workers with specific skills  and/or qualifications.  For example, the ferries that take workers to and  from the island operated on a reduced schedule until all three boat masters  who had walked out were replaced by individuals with the necessary Coast  Guard license.  Also, some USDA officials stepped in to fulfill duties that  were normally performed by qualified contract staff, such as monitoring  the air filters in the laboratory, until qualified replacements were hired.  By  July 2003, most positions left vacant by the strike were filled, most of them  by permanent replacement workers and 16 by striking workers who  returned to work on the island.
section_title: Costs Attributable to the Strike
paragraphs: With USDA’s approval, LB&B Associates exceeded its estimated budget by  about $511,000, or approximately 5 percent, during the 15-month period  covering fiscal year 2002 and the first quarter of fiscal year 2003, the period  during which the strike began. USDA allowed the additional expenditures,  which occurred in the last 2 months of fiscal year 2002 and the first 3  months of 2003, because it recognized that the strike would result in higher  expenses and it found LB&B Associates’ estimate for exceeding the budget  to be acceptable, under the circumstances.  As required by Federal  Acquisition Regulations, LB&B Associates notified USDA that it expected  to exceed its budget as a result of the strike.Figure 3 shows the total costs  LB&B Associates charged to USDA from October 1, 2001 through January 5  2003; the graph also incorporates costs billed to USDA by North Fork  Services from January 6 through May 31, 2003, illustrating the continued  fluctuation in contract costs.
According to LB&B Associates’ data, there were fluctuations in Plum  Island’s costs, as shown in figure 3.  Also, as a result of the strike, additional  costs were incurred in the following areas from August 1, 2002, through  January 5, 2003,unless otherwise noted: labor (salary and benefits),  subcontracts, cafeteria, and travel (including lodging and transportation).
Labor: The cost of labor peaked at $428,161 in August 2002, a 16 percent  increase over the average monthly cost of $370,118 for the previous 10  months.  Monthly labor costs then gradually decreased until November,  when the cost of labor was about 1.6 percent more than the average  monthly cost.  Labor costs increased because most of the temporary  replacements were management-level employees from other LB&B  Associates contract sites, who earned more than the employees they  replaced.  According to its documents, LB&B Associates used  management-level employees because union members from other localities  usually honor a picket line and would not temporarily replace union  strikers.  As new permanent employees were hired, the cost of labor  gradually decreased.
Subcontracts: Subcontracts related to the strike, such as for providing  security guards at the picket line, added about $523,000,or 77 percent of  the total subcontract costs billed to USDA by LB&B Associates.
Cafeteria: Cafeteria expenses increased by about $12,000, or 51 percent of  the total cafeteria expenses because the cafeteria provided two meals per  day for the temporary replacements, who spent more time on the island to  ensure continued operations than employees had before the strike began.
Travel: Travel expenses attributed to the strike, such as transporting and  housing the temporary replacement workers, totaled more than $125,000,  constituting 98 percent of the total travel costs billed to USDA during that  time period.
section_title: Comments from the Department of Homeland Security
section_title: Comments from the U.S. Department of Agriculture
section_title: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Acknowledgments
paragraphs: In addition to the individual named above, Aldo Benejam, Nancy Crothers,  Mary Denigan-Macauley, Jonathan Gill, Thomas Farrell, Wyatt R. Hundrup,  and Ramon Rodriguez made key contributions to this report.
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section_title: To Report Fraud, Waste, and Abuse in Federal Programs
section_title: Public Affairs