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GAO-08-306R: 

United States Government Accountability Office: 
Washington, DC 20548: 

December 17, 2007: 

Congressional Addressees: 

Subject: Plum Island Animal Disease Center: DHS Has Made Significant 
Progress Implementing Security Recommendations, but Several 
Recommendations Remain Open: 

For many years, the Department of Agriculture (USDA) owned and operated 
the Plum Island Animal Disease Center, located on an island in the Long 
Island Sound off the coast of New York. Scientists at Plum Island, 
often with the assistance of scientists from other countries, diagnose 
the pathogens that cause foreign animal diseases and then conduct 
research to, among other things, develop vaccines to protect against 
them. Some of the pathogens maintained at Plum Island, such as foot- 
and-mouth disease, are highly contagious to livestock and could cause 
catastrophic economic losses in the agricultural sector if they are 
released outside the facility. Other pathogens known to have been 
maintained at Plum Island could also cause illness and death in humans. 
For these reasons, USDA conducts its work on Plum Island within a 
sealed biocontainment area that has special safety features designed to 
contain the pathogens. 

After the terrorist attacks on the United States, new laws and 
regulations required officials at the Plum Island Animal Disease Center 
to further restrict access to the pathogens in order to protect animal 
health and, thereby, also help reduce the possibility of bioterrorism. 
In addition, Plum Island and its assets and liabilities were 
transferred from USDA to the Department of Homeland Security (DHS). 
[Footnote 1] Today, USDA continues to conduct its diagnostic and 
research work on Plum Island, but it now does so in coordination with 
DHS as part of a broader joint strategy to protect against the 
intentional or accidental introduction of foreign animal diseases. In 
2005, we reported that, as part of that strategy, DHS had started to 
develop plans to replace the Plum Island Animal Disease Center with a 
new, modernized facility.[Footnote 2] Since then, DHS has selected six 
possible sites for this new facility, including Plum Island. This 
planned higher-level biosecurity facility will enable the department to 
expand the research currently conducted on the island to include work 
on higher-consequence biological threats posed by zoonotic (i.e., 
transmittable from animals to humans) and foreign animal diseases. 
[Footnote 3] 

Prior to Plum Island's transfer from USDA to DHS, 71 employees of the 
contractor USDA had hired to operate and maintain the facility went on 
strike. This strike, accompanied by sabotage of the island's 
infrastructure, heightened already existing concerns that someone might 
try to steal certain pathogens from the facility to conduct terrorist 
activities. In this context, the Congress asked us to review, among 
other things, the adequacy of security at Plum Island. In 2003, we 
reported that although security at Plum Island had improved since the 
terrorist attacks, the facility was vulnerable to security breaches 
because physical security arrangements were incomplete and limited, 
officials had been assuming unnecessary risks by not adequately 
controlling access to areas where pathogens were located, incident 
response capability was limited, and the full array of risks and 
threats to Plum Island were not sufficiently considered.[Footnote 4] We 
made 24 recommendations to the Secretary of Homeland Security to help 
the department overcome these limitations. DHS agreed with the report 
and its recommendations. 

As a part of our routine audit work, we have been tracking the status 
of the 2003 Plum Island security recommendations. In addition, in May 
2007, we received a request from Senator Charles Schumer to report on 
this matter. On September 28, 2007, we briefed interested congressional 
staff on the extent to which DHS had implemented the recommendations at 
that time. Because of broad-based congressional interest, under the 
Comptroller General's statutory authority to conduct evaluations on his 
own initiative, we are issuing this report, which summarizes that 
briefing. (A list of addressees receiving this report appears on the 
last page of this letter). To evaluate DHS's efforts to implement the 
Plum Island security recommendations, we reviewed pertinent DHS and 
USDA documents; interviewed DHS, USDA, and other personnel responsible 
for Plum Island's security; and, during a visit to Plum Island in 2005, 
observed improvements in physical security and the procedures securing 
the biocontainment area as well as the facility's infrastructure. 
However, we did not conduct a comprehensive audit of all decisions that 
DHS and USDA have made to improve Plum Island security. We provided DHS 
and USDA an opportunity to verify facts of this report. Officials from 
both agencies provided us with additional information, which has been 
incorporated into this report. We performed our work from February 2004 
through December 2007. 

In summary, DHS has made significant progress and has implemented 18 of 
the 24 recommendations. However, implementation of the 6 remaining 
recommendations is still under way. The following highlights DHS 
actions to address our recommendations and discusses those that remain 
in progress. Enclosure I lists all 24 recommendations and their status. 

Addressing Physical Security Deficiencies: 

In 2003, physical security at Plum Island was deficient in several 
ways. For example, alarms and door sensors for detecting intruders were 
not fully operational; controls to account for the keys to the island's 
facilities were deficient; and USDA was not providing sufficient 
physical security for certain assets, including those critical to the 
continued operation of the facility. These vulnerabilities were 
particularly troubling because a strike was under way, and sabotage of 
the island's infrastructure had already occurred. DHS has since taken 
many actions in response to our recommendations. For example, alarms 
and door sensors are now in use, and DHS has implemented procedures to 
better control access to keys to facilities. In addition, the 
department has better secured certain features of the physical 
infrastructure that supports the continued operation of the Plum Island 
Animal Disease Center. DHS has also improved the security of North 
America's only foot-and-mouth disease vaccine bank. This bank 
represents years of cooperative research performed by Canada, Mexico, 
and the United States, and the material it contains is considered a 
critical asset for controlling a large outbreak. 

The implementation of two of our recommendations to enhance physical 
security remains in progress. 

* First, we had reported that the island's contracted security force 
reported to the administrative contract officer rather than to the 
security director--a situation that could have impeded prompt 
resolution of security-related issues. DHS agreed that this was 
problematic and told us the department was initiating changes to the 
security contract that would allow the security force to report 
directly to the security director. DHS also told us that changing the 
contract was dependent on resolution of a contract bid protest of the 
contract award submitted to GAO. Since our briefing, GAO's General 
Counsel has issued a decision leaving DHS free to make the necessary 
contract changes.[Footnote 5] Subsequently, on November 1, 2007, DHS 
entered into a new security contract. DHS officials told us that the 
contract provides for the security force to report directly to the 
security director effective January 1, 2008. 

* Second, we also reported that USDA had no procedure for ensuring that 
contractors and visitors entering the biocontainment area did not have 
criminal backgrounds. We recommended that DHS check the backgrounds of 
these individuals before granting them access, using, for example, the 
National Crime Information Center (NCIC).[Footnote 6] According to DHS 
officials, the department is developing a memorandum of agreement with 
the Federal Protective Service (FPS)[Footnote 7] that will provide full-
time FPS presence on the island with the capability to verify 
contractors' and visitors' backgrounds using NCIC before these 
individuals enter the biocontainment area. However, this agreement has 
not yet been finalized because DHS has not determined how it will pay 
for maintaining FPS on the island 24 hours a day, 7 days a week. The 
expense of this arrangement was not planned for or included in DHS' 
current budget. 

Limiting Access to Pathogens: 

In 2003, we reported that USDA was not adequately controlling access to 
the pathogens. For example, we found that 12 Plum Island employees, 
some with access to pathogens, had not had their background checks 
updated in more than 10 years, even though USDA had told us that 
background checks were updated every 5 years. Also, we found that as 
many as five cleaning, maintenance, and repair staff--who are not 
required to have background checks but are required to be escorted by 
an approved individual--were working in the biocontainment area without 
escorts. DHS has taken several actions in response to our 
recommendations. For example, DHS has developed a process to update 
background checks on a regular basis and has developed a line-of-sight 
escort policy that requires all cleaning, maintenance, and repair staff 
entering the biocontainment area to be continually monitored by 
individuals with completed background checks. According to DHS 
officials, if an escort is not available, unapproved individuals are 
not permitted access to the area. 

However, DHS has not fully implemented our recommendation that the 
department ensure that individuals involved in laboratory activities in 
the biocontainment area--including students and regardless of 
citizenship--be approved in accordance with the law. Specifically, in 
2003, we reported that USDA did not require background checks on 
students attending its foreign animal disease diagnostic classes that 
were regularly held in the biocontainment area. We stated that this 
practice might not have been consistent with the regulations 
implementing the Agricultural Bioterrorism Preparedness Act of 
2002.[Footnote 8] According to the regulations, individuals with access 
to pathogens should undergo background investigations. However, these 
regulations also allow the Administrator of USDA's Animal and Plant 
Health Inspection Service to exempt individuals from background 
investigations if the Administrator determines there is good cause and 
if doing so is consistent with protecting animal health or animal 
products. 

USDA officials recently told us that it has provided such an exemption 
for the students attending its foreign animal disease diagnostic 
classes. USDA's position is that background investigations are not 
required because the risk of a student removing a pathogen is 
exceedingly low, largely due to what USDA calls "unique and 
extraordinary security measures" it has taken for students. According 
to USDA, these measures include denying students access to areas where 
pathogens are stored or equipment necessary to extract the pathogen 
from the tissue of the infected animal; not allowing students to 
inoculate animals with the pathogens or to analyze animal tissue or to 
isolate the disease from tissues; requiring students to be escorted at 
all times by approved individuals while in the biocontainment area; and 
requiring students to shower twice and completely change clothing 
between showers while being continuously escorted. Any remaining risk 
is acceptable, according to USDA, given the catastrophic risks 
associated with not having adequately trained professionals who can 
accurately diagnose and treat foreign animal diseases. 

While we recognize the importance of maintaining a cadre of trained 
animal disease professionals, we continue to find it troubling that 
students are not subject to any type of background check before 
handling animals infected with diseases that have been determined to 
pose a severe threat to animal health and the economy. DHS officials 
recently told us that they are conducting background checks on 
international visitors, including those attending the foreign animal 
disease diagnostic classes. DHS officials also plan to do background 
checks on all individuals entering the biocontainment area using NCIC, 
once FPS is on the island full time. However, DHS does not yet have a 
firm timetable for when this will take place. Until this occurs, DHS 
continues to follow USDA policy permitting U.S. students to attend the 
classes without background checks. 

Enhancing Incident Response Capability: 

In 2003, we also found the island's incident response capability to be 
limited. For example, although the small guard force carried firearms, 
it was not authorized to do so; and no policy was put in place defining 
if, when, and how guards should use their weapons. In addition, because 
no formal arrangements with local law enforcement existed in 2003, Plum 
Island officials were unable to predict the extent to which surrounding 
localities would provide backup assistance during an incident. DHS has 
since taken actions to overcome these response limitations. For 
example, the guard force on the island is now authorized to carry 
weapons, in accordance with New York state law, and policies and 
procedures are in place detailing how guards should deal with 
intruders. DHS also recently established a memorandum of agreement with 
the town of Southold, NY, to provide law enforcement backup assistance 
when necessary. As a result, even though the guards do not yet have 
arrest authority, they can detain an individual on the island until 
Southold police arrive and make arrests, if necessary. The agreement 
with Southold also defines response times according to the type of 
assistance required--such as marine and canine patrol support--and 
provides for additional support from the Suffolk County Police 
Department--such as helicopters, explosive ordinance disposal 
capability, and other incident response assets--when warranted. 

The implementation of two of our recommendations to enhance incident 
response capability remains in progress. 

* First, we recommended that DHS develop an incident response plan that 
included precise detail about what to do if an incident occurred that 
exceeded the capability of the security system, such as a terrorist 
attack. In 2003, the island's incident response plan contained certain 
elements required under USDA regulation, such as how to respond to a 
bomb threat, but the plan did not clearly lay out the actions to be 
taken for incidents exceeding Plum Island's security capabilities. This 
was critical because at that time, according to DHS officials, the 
nation faced a significant risk of a terrorist attack. Although, in 
January 2007, DHS entered into a memorandum of agreement to obtain 
backup assistance from the town of Southold, DHS has not yet updated 
its incident response plan reflecting these new capabilities, but told 
us it intends to do so. 

* Second, we recommended that DHS conduct exercises with local law 
enforcement to test the efficiency and effectiveness of Plum Island's 
response capability. DHS agreed that it would be important to conduct 
such exercises once arrangements with local law enforcement were made. 
DHS conducted one exercise with the U.S. Coast Guard in 2006 to test 
response to a simulation involving a suspicious boat approaching the 
island. In addition, DHS recently informed us that, in November 2007, 
it conducted a security exercise with more than 40 law enforcement 
officials. While these exercises are positive developments, further 
steps are needed, including testing the effectiveness of the response 
plan once it reflects lessons learned from these exercises and the new 
arrangements with local law enforcement. 

Reevaluating Risks and Threats: 

Finally, in 2003, USDA had not sufficiently reevaluated the extent of 
the risks and threats to the security of Plum Island. For example, USDA 
had identified a list of threats that applied to all of its 
laboratories, but it had not reviewed these 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. The FBI, Suffolk County officials, and others told us at 
the time that they considered this step to be very important. DHS has 
since taken actions to respond to our recommendations to reconsider 
risks and threats to the security of Plum Island. For example, DHS 
officials told us they consult regularly with appropriate local law 
enforcement and intelligence agencies--including the U.S. Coast Guard, 
the FBI, FPS, and the Southold Police Department--to reconsider and 
update threats specific to Plum Island. 

Implementation of one of our recommendations to reevaluate the risks 
and threats to Plum Island remains in progress. Specifically, we 
recommended that DHS revise, as necessary, security and incident 
response plans to reflect any redefined risks, threats, and assets. 
Although we have asked DHS officials to provide us with an updated 
security plan, we have not seen evidence that the security plan has 
been reviewed since 2004. 

Concluding Observations: 

DHS has made significant progress in the years since 2003, implementing 
most of our recommendations. Whether Plum Island continues to operate 
in its current capacity: 

or as a higher level biosecurity facility, it is important that DHS 
fully implement the remaining recommendations to reduce the risk of 
pathogen theft and to enhance response capabilities at Plum Island. 

We are sending copies of this report to the appropriate congressional 
committees, the Secretaries of Agriculture and Homeland Security, and 
other interested parties. We will also make copies available to others 
upon request. In addition, the report will be available at no charge on 
the GAO Web site at [hyperlink, http://www.gao.gov]. 

If you or your staff have any questions about this report or need 
additional information, 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 enclosure II. 

Signed by: 

Lisa Shames: 
Director, Natural Resources and Environment: 

Enclosures: 

[End of section] 

List of Congressional Addresses: 

The Honorable Tom Harkin:
Chairman:
The Honorable Saxby Chambliss:
Ranking Member:
Committee on Agriculture, Nutrition and Forestry:
United States Senate: 

The Honorable Joseph Lieberman:
Chairman:
The Honorable Susan M. Collins:
Ranking Member:
Committee on Homeland Security and Governmental Affairs:
United States Senate: 

The Honorable Collin C. Peterson:
Chairman:
The Honorable Bob Goodlatte:
Ranking Member:
Committee on Agriculture:
House of Representatives: 

The Honorable John D. Dingell, Jr.
Chairman:
The Honorable Joe Barton:
Ranking Member:
Committee on Energy and Commerce:
House of Representatives: 

The Honorable Bennie G. Thompson:
Chairman:
The Honorable Peter T. King:
Ranking Member:
Committee on Homeland Security:
House of Representatives: 

The Honorable Tom Davis:
Ranking Member:
Committee on Oversight and Government Reform:
House of Representatives: 

The Honorable Herb Kohl:
Chairman:
The Honorable Robert Bennett:
Ranking Member:
Subcommittee on Agriculture, Rural Development, Food and Drug 
Administration, and Related Agencies:
Committee on Appropriations:
United States Senate: 

The Honorable Robert C. Byrd:
Chairman:
The Honorable Thad Cochran:
Ranking Member:
Subcommittee on Homeland Security:
Committee on Appropriations:
United States Senate: 

The Honorable Rosa L. DeLauro:
Chairman:
The Honorable Jack Kingston:
Ranking Member:
Subcommittee on Agriculture, Rural Development, FDA and Related 
Agencies:
Committee on Appropriations:
House of Representatives: 

The Honorable Jim Langevin:
Chairman:
The Honorable Michael T. McCaul:
Ranking Member:
Subcommittee on Emerging Threats, Cybersecurity, and Science and 
Technology:
Committee on Homeland Security:
House of Representatives: 

The Honorable Bart Stupak:
Chairman:
The Honorable John M. Shimkus:
Ranking Member:
Subcommittee on Oversight and Investigations:
Committee on Energy and Commerce:
House of Representatives: 

The Honorable Harold Rogers:
Ranking Member:
Subcommittee on Homeland Security:
Committee on Appropriations:
House of Representatives: 

The Honorable Hillary Rodham Clinton:
The Honorable Charles E. Schumer:
United States Senate: 

The Honorable Tim Bishop:
The Honorable Steve Israel:
House of Representatives: 

[End of section] 

Enclosure I: 

Status of GAO Recommendations on Plum Island Physical Security as of 
December 2007: 

Recommendation: Addressing physical security deficiencies; 
1. Fully implement the physical security measures; 
Status: Implemented. 

Recommendation: Addressing physical security deficiencies; Address the 
specific security shortcomings identified by our Office of Special 
Investigations; 
2. 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; 
Status: In progress. 

Recommendation: Addressing physical security deficiencies; Address the 
specific security shortcomings identified by our Office of Special 
Investigations; 
3. There are no name 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 Crime Information Center) before they are granted access; 
Status: In progress. 

Recommendation: Addressing physical security deficiencies; Address the 
specific security shortcomings identified by our Office of Special 
Investigations; 
4. 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; 
Status: Implemented. 

Recommendation: Addressing physical security deficiencies; Address the 
specific security shortcomings identified by our Office of Special 
Investigations; 
5. 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; 
Status: Implemented. 

Recommendation: Addressing physical security deficiencies; Address the 
specific security shortcomings identified by our Office of Special 
Investigations; 
6. 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; 
Status: Implemented. 

Recommendation: Addressing physical security deficiencies; Address the 
specific security shortcomings identified by our Office of Special 
Investigations; 
7. 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; 
Status: Implemented. 

Recommendation: Addressing physical security deficiencies; Address the 
specific security shortcomings identified by our Office of Special 
Investigations; 
8. Control for keys and master keys of the facility are 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; 
Status: Implemented. 

Recommendation: Addressing physical security deficiencies; 
9. Better secure certain features of the physical infrastructure that 
supports the continued operation of the Plum Island Animal Disease 
Center; Status: Implemented. 

Recommendation: Addressing physical security deficiencies; 
10. Better secure the foot-and-mouth disease vaccine bank; 
Status: Implemented. 

Recommendation: Limiting access to pathogens; 
11. Ensure 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; 
Status: In progress. 

Recommendation: Limiting access to pathogens; 
12. Ensure that background checks of individuals involved in laboratory 
activities in biocontainment are updated regularly; 
Status: Implemented. 

Recommendation: Limiting access to pathogens; 
13. Ensure that cleaning, maintenance, and repair staff entering the 
biocontainment area are escorted at all times by individuals with 
completed background checks; 
Status: Implemented. 

Recommendation: Limiting access to pathogens; 
14. Consult with other laboratories to identify ways to mitigate the 
inherent difficulty of securing pathogens; 
Status: Implemented. 

Recommendation: Enhancing incident response capability; 
15. Resolve the issue of the guards' authority to carry firearms and 
make arrests; 
Status: Implemented. 

Recommendation: Enhancing incident response capability; 
16. Develop and implement a policy on how guards should deal with 
intruders and use weapons; 
Status: Implemented. 

Recommendation: Enhancing incident response capability; 
17. Increase the size of the guard force; 
Status: Implemented. 

Recommendation: Enhancing incident response capability; 
18. Complete an agreement with local law enforcement agencies to ensure 
backup assistance when needed; 
Status: Implemented. 

Recommendation: Enhancing incident response capability; 
19. Define an adequate response time for law enforcement to respond to 
incidents; 
Status: Implemented. 

Recommendation: Enhancing incident response capability; 
20. Develop 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; 
Status: In progress. 

Recommendation: Enhancing incident response capability; 
21. Conduct exercises with local law enforcement to test the efficiency 
and effectiveness of Plum Island's response capability; 
Status: In progress. 

Recommendation: Reevaluating risks and threats; 
22. Reconsider the security risks at Plum Island, taking into account 
recent acts of disgruntled employees; 
Status: Implemented. 

Recommendation: Reevaluating risks and threats; 
23. Consult with appropriate state and local law enforcement and 
intelligence agencies to revisit the threats specific to the Plum 
Island Animal Disease Center; 
Status: Implemented. 

Recommendation: Reevaluating risks and threats; 
24. Revise, as necessary, security and incident response plans to 
reflect any redefined risks, threats, and assets; 
Status: In progress. 

Source: GAO. 

Note: The recommendations listed in this table were made in GAO-03-847. 

[End of table] 

[End of enclosure] 

Enclosure II: 

GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Lisa Shames, (202) 512-3841, or shamesl@gao.gov: 

Staff Acknowledgments: 

In addition to the individual named above, Charles Adams, Assistant 
Director, and Mary Denigan-Macauley made key contributions to this 
report. Kevin Bray, Nancy Crothers, Jennifer Gregory, Barbara 
Patterson, and Raymond Rodriguez also made important contributions. 

[End of enclosure] 

Footnotes: 

[1] The Homeland Security Act of 2002 (Pub. L. No. 107-296, 310, 116 
Stat. 2135, 2174). 

[2] See GAO, Plum Island Animal Disease Center: DHS and USDA Are 
Successfully Coordinating Current Work, but Long-Term Plans Are Being 
Assessed, GAO-06-132 (Washington, D.C.: Dec. 19, 2005). 

[3] For more information on higher-level biosecurity facilities see 
GAO, High-Containment Biosafety Laboratories: Preliminary Observations 
on the Oversight of the Proliferation of BSL-3 and BSL-4 Laboratories 
in the United States, GAO-08-108T (Washington, D.C.: Oct. 4, 2007). 

[4] GAO, Combating Bioterrorism: Actions Needed to Improve Security at 
Plum Island Animal Disease Center, GAO-03-847 (Washington, D.C.: Sept. 
19, 2003). 

[5] See M&M Investigations, Inc., B-299369.2, B-299369.3, Oct. 24, 
2007, 2007 CPD. 

[6] NCIC is operated by the Federal Bureau of Investigation (FBI) and 
provides federal, state, and local law enforcement and other criminal 
justice agencies with, among other things, information on criminal 
history records. 

[7] FPS transferred from the General Services Administration to DHS in 
March 2003 and has responsibility for protecting federal facilities. 

[8] See Pub. L. No. 107-188, Tit. II,  212, 116 Stat. 647. 

[End of section] 

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