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Report to Congressional Requesters: 

March 2005: 

Homeland Security: 

Much Is Being Done to Protect Agriculture from a Terrorist Attack, but 
Important Challenges Remain: 

GAO-05-214: 

GAO Highlights: 

Highlights of GAO-05-214, a report to congressional requesters: 

Why GAO Did This Study: 

U.S. agriculture generates more than $1 trillion per year in economic 
activity and provides an abundant food supply for Americans and others. 
Since the September 11, 2001, attacks, there are new concerns about the 
vulnerability of U.S. agriculture to the deliberate introduction of 
animal and plant diseases (agroterrorism). Several agencies, including 
the U.S. Department of Agriculture (USDA), the Department of Homeland 
Security (DHS), the Department of Health and Human Services (HHS), the 
Environmental Protection Agency (EPA), and the Department of Defense 
(DOD), play a role in protecting the nation against agroterrorism. GAO 
examined (1) the federal agenciesí roles and responsibilities to 
protect against agroterrorism, (2) the steps that the agencies have 
taken to manage the risks of agroterrorism, and (3) the challenges and 
problems that remain. 

What GAO Found: 

After the terrorist attacks of September 11, 2001, federal agenciesí 
roles and responsibilities were modified in several ways to help 
protect agriculture from an attack. First, the Homeland Security Act of 
2002 established DHS and, among other things, charged it with 
coordinating U.S. efforts to protect against agroterrorism. The act 
also transferred a number of agency personnel and functions into DHS to 
conduct planning, response, and recovery efforts. Second, the President 
signed a number of presidential directives that further define 
agenciesí specific roles in protecting agriculture. Finally, Congress 
passed legislation that expanded the responsibilities of USDA and HHS 
in relation to agriculture security.

In carrying out these new responsibilities, USDA and other federal 
agencies have taken a number of actions. The agencies are coordinating 
development of plans and protocols to better manage the national 
response to terrorism, including agroterrorism, and, along with several 
states, have conducted exercises to test these new protocols and their 
response capabilities. Federal agencies also have been conducting 
vulnerability assessments of the agriculture infrastructure; have 
created networks of laboratories capable of diagnosing animal, plant, 
and human diseases; have begun efforts to develop a national veterinary 
stockpile that intends to include vaccines against foreign animal 
diseases; and have created new federal emergency coordinator positions 
to help states develop emergency response plans for the agriculture 
sector.

However, the United States still faces complex challenges that limit 
the nationís ability to respond effectively to an attack against 
livestock. For example, USDA would not be able to deploy animal 
vaccines within 24 hours of an outbreak as called for in a presidential 
directive, in part because the only vaccines currently stored in the 
United States are for strains of foot and mouth disease, and these 
vaccines need to be sent to the United Kingdom (U.K.) to be activated 
for use. There are also management problems that inhibit the 
effectiveness of agenciesí efforts to protect against agroterrorism. 
For instance, since the transfer of agricultural inspectors from USDA 
to DHS in 2003, there have been fewer inspections of agricultural 
products at the nationís ports of entry. 

Burning Carcasses during the 2001 U.K. Outbreak of Foot and Mouth 
Disease: 

What GAO Recommends: 

To enhance the agenciesí ability to reduce the risk of agroterrorism, 
GAO recommends, among other things, that (1) USDA examine the costs and 
benefits of developing stockpiles of ready-to-use vaccines and (2) DHS 
and USDA determine the reasons for declining agricultural inspections. 
USDA, DHS, and HHS generally agreed with our recommendations. DOD and 
EPA made technical comments but took no position on the reportís 
recommendations.

www.gao.gov/cgi-bin/getrpt?GAO-05-214.

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact Robert Robinson, 202-512-
3841, Robinsonr@gao.gov.

[End of section]

Contents: 

Letter: 

Results in Brief: 

Background: 

Federal Agencies' Roles and Responsibilities Were Modified to Protect 
against Agroterrorism: 

Since the Terrorist Attacks of 2001, Federal Agencies Have Taken Steps 
to Manage the Risks of Agroterrorism: 

The United States Still Faces Complex Challenges and Management 
Problems in Protecting against Agroterrorism: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Response: 

Appendixes: 

Appendix I: Scope and Methodology: 

Appendix II: List of Experts GAO Consulted and Summary of Observations: 

Appendix III: Animal and Plant Diseases that Pose a Severe Threat to 
Agriculture: 

Appendix IV: U.S. Concentration of Cattle, Chicken, and Corn Production 
in 2002: 

Appendix V: Additional Information on National and Agency-Specific 
Steps Taken to Protect against Agroterrorism: 

Appendix VI: Comments from the U.S. Department of Agriculture: 

GAO Comments: 

Appendix VII: Comments from the Department of Homeland Security: 

GAO Comments: 

Appendix VIII: Comments from the Department of Health and Human 
Services: 

Appendix IX: GAO Contacts and Staff Acknowledgments: 

GAO Contacts: 

Acknowledgments: 

Related GAO Products: 

Tables: 

Table 1: List of Select Animal Diseases Identified by USDA Pursuant to 
the Bioterrorism Act of 2002 as a Severe Threat to the Livestock 
Industry and Human Health: 

Table 2: List of All Plant Diseases Identified by USDA as Severe 
Threats to Plants Pursuant to the Bioterrorism Act of 2002: 

Figures: 

Figure 1: Top Hog-Producing States in 2002: 

Figure 2: Top Soybean-Producing States in 2002: 

Figure 3: Agricultural Inspector Transferred to DHS Inspecting Suspect 
Cargo: 

Figure 4: Federal Agencies' Roles and Responsibilities as Defined by 
Homeland Security Presidential Directive 9: 

Figure 5: Game Bird Infected with Exotic Newcastle Disease during the 
2002-2003 Outbreak in California: 

Figure 6: Top Cattle-Producing States in 2002: 

Figure 7: Top Chicken-Producing States in 2002: 

Figure 8: Top Corn-Producing States in 2002: 

Abbreviations: 

APHIS: Animal Plant Health Inspection Service: 

ARS: Agricultural Research Service: 

CBP: Customs and Border Protection: 

CDC: Centers for Disease Control and Prevention: 

DHS: Department of Homeland Security: 

DOD: Department of Defense: 

EPA: Environmental Protection Agency: 

FDA: Food and Drug Administration: 

FEMA: Federal Emergency Management Agency: 

FMD: foot and mouth disease: 

GAO: Government Accountability Office: 

HHS: Health and Human Services: 

HSPD: Homeland Security Presidential Directive: 

NVSL: National Veterinary Services Laboratories: 

OIE: Office Internationale des Epizooties: 

PPQ: Plant Protection and Quarantine: 

USDA: United States Department of Agriculture: 

Letter March 8, 2005: 

The Honorable Daniel K. Akaka: 
Ranking Minority Member: 
Subcommittee on Oversight of Government Management, the Federal 
Workforce, and the District of Columbia: 
Committee on Homeland Security and Governmental Affairs: 
United States Senate: 

The Honorable Bennie G. Thompson: 
Ranking Minority Member: 
Committee on Homeland Security: 
House of Representatives: 

U.S. agriculture annually generates more than $1 trillion in economic 
activity, including more than $50 billion in exports, and provides an 
abundant and economical supply of food for Americans and others around 
the world.[Footnote 1] Protecting agriculture is therefore critically 
important to the well-being of Americans and the U.S. economy. While 
the United States has never experienced a terrorist attack against 
agriculture, this important industry is vulnerable for a variety of 
reasons, including the relative ease with which livestock and crop 
diseases could be obtained and disseminated. Many of these diseases are 
endemic in other parts of the world and can be extracted from common 
materials, such as soil. Farms in general are easily accessible because 
they are located in rural areas and have minimal security, especially 
crop farms. Moreover, the highly concentrated breeding and rearing 
practices of our livestock industry make it a vulnerable target for 
terrorists because diseases could spread rapidly and be very difficult 
to contain. For example, between 80 and 90 percent of grain-fed beef 
cattle production is concentrated in less than 5 percent of the 
nation's feedlots. Therefore, the deliberate introduction of a highly 
contagious animal disease in a single feedlot could have serious 
economic consequences.

Most experts believe that the major effect of an attack on agriculture 
would be economic.[Footnote 2] While many animal diseases are not 
transmissible to humans, others are, and when this occurs there could 
be serious human health consequences. For example, one of these 
transmissible diseases, avian influenza, has caused 42 human deaths in 
Asia since January 2004, when accidental outbreaks infected poultry 
flocks. Experts also believe that livestock and poultry are more likely 
to be targets of a terrorist attack than crops because deliberately 
spreading plant diseases is inherently more difficult, requiring, among 
other things, favorable weather conditions such as wind. One scenario 
of particular concern is the intentional introduction of foot and mouth 
disease, a highly contagious livestock disease that does not typically 
affect humans. The 2001 accidental outbreak of the disease in the 
United Kingdom caused approximately $5 billion dollars in losses to the 
food and agriculture sector, as well as comparable losses in the 
tourism industry. By the time this disease was eradicated, over 4 
million animals had been slaughtered and burned, and the nation was 
banned from exporting livestock and animal products that could transmit 
the virus. Numerous other animal and plant diseases are also of 
concern, including classical swine fever and soybean rust. Appendix III 
provides information on the animal and plant diseases of primary 
concern that the U.S. Department of Agriculture (USDA) believes could 
be used in an attack against agriculture.

In 1998, we reported that the United States did not have a process in 
place to detect and respond to a terrorist attack against agriculture 
and that if such an attack were to occur, the country would rely on the 
process used to respond to naturally occurring diseases.[Footnote 3] 
Specifically, we reported that USDA--the agency primarily responsible 
for responding to major outbreaks of disease involving livestock, 
poultry, and crops--lacked a comprehensive, national strategy for 
responding to a widespread attack. Among the problems we identified 
were concerns about the ability of farmers, local veterinarians, and 
other experts to detect, correctly identify, and report cases of 
disease in a timely manner.[Footnote 4] We also found that some states 
had not developed or tested emergency response plans.

Since we last reported, the terrorist attacks of September 11, 2001, 
have heightened concerns about agriculture's vulnerability to 
terrorism, including the deliberate introduction of livestock, poultry, 
and crop diseases. Attacks targeted at agriculture are commonly 
referred to as agroterrorism. For the purposes of this report, 
"agroterrorism" refers to the deliberate introduction of animal and 
plant diseases at the farm level, prior to further processing or 
production. Although other definitions of agroterrorism can be broader 
and include the entire food chain, our definition does not refer to the 
deliberate contamination of manufactured food items, which was outside 
the scope of this review. In this context, you asked that we address 
(1) changes that have taken place since September 2001 in the roles and 
responsibilities of federal agencies to protect against agroterrorism, 
(2) specific steps that the United States has taken to manage the risks 
of agroterrorism, and (3) what challenges and problems remain.

To identify the changes in agencies' roles and responsibilities to 
protect against agroterrorism, we reviewed laws, regulations, and 
presidential directives prior to and after the terrorist attacks of 
September 11, 2001. We also interviewed officials from the Department 
of Homeland Security (DHS); the USDA; the Food and Drug Administration 
(FDA)[Footnote 5] and Centers for Disease Control and Prevention (CDC) 
within the Department of Health and Human Services (HHS); the 
Environmental Protection Agency (EPA); the Department of Defense (DOD); 
and the Department of Justice. To examine the specific steps that the 
United States has taken to manage the risks of agroterrorism, we 
reviewed and analyzed unclassified agency documents and contacted 
federal and state offices of Inspectors General to assess what work has 
been done in relation to agroterrorism.[Footnote 6] We also conducted 
structured interviews in person or via telephone with officials in five 
states, selected in part for their leading role in producing 
agricultural commodities sold before processing. These officials 
included representatives from state departments of agriculture, 
emergency management, and homeland security offices; agricultural 
inspectors from DHS and USDA; and veterinarians, plant health, and 
other officials from regional USDA and FDA offices. We examined the 
steps taken by the agencies in the context of our work on homeland 
security risk management.[Footnote 7] To determine what challenges may 
remain, we conducted structured interviews with experts from academia, 
private think tanks, and other research institutions. We also reviewed 
an extensive body of relevant literature, attended conferences, and 
spoke with industry and agency officials. Additional details about the 
scope and methodology of our review are presented in appendix I. We 
conducted our review from February 2004 through January 2005 in 
accordance with generally accepted government auditing standards.

Results in Brief: 

Since the terrorist attacks of 2001, federal agencies' roles and 
responsibilities have been modified to protect against agroterrorism. 
Under the Homeland Security Act of 2002, DHS was established and 
charged with responsibility for coordinating national efforts to 
protect against terrorism, including agroterrorism. As a result of this 
legislation, DHS also assumed responsibility for certain functions 
previously performed by other agencies, and some personnel who 
performed those functions were transferred to DHS. For example, the 
Federal Emergency Management Agency (FEMA), including its personnel, 
was transferred to DHS which gave it the responsibility for planning 
for emergencies and major disasters. Most of USDA's agricultural 
inspectors were transferred to DHS, although USDA retains some 
functions related to inspecting agricultural products, such as 
conducting specialized inspections; developing and supervising 
training; and developing policies and procedures. This transfer gave 
DHS the role to prevent the entry of infectious diseases and pests into 
the United States. As a part of this transfer, DHS and USDA signed an 
interagency memorandum of agreement that, among other things, 
authorized USDA to request the use of DHS inspectors during a major 
outbreak--whether intentional or natural--of agricultural pests and 
diseases. Also, a number of presidential directives were issued that 
further define agencies' roles and responsibilities for protecting 
against agroterrorism. For example, Homeland Security Presidential 
Directive (HSPD)-9 defines how the various agencies will work together 
to protect the agriculture and food industries. Legislation has also 
expanded the responsibilities of USDA and HHS. Specifically, through 
the Public Health Security and Bioterrorism Preparedness and Response 
Act of 2002 (the "Bioterrorism Act of 2002"), USDA and HHS gained 
authority to regulate agents and toxins that pose a serious threat to 
public health, animals, plants, and animal and plant products. The 
agencies believe these agents could be used in a terrorist attack.

In carrying out their new roles and responsibilities, federal agencies 
have taken steps to better manage the risks of agroterrorism, including 
development of national plans and the adoption of standard protocols. 
For example, DHS led the development of a National Response Plan that, 
for the first time, spells out how the nation would work together in 
the event of a terrorist attack on its critical infrastructure sectors, 
including agriculture. In addition, federal agencies have adopted 
standard protocols for managing such emergencies and, through federal 
grants, have provided incentives for states to adopt similar protocols. 
Among other things, these protocols include establishing emergency 
operation centers and a chain of command. To test these protocols and 
response capability in general, federal and state officials are 
conducting test exercises. At the federal level, a number of other 
agency-specific actions are also under way, including the following: 

* FDA and USDA are in varying stages of conducting vulnerability 
assessments to determine which agricultural products are most 
vulnerable to terrorist attacks.

* USDA and HHS are enhancing their diagnostic and monitoring capability 
by creating laboratory networks.

* Agencies have formed numerous working groups to protect agriculture. 
For example, DHS created a Food and Agriculture Sector Coordinating 
Council to help the federal government and industry share ideas about 
how to mitigate the risk of an attack on agriculture. DHS recently 
created a Government Coordinating Council to oversee the tasks of the 
various working groups.

* USDA has established a steering committee to guide efforts to develop 
a National Veterinary Stockpile that, among other things, is intended 
to address what vaccines are needed to respond to animal diseases most 
damaging to human health and the economy.

* DHS, USDA, and HHS have funded research to address a range of issues 
related to agroterrorism. For example, DHS provided $33 million in 2004 
to establish two university-based Centers of Excellence to oversee 
research on post-harvest food protection and on diseases that affect 
livestock and poultry.

* USDA created 16 Area and Regional Emergency Coordinator positions to 
help states develop individual emergency response plans and to serve as 
a technical resource for states, industry, and other stakeholders.

While these actions are important and necessary steps, the United 
States still faces several complex challenges that limit the nation's 
ability to quickly and effectively respond to a widespread attack on 
livestock and poultry: 

* Many United States' veterinarians lack training needed to recognize 
the signs of foreign animal diseases. According to a 2004 report 
produced for USDA, while all U.S. veterinary schools offer information 
about foreign animal diseases, only about 26 percent of their graduates 
have taken a course specifically dedicated to foreign animal diseases. 
Furthermore, foreign animal disease training is not required for USDA- 
accredited veterinarians, the ones most likely to be called upon if 
livestock were attacked. Two years ago, USDA drafted a rule to make 
such training a prerequisite for accreditation, but other draft rules 
have taken precedence and caused it to be delayed.

* USDA does not use rapid diagnostic tools to test animals at the site 
of an outbreak. They employ this technology only within selected 
laboratories. According to experts, on-site use of these tools is 
critical to speeding diagnosis, containing the disease, and minimizing 
the number of animals that need to be slaughtered. DOD uses rapid 
diagnostic tools to identify disease agents on the battlefield, but 
USDA officials consider this technology to be still under development. 
Nevertheless, USDA officials told us that they agree it is important to 
evaluate the costs and benefits of developing and validating these 
tools for use outside of a laboratory setting.

* Vaccines cannot be deployed within 24 hours of an outbreak as called 
for in HSPD-9. First, supplies are limited because USDA maintains 
vaccines for only one foreign animal disease--foot and mouth disease-- 
since this disease is so highly contagious. USDA generally prefers to 
immediately slaughter diseased animals rather than to vaccinate them. 
Also, these vaccines cannot be rapidly deployed because they are not 
stored in a "ready-to-use" state and would first need to be sent to the 
United Kingdom for bottling and testing. USDA officials told us that it 
has recently established a steering committee that will address vaccine 
stockpiling issues, but it is not clear that the committee will address 
the costs and benefits of developing ready-to-use vaccines that can be 
quickly deployed against animal diseases of primary concern.

* Current USDA policy requires a complex process for deciding if and 
when to use vaccines--a process that could be too lengthy during an 
attack. USDA officials agree that they can explore the possibility of 
designing a more rapid decision-making process but cautioned this 
process is complex and takes into consideration many variables, such as 
the location of outbreaks in relation to susceptible animal 
populations, as well as trade concerns and restrictions.

We also found several management problems that reduce the effectiveness 
of the agencies' routine efforts to protect against agroterrorism.

* Agricultural inspections at ports of entry--the first line of defense 
against the entry of foreign animal and plant diseases--have declined 
over the past 2 years at a time when imports have increased. Neither 
USDA nor DHS officials can fully explain why this drop occurred. Since 
the transfer of most USDA agricultural inspectors to DHS, data show a 
decline in the number of agricultural inspections at ports of entry 
nationwide from 40.9 million in fiscal year 2002, when USDA was fully 
responsible for agricultural inspections, to 37.5 million in fiscal 
year 2004, when DHS had primary responsibility. However, officials 
pointed out some factors that may be contributing to this reduction, 
most importantly, the large number of unfilled vacancies for 
agricultural inspectors. DHS officials told us they plan to address 
this shortage by hiring more than 500 inspectors by fiscal year 2006, 
but also stated that the ability to hire and deploy new inspectors is 
impeded by the length of time needed for background checks. Inspectors 
also told us that another factor contributing to the decline in 
inspections is that they do not always receive timely information about 
high-risk cargo that needs to be inspected. While DHS officials told us 
these instances represent a small fraction of inspections, they agreed 
that changes can be made to improve the flow of information.

* There are weaknesses regarding the flow of critical information among 
key stakeholders. First, DHS is not promptly and effectively seeking 
input from key stakeholders on critical national guidance documents. 
For example, officials in key agricultural states and industry 
representatives told us that DHS did not give them enough time to 
review and comment on draft federal guidance, including the National 
Response Plan. As a result, state officials and industry 
representatives we spoke with are concerned that the response plan may 
set unrealistic expectations regarding the states' capabilities to meet 
the requirements of the plan. Second, "after-action" reports on the 
results of national and state-level test exercises that simulate the 
consequences of a major agroterrorism event and test the response 
capabilities needed to manage such an event, are not systematically 
shared among key stakeholders. DHS officials told us that they are 
developing a Homeland Security Information Network that could 
facilitate sharing this information.

* States are not receiving sufficient technical federal assistance in 
developing emergency response plans and other activities to effectively 
prepare them to deal with agroterrorism. This lack of assistance 
results in part from implementation problems associated with the Area 
and Regional Emergency Coordinators positions--USDA has not yet filled 
all 16 of these positions. USDA officials told us they face 
difficulties hiring these coordinators due to the extensive travel 
required since each coordinator must cover a broad geographic area. 
Federal and state officials we interviewed told us that, even if the 
vacancies were filled, the current number of emergency coordinators is 
insufficient, as each coordinator is responsible for up to 6 states on 
the animal health side and 27 states on the plant side.

* Shortcomings exist in DHS' coordination of federal working groups and 
research efforts. Although DHS has lead responsibility for coordinating 
efforts to protect against agroterrorism, officials from other agencies 
told us that the tasks assigned to various interagency working groups 
are not consistent with activities outlined in national guidance, 
including important documents such as the National Response Plan. This 
could lead to confusion and undermine the efforts of "national" 
planning. DHS has also not developed controls to coordinate research 
efforts with other agencies, even though HSPD-9 specifically designates 
DHS as the agency responsible for coordinating research efforts to 
protect against agroterrorism. For example, some of the DHS-supported 
activities at the Centers of Excellence, such as vaccine research, 
appear to duplicate research conducted by USDA. USDA officials told us 
they agree that there needs to be more coordination and cooperation 
between USDA and DHS on research activities.

* Finally, while steps are being taken to integrate agencies' 
diagnostic laboratory networks, USDA has not yet integrated the 
databases of the member laboratories within its own networks, nor have 
they integrated with HHS laboratories for diseases of common concern. 
As a result, USDA's ability to look at diagnostic data from across the 
country, detect trends, and implement a response is limited, and HHS 
may not receive timely information from USDA on agricultural diseases 
that could spread to humans. USDA plans to integrate information from 
its laboratory networks for diseases of concern by mid-2005 and has 
established an interagency working group with HHS to discuss 
integrating their respective laboratory networks.

We are making several recommendations aimed at improving agencies' 
efforts to mitigate and quickly and effectively respond to a widespread 
attack on animal agriculture and to address routine management problems 
that impair the agencies' ability to protect against agroterrorism in 
general. For example, we are recommending that the Secretary of 
Agriculture, within the context of the agency's overall risk management 
efforts, expedite the review and issuance of the draft rule on USDA's 
accreditation process for veterinarians, which would require training 
in recognizing foreign animal diseases; evaluate the costs and benefits 
of using rapid diagnostic tools at the site of an outbreak; examine the 
cost and benefits of developing stockpiles of ready-to-use vaccines 
that can be quickly deployed against animal diseases of primary 
concern; and simplify the decision-making process for determining if 
and/or when to use vaccines to control an outbreak to ensure that rapid 
decisions can be made in the event of a terrorist attack. We are also 
recommending that the Secretaries of Agriculture and Homeland Security 
work together to analyze agricultural inspections data to identify 
reasons for the decline in agricultural inspections and areas for 
improvement.

In commenting on a draft of this report, USDA, DHS, and HHS generally 
concurred with the report's recommendations. USDA said that it found 
the report offered a number of insightful and appropriate 
recommendations but also raised some concerns regarding rapid 
diagnostic tools and vaccines. DHS noted that it was in the process of 
implementing several corrective actions in response to our report. HHS 
welcomed the attention to animal diseases. The agencies also provided 
additional information, comments, and clarifications on the report's 
findings that we have addressed as appropriate throughout the report. 
DOD and EPA took no position on the report's contents but provided 
minor technical comments that we incorporated as appropriate.

Background: 

Experts believe that the deliberate introduction of animal and plant 
diseases at the farm level would cause severe economic disruption given 
that agriculture accounts for 13 percent of the U.S. gross domestic 
product and 18 percent of domestic employment. In the event of 
agroterrorism, losses to farmers could result from decreases in the 
price of livestock, poultry, and crops; reductions in sales due to a 
decline or halt in productivity; inability to move animals to the 
market; and costs associated with disease control, including disposal 
of contaminated animals or plants. Losses could be particularly severe 
in states where animal and crop production is concentrated. For 
example, three states produce 53 percent of the total U.S. hog 
production and three states produce 39 percent of the total U.S. 
soybean production.[Footnote 8] (See figs. 1 and 2.) Substantial losses 
could also arise from halting exports; the value of U.S. agricultural 
exports in fiscal year 2003 exceeded $56 billion.

Figure 1: Top Hog-Producing States in 2002: 

[See PDF for image] 

Note: Three states did not disclose their information.

[End of figure] 

Figure 2: Top Soybean-Producing States in 2002: 

[See PDF for image] 

Note: Nine states do not produce soybeans. Six states did not disclose 
their information.

[End of figure] 

USDA has primary responsibility for protecting the agriculture sector. 
Within USDA, the Animal and Plant Health Inspection Service (APHIS) is 
responsible for protecting America's animals and plants from 
agricultural pests and diseases. APHIS's Veterinary Services operates 
the National Veterinary Services Laboratories (NVSL), which is 
responsible for activities such as training and approving personnel 
from state and university diagnostic laboratories to conduct diagnostic 
tests for foreign animal diseases. NVSL is composed of four facilities, 
three of which are located in Ames, Iowa. The fourth, the Foreign 
Animal Disease Diagnostic Laboratory, is located at the Plum Island 
Animal Disease Center off the coast of New York. The Plum Island Animal 
Disease Center also houses the North American Foot and Mouth Disease 
Vaccine Bank.[Footnote 9] Regarding plant health, APHIS' Plant 
Protection and Quarantine (PPQ) program is responsible for safeguarding 
crops from pests and diseases.[Footnote 10]

USDA also supports research into protecting the agricultural sector. 
USDA's Cooperative State Research, Education, and Extension Service 
funds university-based agricultural research, including research on 
agricultural biosecurity. In addition, USDA's in-house research agency, 
the Agricultural Research Service (ARS), conducts research in fields 
that complement homeland security efforts, such as the development of 
vaccines. The Agricultural Research Service also conducts research at 
the Plum Island Animal Disease Center.

USDA's Food Safety and Inspection Service is responsible for the safety 
of meat, poultry, and certain egg products, while FDA is responsible 
for shell eggs, seafood, and milk. In fiscal year 2003, USDA received 
approximately $495 million for homeland security activities, which 
included those that address agroterrorism and other routine USDA 
programs. FDA received approximately $160 million in fiscal year 2003 
for homeland security efforts, including protecting against 
agroterrorism.

Other federal agencies play a part in protecting the agriculture 
sector. Examples include: 

* If an outbreak of zoonotic disease--that is, a disease that can 
infect and possibly cause death to both animals and humans--occurs, CDC 
becomes involved to help control the spread of the disease and minimize 
the impact of the outbreak.

* In the event of a disease outbreak, EPA provides technical support to 
federal and state agencies and the private sector to ensure protection 
of land, drinking water, and air from potential contamination 
associated with the disposal of diseased animal carcasses and infected 
plant material. EPA is also responsible for reviewing and approving the 
use of pesticides to prevent the spread of crop and animal diseases, 
both during an emergency and for prevention purposes.

* In the event of an agricultural emergency that USDA cannot handle 
alone, DOD provides veterinarians from its Veterinary Corps to USDA 
under a Memorandum of Understanding. In addition, the U.S. Army Medical 
Research Institute of Infectious Diseases in Fort Detrick, Maryland, 
conducts research designed to help protect soldiers from diseases, 
including many that are zoonotic and may be potential agroterrorism 
threats.

International organizations also play a role, particularly the Office 
Internationale des Epizooties (OIE), an organization headquartered in 
Paris, France, that has 166 member countries, including the United 
States.[Footnote 11] OIE classifies member countries or certain zones 
within these countries as being disease-free if they meet certain 
criteria detailed in the OIE International Animal Health Code. The 
international community generally places a high value on products from 
countries that OIE classifies as disease-free without the use of 
vaccination. Such countries can export both live animals and animal 
products easily to other countries. In contrast, countries that are 
classified as disease-free but who use vaccines are restricted in their 
ability to trade. Most countries that are foot and mouth disease (FMD) 
- free without vaccination resort to a "stamping out," or cull and 
burn, process to eradicate the disease. The United Kingdom followed 
this process during the FMD outbreak in 2001. As a member state of OIE, 
the United States would also generally follow this process.[Footnote 12]

Federal Agencies' Roles and Responsibilities Were Modified to Protect 
against Agroterrorism: 

Following the terrorist attacks of 2001, Congress and the President 
modified the roles and responsibilities of federal agencies to better 
protect against agroterrorism. Congress passed the Homeland Security 
Act of 2002,[Footnote 13]establishing the Department of Homeland 
Security as the chief coordinating agency for efforts to protect the 
United States from terrorist acts, including agroterrorism. To outline 
agency goals and tasks for protecting against agroterrorism, the 
President issued four Homeland Security Presidential Directives. 
Congress also passed legislation that clarifies USDA's responsibilities 
over agriculture and food security.

The Department of Homeland Security Is Responsible for Coordinating 
Efforts to Protect against Agroterrorism and Has Absorbed Staff and 
Functions from Other Agencies: 

The Homeland Security Act of 2002 created the Department of Homeland 
Security and assigned the new agency lead coordinating responsibility 
for protecting the nation against terrorist acts, including 
agroterrorism. The act transferred functions and personnel from other 
agencies to DHS, which allowed it to accomplish this role. For example, 
the Homeland Security Act of 2002 transferred the functions and 
personnel of FEMA, which had been responsible for mitigating, planning 
for, and responding to natural emergencies and major disasters, into 
DHS to support the new agency's responsibility for protecting the 
United States from terrorist attacks. In addition, DHS is responsible 
for consolidating federal response plans for various emergencies, 
including agroterrorism, into a single coordinated plan, which is 
called the National Response Plan. DHS is also responsible, through 
FEMA, for providing emergency response to terrorist attacks, including 
managing the response, coordinating federal response resources, and 
aiding recovery.[Footnote 14] Under federal law, once the President 
makes an official declaration of an emergency or a major disaster, DHS 
is authorized to direct federal agencies to support state and local 
efforts; coordinate relief assistance; provide technical and advisory 
assistance to state and local governments for management, control, and 
reduction of immediate threats to public health and safety; and provide 
financial assistance.[Footnote 15]

The Homeland Security Act of 2002 transferred most of USDA's 
responsibility for conducting agricultural import inspections to DHS, 
which provided DHS with the capability to recognize and prevent the 
entry of organisms that may be used for agroterrorism. The act also 
authorized the transfer of no more than 3,200 inspector positions from 
USDA's Plant Protection and Quarantine Unit to DHS.[Footnote 16] DHS 
and USDA signed an interagency Memorandum of Agreement that, among 
other things, further clarified the responsibilities of both agencies 
at the border. Pursuant to this agreement, USDA may request the use of 
DHS inspectors during a major animal or plant health incident of 
national significance--whether intentional or natural.[Footnote 17] DHS 
acquired USDA's authority to inspect passenger declarations and cargo 
manifests, international passengers, baggage, cargo, and 
conveyances,[Footnote 18] and hold suspect articles for quarantine to 
prevent the introduction of plant or animal diseases. (See fig. 3.) 
USDA retained its traditional authorities to conduct veterinary 
inspections of live, imported animals; establish policy for inspections 
and quarantine functions; provide risk analysis; develop and supervise 
training on agriculture for DHS and USDA inspectors; conduct 
specialized inspections of plant or pest material; and identify 
agricultural pests. Under DHS' usual practices, a DHS inspector who 
comes across a questionable agricultural product should hold it and 
turn the item over to USDA inspectors for a more thorough analysis of 
its potential threat to U.S. agriculture.

Figure 3: Agricultural Inspector Transferred to DHS Inspecting Suspect 
Cargo: 

[See PDF for image] 

[End of figure] 

The Homeland Security Act of 2002 also consolidated research efforts in 
chemical, biological, and nuclear defense by transferring a number of 
research facilities to DHS, including USDA's Plum Island Animal Disease 
Center. The center is the only place in the United States where certain 
highly infectious foreign animal diseases are studied, including FMD. 
Since the transfer, DHS has assumed responsibility for the security and 
management of the facility. Although USDA still administers its own 
research and diagnostic programs on the island, DHS and USDA have 
established a Senior Leadership group at the center to integrate 
research efforts in general and to coordinate the management for joint 
research projects. For example, this group integrates USDA and DHS 
research efforts on FMD.

The Homeland Security Act of 2002 transferred the Office for Domestic 
Preparedness and its grant-making functions from the Department of 
Justice's Office of Justice Programs to DHS.[Footnote 19] This transfer 
established DHS as the primary source of much federal homeland security 
funding to state and local governments. In fiscal year 2005, DHS will 
distribute formula and discretionary grants to the states through the 
Homeland Security Grant Program.[Footnote 20] These grants have 2-year 
performance periods and support expenditures, which include planning, 
organizing, equipment, training, test exercises, and management and 
administration. DHS gives states the flexibility to choose which 
emergency "disciplines"--such as law enforcement, hazardous material 
response, and public works--to fund, using the grants. Most DHS grant 
programs require states to obligate not less than 80 percent of the 
total grant award to local units of government.[Footnote 21] In the 
program application kit, DHS provides guidance on the types of 
expenditures that are allowable. Beginning in fiscal year 2004, DHS 
provided states with examples of resources, which could be acquired 
with grant funds for prevention, response, and recovery efforts related 
to agricultural and/or food security preparedness. These resources 
include agricultural response equipment, and agriculture-related test 
exercises and training.

Finally, the Homeland Security Act of 2002 created the Information 
Analysis and Infrastructure Protection Directorate in DHS and 
transferred intelligence, law enforcement, and vulnerability assessment 
functions from other agencies into the directorate.[Footnote 22] 
Congress and the President have tasked DHS, through this directorate, 
with developing a comprehensive national plan to secure critical 
infrastructure sectors of the United States. Accordingly, DHS has 
developed its interim National Infrastructure Protection Plan, which 
includes strategies for securing the agriculture sector. In addition to 
developing the plan, DHS is responsible for assessing and identifying 
the nature and scope of terrorist threats to the homeland based on 
information received and analyzed by other government agencies. To do 
so, DHS receives information from the Federal Bureau of Investigations, 
the Central Intelligence Agency, and other intelligence agencies and 
assesses whether the combined information indicates a threat to 
critical infrastructures.

Presidential Directives Define Agency Responsibilities for Protecting 
against Agroterrorism: 

Following the creation of DHS, the President issued four directives 
that further define agencies' roles and responsibilities for protecting 
against terrorism. The most important of these directives in relation 
to agriculture is HSPD-9, which was released in January 2004. The 
directive establishes a national policy to defend the agriculture and 
food system against terrorist attacks, major disasters, and other 
emergencies. Specifically, HSPD-9 outlines goals and assigns lead and 
supporting roles to agencies to achieve these goals. (See fig. 4.) 
There are seven categories outlined in HSPD-9: awareness and warning; 
vulnerability assessments; mitigation strategies; response planning and 
recovery; outreach and professional development; research and 
development; and budget. Federal agencies, especially DHS, USDA, and 
HHS, are assigned lead responsibilities to achieve the stated goals. To 
accomplish the tasks outlined in the seven categories, lead agencies 
often must coordinate with secondary or supporting agencies and, in 
some instances, with states and private industry as well. For example, 
HSPD-9 directs DHS to improve awareness and warning capabilities by 
coordinating with other agencies to develop a biological threat 
awareness capacity that will enhance detection and characterization of 
agroterrorism. The directive also designates DHS as the lead agency in 
ensuring that the combined federal, state, and local response 
capabilities are adequate to respond quickly to a terrorist attack or 
other emergencies affecting agriculture or food. HSPD-9 also directs 
DHS to oversee a national biological surveillance system that will 
combine surveillance information collected from several agencies with 
threat and intelligence information to allow DHS to characterize 
threats more quickly. According to DHS officials, this interagency 
effort will help them differentiate between natural and intentional 
outbreaks.

Likewise, HSPD-9 assigns lead tasks to USDA and HHS for agriculture and 
food matters, respectively. Specific tasks for USDA and HHS include 
developing safe, secure, and state-of-the-art agriculture laboratories 
that research and develop diagnostic capabilities for foreign animal 
and zoonotic diseases.[Footnote 23] Also under HSPD-9, USDA and HHS, in 
coordination with EPA and DHS, are the lead agencies responsible for 
improving existing recovery systems that will stabilize agriculture 
production and rapidly remove and dispose of contaminated animals, 
plants, and food products, and decontaminate premises following an 
agroterrorism attack.

Figure 4: Federal Agencies' Roles and Responsibilities as Defined by 
Homeland Security Presidential Directive 9: 

[See PDF for image] 

[End of figure] 

HSPD-9 builds upon and augments tasks outlined in prior Homeland 
Security Presidential Directives. HSPD-5 directs DHS to coordinate 
development of the new National Response Plan that incorporates 
national prevention, preparedness, response, and recovery plans into a 
single, all-hazard plan. USDA, in collaboration with other agencies 
including DHS, were tasked with writing the sections of the National 
Response Plan guiding U.S. efforts to respond to an attack on U.S. 
agriculture. HSPD-5 also directs DHS to consult with other federal 
agencies, state, and local governments to implement a common National 
Incident Management System, which standardizes planning, 
communications, and public information during an incident in which 
multiple federal and state agencies are involved. A key component of 
the National Incident Management System is the Incident Command System, 
which is designed to allow multiple agencies to coordinate the command, 
operations, planning, logistics, finances, and administration during an 
incident. HSPD-5 further directs agencies to require the adoption of 
the National Incident Management System as a condition for states to 
receive federal preparedness assistance.

HSPD-7 defines USDA and HHS as "sector-specific agencies" with 
responsibilities for securing the agriculture and food sectors. These 
agencies, in coordination with DHS, are tasked with collaborating with 
federal, local, and state governments, as well as private industry and 
other stakeholders to help protect their respective critical 
infrastructure sectors, including agriculture. Among other things, HSPD-
7 directs DHS to establish systems, mechanisms, and procedures to share 
homeland security information relevant to threats and vulnerabilities 
in critical infrastructures with other federal departments and 
agencies, state and local governments, and private industry in a timely 
manner.

Finally, HSPD-8 sets out a national preparedness goal for all hazards, 
including agriculture. The directive calls on federal agencies to 
establish readiness priorities, to deliver federal assistance to state 
and local governments effectively and expeditiously, and to ensure that 
first responders are prepared to respond to major events. The directive 
outlines criteria for federal preparedness assistance to the states 
based on assessments of population concentrations, critical 
infrastructure, and other risk factors such as terrorism threats.

Other Legislation Has Expanded USDA's and HHS's Traditional 
Responsibilities to Protect against Agroterrorism: 

The traditional responsibilities of USDA and HHS have been augmented 
through Congress' passage of the Bioterrorism Act of 2002.[Footnote 24] 
This act made USDA and HHS responsible for requiring companies, 
laboratories, and other entities to register materials that could be 
dangerous to agriculture production and human health. It also required 
USDA and HHS to develop an inventory of potentially dangerous agents 
and toxins that cause animal, plant, or human diseases. Furthermore, 
individuals who possess or use such materials must register with the 
Secretary of Agriculture or HHS and submit to a background check by the 
U.S. Attorney General. Also, the act directed USDA and HHS to take a 
number of steps to improve surveillance for such materials. 
Specifically, the act directed USDA and HHS to coordinate surveillance 
activities to detect zoonotic diseases. The act also authorized USDA to 
conduct and support research into the development of an agricultural 
bioterrorism early warning system. The system would enhance the 
capacity of and coordination between state veterinary diagnostic 
laboratories, federal and state agricultural research facilities, and 
public health agencies. The act also gave USDA the authority to 
coordinate with the intelligence community to better identify research 
needs and evaluate materials or information acquired by the 
intelligence community relating to potential threats to U.S. 
agriculture.

Since the Terrorist Attacks of 2001, Federal Agencies Have Taken Steps 
to Manage the Risks of Agroterrorism: 

In carrying out their new roles and responsibilities, federal agencies 
have taken steps to manage the risks of agroterrorism, including the 
development of a comprehensive national strategy that did not exist 
before September 11, 2001. As part of this strategy, DHS has overseen 
the development of national plans and the adoption of standard 
protocols that will help agencies coordinate in protecting against and 
responding to agroterrorism. Federal and state officials are also 
conducting joint exercises to test the new plans and protocols. In 
addition, federal agencies are taking a number of specific actions to 
protect against agroterrorism, including those summarized as follows.

National Plans Are Being Prepared, Emergency Protocols Have Been 
Adopted, and Test Exercises Are Being Conducted: 

DHS coordinated with other agencies to create an interim "National 
Infrastructure Protection Plan" to guide the efforts of federal, state, 
and local governments and private industry to protect critical 
infrastructure sectors, including agriculture, against terrorist 
attacks.[Footnote 25] The overall plan incorporates sector-specific 
plans that include processes, guidance, and mitigation strategies that 
address how DHS and other agencies will work with state and local 
governments, private industry, and foreign governments to safeguard the 
sectors. Additionally, the plan includes initiatives for sharing 
warning data with state and local governments and the private sector. 
(See app. V for more details about these plans.)

To outline how the nation will respond in the aftermath of an emergency 
or major disaster such as a terrorist attack, DHS released a "National 
Response Plan" in January 2005. The National Response Plan differs from 
earlier federal emergency plans in that it describes the roles and 
outlines the responsibilities for federal, state, and local responders 
in addressing the national response to outbreaks or other emergencies 
in the food and agriculture sector. DHS coordinated with USDA, HHS, and 
EPA to develop the appendixes contained in the plan that pertain to 
protecting agriculture and the food supply in emergencies, from first 
detection to the response and recovery phase.[Footnote 26]

To further improve the response to emergencies such as agroterrorism, 
DHS established the "National Incident Management System" in March 
2004. A key component of the National Incident Management System is the 
"Incident Command System," which is designed to coordinate the 
communication, personnel, and procedures of different agencies and 
levels of government within a common organizational structure during an 
emergency that requires the resources of multiple federal, state, and 
local responders. HSPD-5 directs federal agencies to require that 
states become compliant with the National Incident Management System in 
fiscal year 2005 as a condition for receiving federal grant aid for 
emergency preparedness. To support this directive, DHS has established 
a number of minimum requirements for states to implement during fiscal 
year 2005. A DHS official noted that as of December 2004, most states 
had already implemented the Incident Command System and other 
components of the National Incident Management System. (See app. V for 
more information on the National Incident Management System.)

To test response capability, including aspects of the National Incident 
Management System, federal and state agencies have collaborated in 
conducting test exercises to simulate outbreaks of foreign animal and 
plant diseases. For example, USDA, along with numerous other agencies, 
conducted a 1-day exercise in September 2002 called "Crimson Sky," 
which simulated the intentional introduction of the FMD virus in five 
different locations across the United States. Exercises have also been 
conducted to test response capability to address plant diseases. For 
example, USDA and Minnesota, with the assistance of Iowa,[Footnote 27] 
simulated an outbreak of soybean rust using the Incident Command System 
in September 2004. Two months later, there was an apparently natural 
outbreak of soybean rust in Louisiana and other southern states, and 
USDA officials told us that the lessons learned from the test exercise 
in coordinating their communications were incorporated in response to 
the real outbreak. Federal, state, and industry officials whom we 
interviewed said that these test exercises in general have been useful 
in allowing players to better understand their roles and 
responsibilities in a real-life event, to uncover shortfalls they had 
not necessarily foreseen in planning, and to test solutions. For 
instance, exercises have shown that some areas of agencies' 
jurisdiction needed to be better defined. Many participants have 
written unclassified "after-action" reports incorporating the lessons 
they learned and raising key issues to be resolved. (See app. V for 
more information on test exercises.)

A Number of Agency-Specific Actions Are Under Way: 

In addition to the broad national planning efforts discussed, other 
specific actions that federal agencies responsible for protecting 
against agroterrorism have taken since 2001 include the following: 

* FDA and USDA are in various stages of developing vulnerability 
assessments of the agriculture and food sectors, as called for in HSPD- 
9. As part of a continuing effort to anticipate threats to farm 
products, FDA has conducted vulnerability assessments of different 
categories of food for which FDA has statutory responsibility, to 
identify those products most vulnerable to deliberate contamination. 
Similarly, USDA is assessing vulnerabilities in USDA-regulated products 
but had not completed its preliminary assessments at the time of our 
review. Such assessments are generally not consistent across program 
areas because different maximum values for the impact of terrorist 
events are sometimes used. (See app. V for more details about FDA and 
USDA vulnerability assessments.)

* To increase early warning and monitoring capabilities, USDA and HHS 
have created laboratory networks to integrate existing federal, state, 
and university laboratory resources. These networks are intended to 
link laboratories that screen for animal, plant, and human health 
diseases across the nation and help to provide diagnostic surge 
capacity in the event of a disease outbreak. Within each network, the 
laboratories use standardized diagnostic protocols and procedures to 
ensure consistent results. For example, USDA provided funding and 
leadership for two networks that serve the nation: the National Animal 
Health Laboratory Network, which originally consisted of 12 state and 
university veterinary laboratories nationwide, and the National Plant 
Diagnostic Laboratory Network, which consists of 5 laboratories located 
at land grant universities. By December 2004, the National Animal 
Health Laboratory Network had expanded to 47 laboratories in 39 states 
surveying domestic and foreign animal diseases. When these network 
laboratories find positive test results for foreign diseases, USDA's 
own federal laboratories in Ames, Iowa; Plum Island, New York; and 
Beltsville, Maryland, still conduct their own diagnostic tests to 
confirm results before USDA announces the outbreak of a disease. 
Meanwhile, FDA, in conjunction with other agencies including USDA's 
Food Safety and Inspection Service, developed and have continuously 
expanded, the Food Emergency Response Network to integrate 93 local, 
state, and federal laboratories for the detection of biological, 
chemical, and radiological agents in food.[Footnote 28] Likewise, the 
CDC has expanded its Laboratory Response Network to address public 
health emergencies. This network now enlists the technology and 
capacity of 138 laboratories across the United States and abroad in the 
event of a suspected or known release of biological or chemical agents. 
These federal laboratory networks have operated during animal, plant, 
and human health emergencies in the past few years. For example, USDA's 
animal and plant laboratory networks tested samples in the 2002-2003 
exotic Newcastle disease outbreak in poultry and in the sudden oak 
death outbreak in California in 2004.[Footnote 29]

* Agencies are also working to enhance coordination and communication 
among multiple stakeholders. In particular, DHS, USDA, and other 
agencies have established numerous interagency working groups to 
coordinate their efforts to protect against agroterrorism. These 
working groups are, in turn, coordinated through a Government 
Coordinating Council, which DHS finalized in the fall of 2004. DHS, 
USDA, and HHS alternately chair the Government Coordinating Council on 
a rotating basis.[Footnote 30] DHS also helped the food and agriculture 
industry to establish the Food and Agriculture Sector Coordinating 
Council to facilitate the flow of alerts, plans, and other information 
between the federal and state governments and industry groups. Through 
the Food and Agriculture Sector Coordinating Council, DHS has been 
seeking the expertise of the industry groups to develop national 
guidance, such as the interim National Infrastructure Protection Plan. 
In turn, this plan is intended to provide industry with a blueprint to 
develop strategies to protect their assets. (See app. V for more 
details about interagency working groups.)

* USDA has established a steering committee, which includes 
representatives from FDA and CDC, to guide efforts to develop a 
National Veterinary Stockpile that, among other things, is intended to 
address vaccines needed to respond to animal diseases most damaging to 
human health and the economy. The steering committee will also identify 
such things as reagents, personal protection equipment that would be 
needed, how to obtain vaccines, as well as prioritizing a stocking 
schedule for the National Veterinary Stockpile. This stockpile is being 
developed for foreign animal diseases other than FMD, since there is 
already a North American FMD Vaccine Bank. USDA is also creating a 
separate vaccine bank for certain strains of avian influenza that will 
be completed by May 2005.

* DHS, USDA, and HHS are funding research to enhance the nation's 
protection against agroterrorism. Of note, DHS is providing $33 million 
over 3 years to establish two university-based Centers of Excellence to 
oversee research into post-harvest food protection and diseases that 
affect livestock and poultry. In addition, as of 2004, USDA is 
supporting homeland security research, including university-based 
efforts to evaluate contaminated carcass disposal efforts, assess 
animal and plant disease test exercises, and analyze pathways by which 
foreign animal and plant diseases can enter the United States.[Footnote 
31] CDC has also provided $1 million in annual funding to a university 
for developing a center for food security and public health that will 
support efforts such as online programs to educate veterinarians in 
foreign animal diseases. (See app. V for more details about research 
efforts.)

* USDA's Veterinary Services has developed a National Animal Health 
Emergency Management System that provides comprehensive guidance on 
mitigating, preparing for, responding to, and recovering from an animal 
health emergency, including a terrorist attack. USDA officials believe 
the system's guidance is more efficient than that provided by previous 
animal health manuals. For example, rather than changing with each 
disease, the roles of various emergency response personnel change to 
fit only three scenarios: an outbreak of a highly contagious disease 
(e.g., FMD); an outbreak of a disease spread by "vectors" such as 
mosquitoes (e.g., Venezuelan equine encephalomyelitis); or an outbreak 
of a disease that is not highly contagious (e.g., bovine spongiform 
encephalopathy). USDA officials believe that this approach will speed 
response times and be more effective in containing any outbreaks, 
whether natural or intentional. (See app. V for more details about 
USDA's National Animal Health Emergency Management System.)

* Since 2002, USDA has created 14 Area Emergency Coordinator positions 
across the nation for animal health, and 2 Regional Emergency 
Coordinator positions for plant health, to coordinate federal and state 
efforts in the event of an emergency, including agroterrorism.[Footnote 
32] Among other duties, these coordinators have assisted states in 
developing emergency response plans in keeping with federal guidelines, 
and helped organize test exercises.[Footnote 33] For example, an Area 
Emergency Coordinator was involved in developing Wisconsin's Animal 
Health Emergency Management System, the nation's first statewide plan 
that parallels the National Animal Health Emergency Management System 
and outlines tasks and responsibilities of agencies and organizations 
in an animal health emergency. The USDA emergency coordinators have 
also responded to recent natural outbreaks of plant and animal 
diseases, acting in key roles under the Incident Command System. For 
example, an Area Emergency Coordinator served as the liaison officer to 
the command staff for the widely reported bovine spongiform 
encephalopathy case in Washington state in January 2004. The Western 
Regional Emergency Coordinator helped respond to the soybean rust 
outbreak in Louisiana in November 2004 and acted as a coach for the 
incident management team.

The United States Still Faces Complex Challenges and Management 
Problems in Protecting against Agroterrorism: 

Although many important steps have been taken to prevent or reduce the 
impact of agroterrorism, the United States still faces complex 
challenges that limit the nation's ability to quickly and effectively 
respond to a widespread attack on animal agriculture. There are also 
some less complex management problems that impair the effectiveness of 
federal agencies' efforts to protect against agroterrorism.

The United States Faces Challenges in Quickly Responding to a 
Widespread Attack on Animal Agriculture: 

Experts we spoke with told us that to effectively control the spread of 
highly contagious foreign animal diseases, such as FMD, it is critical 
to quickly identify animals that may have the disease, promptly confirm 
the presence of the disease with diagnostic tools, and rapidly 
vaccinate animals in the surrounding area. However, the United States 
faces a shortage of veterinarians trained in foreign animal diseases, 
does not use rapid diagnostic tools at the site of an outbreak, and has 
insufficient vaccine stockpiles. These complex challenges impair the 
nation's ability to contain the spread of animal diseases that are of 
potential use in agroterrorism.

Many Veterinarians Lack Training in Foreign Animal Diseases: 

Many U.S. veterinarians lack training to recognize the signs of foreign 
animal diseases, according to a 2004 report produced for USDA. The 
report notes that while all U.S. veterinary schools offer information 
about foreign animal diseases, only about 26 percent of the nation's 
veterinary graduates have taken a course specifically dedicated to 
foreign animal diseases.[Footnote 34] According to the report, only 12 
of the 28 veterinary schools in the United States offer courses 
dedicated to foreign animal diseases. Further, among the 12 veterinary 
schools that offer such courses, 5 offer them as electives rather than 
as core courses. As a result, when federal or state veterinarians are 
called to determine whether symptoms suggest the presence of a foreign 
animal disease, they may not have the training or expertise needed to 
identify it, and the disease could go undetected. According to USDA 
officials, however, all veterinary students must take instruction in 
infectious diseases and pathology which, according to these officials, 
includes foreign animal diseases. USDA officials also told us they have 
worked to develop Web and CD-Rom-based training to strengthen 
veterinary student training in foreign animal diseases.

Another reason for this lack of expertise in foreign animal diseases is 
that such training is not required to obtain USDA accreditation. More 
than 80 percent of veterinarians in the United States are USDA- 
accredited and are intended to be instrumental in maintaining effective 
disease surveillance and monitoring by accurately diagnosing and 
reporting animal diseases.[Footnote 35] To be accredited, an individual 
must have graduated from an accredited school of veterinary medicine, 
submitted an application certifying the ability to complete 16 tasks 
such as recognizing common breeds of livestock, completed a core 
orientation session, and be licensed or legally able to practice 
without supervision. USDA officials believe that because an accredited 
veterinarian must be licensed, this is an indication that they have 
received basic training in foreign animal diseases. However, this 
accreditation process does not require veterinarians to demonstrate 
their ability to recognize or diagnose basic clinical signs of foreign 
animal diseases.[Footnote 36] Furthermore, once granted, accreditation 
is valid for life and no continuing education is required.[Footnote 37] 
The Association of American Veterinary Medical Colleges believes that 
this process could be more rigorous if, as a condition of 
accreditation, veterinarians were required to demonstrate an ability to 
recognize clinical signs of foreign animal diseases at the time of 
accreditation and also periodically throughout their careers. USDA 
recognizes the need to modernize its accreditation process and agrees 
that continuing education is needed. APHIS drafted a rule to modify its 
current program by developing a two-tiered National Veterinary 
Accreditation program, which would have requirements for supplemental 
training in such areas as emergency management and foreign animal 
diseases;[Footnote 38] however, after more than 2 years, it is still 
not in effect. According to the Chief of Staff of Emergency Management 
and Diagnostics at APHIS, the draft rule has been undergoing revisions 
but had to be set aside several times in an effort to pursue the 
development of other more important draft regulations and emergency 
regulations. According to this official, the draft rule is now being 
reviewed by USDA's Office of General Counsel. This official told us 
that this review can take several months, but if no problems are 
encountered, it is anticipated that the draft rule will be published as 
a proposed rule in the Federal Register during the first or second 
quarter of calendar year 2005. USDA officials told us that new efforts 
are also being made to strengthen APHIS' role in colleges of veterinary 
medicine to provide information on various aspects of regulatory 
medicine.

Finally, expertise in foreign animal diseases is lacking because most 
veterinarians work in private practice where this skill is not 
required. According to the American Veterinary Medical Association, 
approximately 74 percent of practicing veterinarians in the United 
States work in private practice.[Footnote 39] Similarly, the 
Association of American Veterinary Medicine reports that only about 
5,000 veterinarians work in public service,[Footnote 40] some of whom 
play an essential role in the detection, prevention, and control of 
foreign animal diseases. USDA officials told us they intend to increase 
the number of veterinarians entering public service by making new 
efforts to increase veterinary students' awareness of potential careers 
in public service.

USDA Does Not Use Rapid Diagnostic Tools on Site: 

Another complex challenge impairing the ability of the United States to 
quickly contain an outbreak and limit the loss of animals is the 
inability to rapidly diagnose diseases at the site of an outbreak. 
Currently, if an animal is suspected of having a foreign disease, a 
sample would be collected from the sick animal and a federal official 
would send it by Express Mail to one of USDA's reference laboratories-
-either the NVSL in Ames, Iowa, or the Foreign Animal Disease 
Diagnostic Laboratory located on Plum Island, New York.[Footnote 41] 
Using traditional techniques, USDA technicians would generally diagnose 
the disease in 3 to 4 days. During this time, the affected animals and 
other animals within the vicinity, or those that had recent contact 
with the sick animal, would be quarantined. Should USDA officially 
confirm the presence of a disease, such as FMD, the affected herd and 
all cattle, sheep, goats, swine, and susceptible wildlife--infected or 
not--within a minimum 10-kilometer zone around the infected farm would 
be killed. USDA would wait for confirmation before slaughtering animals 
to avoid causing unnecessary panic among producers and severe market 
fluctuations.[Footnote 42] If the disease were to spread beyond the 
initial zone, authorities would continue to quarantine and kill animals 
until the disease was "stamped out." USDA's "Crimson Sky" test exercise 
in 2002, estimated that, under the current "stamping out" approach, FMD 
would spread rapidly, necessitating the slaughter of millions of 
animals and cause staggering financial losses--precisely the type of 
high-visibility destruction that some experts told us terrorists seek.

According to the former Associate Administrator for Special Research 
Programs at USDA's Agricultural Research Service, the impact of a 
disease such as FMD can be mitigated if rapid diagnostic tools are used 
on site to speed diagnosis. In 2000, under the direction of this 
official, USDA developed state-of-the-art, rapid diagnostic tools to 
detect FMD, classical swine fever, African swine fever, Rinderpest, 
avian influenza, and Newcastle disease.[Footnote 43] According to this 
official, the rapid diagnostic tools are designed to yield results in 
less than an hour and are intended to be used outside of specialized 
laboratories, at the site of an outbreak. Importantly, the tools can 
detect disease before the animal shows clinical signs of infection. 
According to USDA, symptoms of FMD may take up to 14 days to appear, or 
even longer in sheep and goats. In fact, animals may show no symptoms 
at all. USDA's draft guidance for controlling FMD warns that if the 
first animal infected with FMD does not outwardly show clinical signs, 
detection may be delayed. The guidance further states that potential 
delays and difficulty in detection may complicate the decision-making 
process regarding appropriate disease control measures. According to 
the former Associate Administrator, rapid diagnostic tools would not 
only allow for a rapid diagnosis but would also permit the monitoring 
of nearby herds before symptoms appeared so that only infected herds 
would have to be killed. Slaughter would, therefore, be based not on 
proximity but on actual infection, thereby reducing the number of 
animals lost and lessening the impact of the attack.[Footnote 44] 
Overall, rapid diagnostic tools would be helpful because FMD would be 
detected in less than an hour, informed control measures could be 
implemented, and herds in the area would be under regular surveillance.

According to state officials, the use of these rapid tools on site 
would also help prevent laboratories from becoming overwhelmed with 
test samples, which would be an advantage if a terrorist attack 
involved the introduction of disease at multiple locations. In 2003, 
California state officials used rapid diagnostic tools to test animals 
for exotic Newcastle disease--a contagious and fatal viral disease 
affecting birds of all species. (See fig. 5.) These state officials 
told us that the tools used at the time allowed diagnostic results 
within 6 hours and enabled them to test up to 1,500 samples per day, 
many more samples than traditional testing methods. State officials 
also told us that rapid diagnostic tools would be useful during a 
widespread outbreak so that individual animals or herds could be tested 
in a temporary laboratory at the site of an outbreak, rather than 
waiting for results while samples were sent to laboratories distant 
from the outbreak.

Figure 5: Game Bird Infected with Exotic Newcastle Disease during the 
2002-2003 Outbreak in California: 

[See PDF for image] 

[End of figure] 

USDA officials believe that rapid diagnostic tools can be useful, but 
they told us most such technologies are not yet ready to be used at the 
site of an outbreak.[Footnote 45] While USDA has employed some of its 
rapid diagnostic tools for exotic Newcastle disease and avian 
influenza, it has done so only in select laboratories within the 
National Animal Health Laboratory Network.[Footnote 46]

There are several reasons why USDA is reluctant to use the tools 
outside of a laboratory setting. One reason is that samples put into 
the rapid diagnostic tests may contain a live virus. For highly 
contagious diseases such as FMD and classical swine fever, USDA 
believes that rapid diagnostic testing must be conducted in a 
specialized laboratory setting where certain procedures are taken to 
prevent the virus from escaping and infecting livestock and wildlife. 
According to the former Associate Administrator for Special Research 
Programs at ARS, this precaution is unnecessary. Once a sample is 
taken, it is inserted into a tube containing reagents that inactivate 
the virus if it is present. The tube, as well as the person who 
collected the sample, can then be decontaminated using a common 
solution, such as acetic acid in the case of FMD, and the sample can be 
tested using the rapid diagnostic tool in a mobile unit at, for 
example, the entrance to the farm.[Footnote 47] USDA officials agree 
that samples can be taken in this manner but told us that their current 
technique for collecting samples for the rapid diagnostic tools that 
USDA uses in its laboratories does not inactivate the sample. For that 
reason, samples of highly contagious diseases must be processed under 
special laboratory conditions. USDA uses this sampling technique in 
order to preserve the "live virus" sample necessary for the traditional 
method of diagnosing diseases. USDA officials told us they have 
initiated discussions about sampling using an "inactivation model" such 
as discussed above, but the sample would still be diagnosed using a 
rapid diagnostic tool located in a laboratory.

Unlike USDA, agencies within DOD are using rapid diagnostic tools in 
the field to obtain quick results during emergency situations or when a 
laboratory setting is not possible, such as in combat zones.[Footnote 
48] For example, the Army is using various types of rapid diagnostic 
tools in Iraq to detect pathogens used in biological warfare, such as 
anthrax. DOD officials told us that for samples that are a "true 
unknown," such as chemical substances they encounter in combat, they 
utilize many safety procedures, such as wearing protective clothing and 
opening samples in safety cabinets. The officials also told us that the 
reagents they use to detect agents used in biological warfare will 
inactivate viruses, allowing the test to be safely conducted without 
contaminating the surrounding area. A DOD official noted that with 
animal diseases, if samples are positive for a disease, then 
contaminating other animals within that herd is not a concern since 
these animals would have to be destroyed anyway.[Footnote 49]

Another reason USDA is reluctant to use rapid diagnostic tools at the 
site of an outbreak is that personnel need training to use the tools. 
According to the former ARS Associate Administrator, however, the tests 
are designed to be performed by persons with limited training, using 
quality-controlled standardized reagents and protocols that are 
consistent with international standards.[Footnote 50] DOD concurs that 
the tools are not difficult to use, but to ensure that samples are not 
contaminated and results are rigorous, the U.S. Army Medical Research 
Institute of Infectious Diseases requires personnel to undergo a 4-week 
training program and follow strict procedures, such as loading and 
capping pathogen samples before adding the control samples to help 
eliminate cross-contamination.[Footnote 51] To help increase confidence 
in the accuracy of the results, DOD also uses more than one type of 
rapid diagnostic tool to test a sample if it comes back positive. 
[Footnote 52]

USDA officials told us that although the rapid diagnostic tools have 
been developed, these tools still need to be validated before they can 
be used in order to rule out diseases with similar clinical signs or 
protein sequences that might result in a false positive result. 
Therefore, USDA would still make an initial diagnosis using traditional 
test procedures and confirmatory testing would still be done at NVSL in 
Ames, Iowa, or at the Foreign Animal Disease Diagnostic laboratory on 
Plum Island in New York. Once the initial diagnosis is confirmed, USDA 
believes there may be opportunities to use validated rapid diagnostic 
tools to evaluate herd health either on site or at a nearby laboratory. 
USDA further agrees that it is important to evaluate the costs and 
benefits of developing and validating these tools for use outside of a 
laboratory setting.

Vaccines Cannot Be Rapidly Deployed to Contain a Widespread Disease 
Outbreak: 

For several reasons, USDA would not be able to deploy vaccines rapidly 
enough to contain a widespread animal disease outbreak caused by a 
deliberate attack. First, USDA has very few supplies of vaccines. The 
only vaccines currently stored in the United States against foreign 
animal diseases are for various strains of FMD because this disease is 
so highly contagious. In place of vaccination, USDA generally prefers 
to immediately slaughter diseased animals because international rules 
that the United States and other countries have agreed to abide by are 
designed to prevent trade in infected or vaccinated animals. As a 
result, vaccine stockpiles have traditionally not been needed to 
control natural outbreaks. Also, vaccines have not yet been developed 
for all foreign animal diseases that USDA considers to be of primary 
concern.[Footnote 53] For example, worldwide, there is no vaccine 
currently available for African swine fever. USDA's ARS is researching 
new vaccines, but it is unlikely that vaccines will ever be developed 
for all strains of these diseases because of the vast number of strains 
and subtypes for each disease. For example, there are 7 different types 
of FMD with more than 60 different subtypes. According to an expert we 
consulted, it is not realistic to develop vaccines for all of these 
subtypes. It is also conceivable that a terrorist could genetically 
engineer a new strain.

Second, the only vaccines that are stockpiled in the United States-- 
vaccines for FMD--cannot be rapidly deployed because they are not 
stored in a "ready-to-use" state. Although HSPD-9 states that vaccines 
should be capable of deployment within 24 hours, USDA's stockpiles are 
concentrates that require additives to become a vaccine. Because the 
additive for the FMD vaccine is manufactured in the United Kingdom, 
USDA must first ship the stock there for bottling and subsequent 
testing. It can take up to 3 weeks to transform the stock into a 
vaccine once the concentrate arrives in the United Kingdom. Vaccines 
are not stockpiled in a ready-to-use state because vaccines generally 
have a shelf life of only 1 or 2 years before they must be used or 
destroyed, and replacing stocks on a regular basis would be expensive.

Yet until animals are vaccinated, USDA will have no recourse but to 
slaughter animals in a systematic manner to contain the spread of the 
disease. While this approach may be adequate for containing a limited 
outbreak, the recent USDA test exercise of an intentional introduction 
of FMD in multiple locations suggests that this approach would have 
catastrophic results.[Footnote 54] Although USDA officials raise 
concerns about the use of vaccination to control an outbreak, such as 
the limited number of fully trained personnel to administer the 
vaccine, it is now acknowledged that the ability to vaccinate, in 
conjunction with culling, may be a necessary measure to contain an FMD 
outbreak. A recent evaluation by the National Audit Office in the 
United Kingdom reports that the government has substantially increased 
stocks of vaccines for FMD to better contain the spread of FMD should 
another outbreak occur.[Footnote 55] Furthermore, USDA's draft response 
plan for an outbreak of FMD disease or other highly contagious animal 
disease notes that vaccines may be used strategically to create 
barriers between infected zones and disease-free zones.

The Centers for Disease Control and Prevention faces similar challenges 
in stocking vaccines used to protect humans. Because many animal 
diseases can affect humans, CDC is participating in the steering 
committee to help USDA create its National Veterinary 
Stockpile.[Footnote 56] An expert suggests, and CDC officials agree, 
that USDA could contract with pharmaceutical companies to supply a 
stockpile of ready-to-use vaccines. Once the shelf life for those 
vaccines neared expiration,[Footnote 57] the contractor could replenish 
the stock and then sell the supply of vaccines nearing expiration in 
the commercial marketplace to countries that routinely vaccinate 
livestock. Where the market would not support such sales, USDA could 
donate the old, yet still effective, vaccines to other countries where 
the disease is endemic and there is still a demand.[Footnote 58] USDA 
officials agree that it would be useful to have the FMD virus vaccine 
available within 24 hours.[Footnote 59] They also told us they have 
plans to consider options to cut some of the time delay for obtaining 
finished, ready-to-use vaccines. One option could be storing the frozen 
bulk antigen concentrate needed to produce the vaccine at the site of 
the foreign manufacturer. While it is the responsibility of the 
steering committee to consider options and recommend specific processes 
for each of the foreign animal diseases of concern to the United 
States, it is not clear if the steering committee will address the 
costs and benefits of developing ready-to-use vaccines that can be 
quickly deployed against diseases of primary concern.

Finally, even if USDA were to overcome the difficulties discussed above 
and develop adequate stockpiles of ready-to-use vaccines, current USDA 
policy would require a complex decision-making process to determine if 
vaccines would be deployed in an outbreak. In 2000, USDA decided to use 
a decision tree flowchart combined with decision matrices that evaluate 
multiple factors to determine when and if to use vaccines to control an 
outbreak. Because the use of vaccines would affect trade and have major 
consequences for both USDA and producers, the decision tree is complex 
and may not be designed for rapid decision-making, such as would be 
needed during a terrorist attack.[Footnote 60] For example, it requires 
information on the availability of human resources, public opinion and 
perception of government, industry acceptance, and vaccination costs, 
as well as slaughter and disposal capacity. USDA officials agree that 
this process is lengthy, but this is because of the many variables, 
including the location of the outbreak in relation to susceptible 
animal populations as well as trade concerns and restrictions that 
impact this decision-making process. As previously noted, HSPD-9 
requires that vaccines be deployed within 24 hours of an outbreak, but 
such rapid deployment may not be achievable under the current, complex 
decision-making process. USDA officials told us they can explore the 
possibility of designing a more rapid decision-making process; however, 
they noted that it would take additional time to select, deploy, equip, 
and direct vaccination crews in a manner that would be advantageous to 
disease eradication and not cause the virus to spread from farm to farm 
due to the vaccination process. Hastily applied vaccination programs 
could prove detrimental. A USDA official also told us that it is not 
possible to estimate how long it would take to determine whether to use 
FMD vaccines based on the decision tree flow chart, due to the many 
variables involved in the process.

Federal Agencies Have Not Addressed Several Management Problems: 

In addition to the complex challenges discussed above, federal agencies 
are encountering management problems that further impair the 
effectiveness of their efforts to protect against agroterrorism. First, 
since the transfer of agricultural inspectors to DHS, inspections and 
interceptions of prohibited agricultural products and pests have 
declined nationally, and inspectors are less available to respond to 
agricultural emergencies. Second, there are weaknesses regarding the 
flow of critical information among key stakeholders. Third, USDA has 
not hired a sufficient number of Area and Regional Emergency 
Coordinators to help states prepare for an agricultural emergency. 
Fourth, DHS has not developed controls to avoid duplication of effort 
among agencies. Finally, federal agencies' diagnostic laboratory 
networks are not yet integrated for diseases of common concern.

Agricultural Inspections and Interceptions Have Declined, and Fewer 
Inspectors Are Available to Respond to Agricultural Emergencies since 
the Transfer of USDA Inspectors to DHS: 

Since the transfer of most USDA Plant Protection and Quarantine (PPQ) 
inspectors to DHS in March 2003,[Footnote 61] government officials, 
reports, and data indicate that the nation may be more vulnerable to 
the introduction of foreign animal and plant diseases through ports of 
entry into the United States.[Footnote 62] In addition, the transfer of 
inspectors has reduced USDA's ability to respond to agricultural 
emergencies.

Inspectors Have Performed Fewer Agricultural Inspections and Made Fewer 
Interceptions of Prohibited Plant and Animal Products and Pests: 

USDA officials, as well as agricultural inspectors who now work at DHS, 
told us that inspections of agricultural products have decreased at 
some land border crossings, airports, and maritime ports--including 
three major ports that receive a high percentage of the nation's 
agricultural imports and international flights. USDA provided us with 
data showing an overall decline in the number of inspections nationwide 
since 2002[Footnote 63]--the last year when USDA had sole 
responsibility of agricultural inspections. This decrease occurred at a 
time when imports and international air traffic have increased. In 
fiscal year 2002, there were 40.9 million agricultural inspections at 
ports of entry; in fiscal year 2003, the year when USDA inspectors 
transferred to DHS, 35.0 million inspections were conducted; and in 
fiscal year 2004, there were 37.5 million agricultural inspections. 
USDA data also show that inspections have decreased at certain types of 
ports and by certain modes of entry nationwide, such as passenger 
baggage and cargo.[Footnote 64] In particular, USDA officials and DHS 
inspectors told us that the number of agricultural inspections has 
declined at three specific air and sea ports that receive a large 
proportion of international cargo and passenger baggage. For example, 
at one of these ports, former and current DHS agricultural inspectors 
told us they had cut their inspections in late 2004 by more than 50 
percent, from an average of about 1,200 cargo containers per week to 
500 per week. These inspectors said they reduced inspections, in part, 
because of an instruction by the DHS port director to cut their "holds" 
of agricultural cargo and conduct fewer inspections of tile, which are 
often packed in a regulated material that can contain pests such as 
snails and beetles.[Footnote 65] In August 2004, this port intercepted 
a species of live, wood-boring beetles as a result of holding and 
inspecting cargo tile shipments. However, another shipment at this port 
that was not inspected was later found to contain the same beetles, 
which belong to the Asian longhorned beetle family and are costly to 
treat. These inspectors were concerned that if DHS continued to 
decrease agricultural inspections at that port, importers would direct 
more illegal shipments there. DHS officials acknowledged that, since 
the transfer of inspectors, inspections have declined overall. However, 
they also pointed out that some ports have increased their inspections 
in the past 2 years. For example, USDA data show that inspections at 
land border crossings increased from 21.2 million agricultural 
inspections in fiscal year 2002 to 22.5 million such inspections in 
fiscal year 2004.

USDA data also indicate a decline in the number of agricultural 
interceptions--seizures of prohibited plant and animal products, and 
agricultural pests--at ports of entry nationwide since the transfer of 
inspectors to DHS. Interceptions dropped from 1.8 million in fiscal 
year 2002, when USDA had sole responsibility for inspections, to 1.6 
million in 2004, when DHS had primary responsibility for agriculture 
inspections. However, in 2003, a transitional year, interceptions 
totaled 1.8 million. Interceptions of reportable pests in particular 
have declined each fiscal year--from 77,886 in 2002, to 72,988 in 2003, 
and to 54,109 in 2004. USDA officials told us that interceptions are a 
meaningful indicator of effective inspections because the purpose of 
inspecting agricultural products is to intercept prohibited items and 
pests. USDA is concerned that the decrease in interceptions may 
indicate a decline in the quality of inspections or a switch to less 
effective methods. For example, USDA and DHS officials told us that 
while agricultural inspectors rove several ports of entry with sniffing 
dogs--an effective method for detecting and therefore intercepting 
prohibited items--they are now used less frequently. DHS and USDA 
officials also noted that the number of interceptions can vary based on 
a number of factors aside from inspection quality, including changes in 
the amount or type of agricultural products entering the country and in 
international passenger travel patterns. However, we found that both 
agricultural imports and international air passengers entering the 
United States had increased over the past 2 fiscal years.[Footnote 66] 
USDA officials told us that the number of interceptions should 
generally increase accordingly. At the time of our report, DHS 
officials told us they were not aware of changes in inspection methods 
or the risk management approach used at ports that could account for 
the decline in agricultural inspections and interceptions. According to 
agency officials, neither USDA nor DHS has analyzed the inspections and 
interceptions data to identify trends and potential areas for 
improvement, but headquarters officials at both agencies told us they 
would analyze the data in early 2005.[Footnote 67]

Although USDA and DHS officials have not begun an analysis to determine 
the reasons for declining agricultural inspections, they believe that 
several factors are responsible for the decline in agricultural 
inspections and interceptions. First, there is a shortage of 
agricultural inspectors nationwide. In March 2003, USDA transferred 
1,517 full-time inspectors, according to DHS officials.[Footnote 68] 
Recently, DHS has been able to hire new agricultural inspectors, but 
numerous departures left DHS with 1,446 agricultural inspectors and 426 
vacancies as of mid-October 2004.[Footnote 69] DHS told us that the 
agency intends to hire more than 500 additional agricultural inspectors 
by February 2006. However, DHS officials said the agency's ability to 
quickly hire new inspectors is impeded by the length of time needed for 
conducting security background checks. These background checks, which 
are required before a newly hired inspector can report for duty, can 
take more than a year to process, by which time applicants might find 
other work. Agricultural inspectors working at the ports suggested to 
us that DHS could allow new inspectors to perform nonsensitive 
procedures while background checks are pending. According to a DHS 
headquarters official, the agency is allowing some new inspectors with 
modified background checks to start work under certain circumstances 
while their full background investigations are pending.

Second, DHS agricultural inspectors are sometimes used for other 
purposes, such as helping reduce immigration lines at airports. For 
example, a DHS supervisor of agricultural inspectors at a capital city 
airport told us that his inspectors are regularly pulled from their 
agricultural duties to inspect other types of cargo or to assist in 
clearing passengers though immigration. DHS officials told us that they 
need the flexibility to occasionally shift inspectors' duties to 
respond to different priorities and needs, such as searching for drugs 
rather than inspecting agricultural products for diseases or pests. For 
this reason, all customs, immigration, and agricultural inspectors are 
cross-trained to perform aspects of each other's work.

Third, DHS agricultural inspectors do not always receive timely 
information about high-risk cargo that should be held for inspection. 
For example, after Canada confirmed a case of bovine spongiform 
encephalopathy in 2003, inspectors at one border crossing did not 
receive a warning from USDA to hold shipments of Canadian beef in time 
to intercept it, and let the shipment through. In another instance, DHS 
inspectors at a sea port in a major agricultural state told us they did 
not receive an alert in late 2004 about an outbreak of a strain of 
avian influenza that can cause death in humans, until a week after the 
warning was released. DHS headquarters officials told us that while 
some cargo alerts issued by USDA do not get to every agricultural 
specialist in a timely manner, these instances represent a small 
fraction of inspections. However, these officials agreed that 
improvements can be made to improve the flow of information. 
Agricultural inspectors and other port officials attributed the delay 
in receiving information to the transfer of some inspection roles and 
responsibilities from USDA to DHS. This transfer has created additional 
layers of communication that have impeded the rapid delivery of 
critical information to port inspectors. Whereas USDA used to 
communicate critical information directly to its agricultural 
inspectors, DHS inspectors told us that now they receive information 
indirectly through DHS headquarters. While DHS officials told us this 
practice is not the agency's policy, they acknowledged that some ports 
follow a hierarchical chain of command. The memorandum of agreement 
between the two agencies, which is designed to delineate new roles and 
responsibilities, does not detail how DHS should convey alerts, 
warnings, directives, or guidelines that come from USDA.

Finally, DHS and USDA have different databases and information 
technology systems, including email, which has further hindered their 
ability to share information. For example, agricultural inspectors who 
transferred to DHS have experienced difficulty in accessing USDA's 
intranet site, where the Work Accomplishment Data System, the primary 
agricultural inspections database, can be viewed. DHS agricultural 
inspectors told us they still cannot enter USDA's electronic Emergency 
Action Notification System, which was created after September 11, 2001, 
to track problematic or prohibited imported goods at ports of entry. 
DHS officials acknowledged technical problems in the integration of the 
two agencies' systems, but said that they are working with USDA to 
address these problems.[Footnote 70]

As a related matter, some DHS inspectors we spoke with expressed 
concern that the cross-training for "legacy" customs and immigration 
inspectors on agricultural laws, policies, and inspection procedures is 
insufficient--and that these legacy inspectors are thus not able to 
increase the number of items they refer to agricultural inspectors for 
further examination.[Footnote 71] For example, while legacy customs 
inspectors receive weeks of cross-training on immigration functions, 
they receive only 3 hours of computer-based training on agriculture. 
Inspectors told us that while the computer-based training raises 
awareness of the importance of agriculture, it has not enabled legacy 
customs and immigration inspectors to increase the amount of prohibited 
items they refer to agricultural inspectors. Furthermore, the training 
is not always supervised by an agricultural inspector who could answer 
questions.[Footnote 72] DHS officials agree that training for legacy 
customs and immigration inspectors should be enhanced, and told us that 
much training enabling legacy officers to make referrals to agriculture 
specialists has been accomplished. These officials also told us that 
all inspectors will be required to take a new course on agriculture 
procedures that will be launched in fiscal year 2005. This course, 
which will combine 16 to 24 hours of classroom and on-the-job training, 
is intended to help customs and immigration inspectors better screen 
and refer suspicious items to agricultural inspectors.[Footnote 73]

Fewer Inspectors Are Available to Help USDA Manage Agricultural 
Emergencies: 

In addition to the decline in inspections and interceptions, DHS has 
not been able to loan sufficient numbers of inspectors to respond to 
agricultural emergencies managed by USDA, according to USDA 
officials.[Footnote 74] Since the transfer of agricultural inspectors 
to DHS, the memorandum of agreement between the two agencies 
implementing the transfer provisions of the Homeland Security Act of 
2002 states that DHS and USDA agreed to develop procedures for USDA use 
of DHS employees, but it does not detail how many employees DHS must 
loan, or for what time period. While DHS has dispatched some 
agricultural inspectors on temporary duty, USDA officials said that 
compared to the assistance available prior to the transfer to DHS, the 
number of such personnel and the length of time they were available 
have been inadequate. For example, USDA's Western Regional Office 
requested 83 agricultural inspectors from DHS to help control and 
contain the exotic Newcastle disease outbreak in California over 2 
months in 2003. DHS provided 26 employees, but declined USDA's requests 
for further assistance. As a result, USDA officials are concerned that 
DHS will not loan a sufficient number of specialists to help treat and 
contain future agricultural emergencies, including the likely infection 
of the 2005 soybean crop with soybean rust--a plant disease identified 
by USDA pursuant to the Bioterrorism Act of 2002 as having the 
potential to pose a severe threat.[Footnote 75] DHS officials told us 
they have not been able to loan greater numbers of inspectors to USDA 
to respond to agricultural emergencies because of the staff shortage. 
DHS officials also said their policy is to loan agricultural inspectors 
with specific expertise, but the agency's first priority is to clear 
ports of entry. Once DHS feels the ports are adequately staffed with 
agricultural inspectors, the agency will be in a better position to 
dispatch agricultural inspectors to USDA for emergency purposes.

Experts say that routine inspections at ports of entry cannot, by 
themselves, prevent the accidental or intentional introduction of 
diseases. However, experience has shown that inspections can be 
successful in intercepting harmful diseases. In 2004, for example, DHS 
and USDA agricultural inspectors at a California mail facility 
prevented an outbreak of citrus canker when they successfully 
intercepted an illegal package of branch cuttings from Japan that were 
intended to start a new variety of citrus groves. An outbreak of citrus 
canker--a highly contagious bacterial disease--would threaten the 
state's crop and billion-dollar citrus industry, the second-largest in 
the nation.[Footnote 76] The state of Florida, for example, has lost 
2.1 million citrus trees due to the spread of the disease since 1995.

There Are Weaknesses Regarding the Flow of Critical Information Among 
Key Stakeholders: 

Federal agencies face barriers to promptly and effectively sharing 
critical guidance that is important to state and industry stakeholders 
to better protect the agriculture sector. State and industry officials 
told us they did not receive draft national guidance in a timely 
fashion; DHS may not be providing states sufficient guidance to 
allocate homeland security grant funding for agriculture; and after- 
action reports on test exercises and real outbreaks are not routinely 
shared with many stakeholders who could benefit from the lessons 
learned.

While efforts have been made to include agricultural stakeholders in 
the development of national guidance through various working groups, 
state and industry officials told us they were not given sufficient 
time to review and comment on key draft national guidance from DHS 
pertaining to protecting infrastructure and preparing for emergencies. 
Specifically, officials said that they had as little as 3 days to 
review and submit comments on both the draft National Response Plan and 
the draft National Infrastructure Protection Plan, even though they 
will be expected to implement critical sections of these plans. As a 
result, state and industry officials we spoke with are concerned that 
these plans may set unrealistic expectations. Although we asked, DHS 
officials did not explain to us how they distributed the National 
Response Plan to stakeholders. When distributing the National 
Infrastructure Protection Plan, DHS officials sent the plan to the 
offices of State Homeland Security Advisors, which had the 
responsibility to solicit comments from appropriate stakeholders within 
a 2-week period. DHS officials told us that they had no input over 
which state agencies received the draft plan, and they believe that in 
some instances state officials may have delayed distribution to state 
departments of agriculture. DHS also distributed the draft plan for 
review through the Government Coordinating Council and the Food and 
Agriculture Sector Coordinating Council. DHS officials told us that 
limiting the comment period to 2 weeks was necessary in order to meet 
the timelines set by HSPD-7. DHS officials further noted that because 
of the limited time allowed for initial review of the National 
Infrastructure Protection Plan, they released the plan as an interim 
document, allowing public and private stakeholders to have more input 
in the final plan. DHS officials acknowledged that in the future, they 
will use different procedures to distribute drafts for state and 
industry comments.

Furthermore, DHS may not be providing sufficient guidance to the states 
on how to use the Homeland Security Grant Program to obtain federal 
emergency preparedness assistance to support the agricultural 
sector.[Footnote 77] Although states must fulfill a number of 
requirements to receive DHS emergency preparedness grants, DHS gives 
leeway regarding which disciplines--such as fire, law enforcement, or 
agriculture--states choose to fund with DHS grants. However, according 
to federal and state officials, in the past, states used grant funding 
mainly for "traditional" emergency disciplines such as law enforcement. 
Prior to 2004, DHS grant application kits did not refer to agriculture 
as a sector eligible for emergency assistance. DHS grant program 
officials told us that, based on feedback from the states, in 2004 they 
included agriculture as an emergency discipline toward which states can 
apply DHS funding. However, despite the inclusion of agriculture in the 
application guidance, state officials told us that they have received 
limited funding from DHS relative to other emergency disciplines. For 
example, one official from a major agriculture state told us that in 
fiscal year 2004 the state had set aside less than $600,000 for 
agroterrorism projects out of a total of over $20 million that DHS had 
allocated to the state.[Footnote 78] The same state had received a $2- 
million grant to head a multistate partnership to protect against 
agroterrorism in fiscal year 2003, but because this amount was in the 
form of a directed grant, it could not be used to purchase equipment or 
training for state or local responders. Federal officials believe that 
agriculture continues to receive limited emphasis in the fiscal year 
2005 grant kit relative to other funding priorities. For example, in 
several instances throughout the fiscal year 2005 grant kit, 
agriculture does not appear in lists of other disciplines that are 
eligible for funding. Federal officials told us that without additional 
guidance or emphasis, state governments would continue to fund 
traditional emergency preparedness disciplines without considering 
agriculture.

Finally, state and industry officials told us that there is no 
mechanism to share lessons learned from federal and other state or 
industry test exercises or from real-life animal and plant disease 
outbreaks--such as the exotic Newcastle disease outbreak in California 
or from the karnal bunt outbreak in Texas. Several state and industry 
representatives expressed interest in receiving after-action reports so 
they could benefit from lessons learned. They also believe that lessons 
learned do not have to be industry-specific. For example, one crop 
industry group official told us it would be helpful to learn from FMD 
exercises, as well as the real-life bovine spongiform encephalopathy 
outbreak, about ways to better communicate during an outbreak. DHS 
officials told us that they will soon deploy a secure Web site for the 
food and agriculture sector as a component of DHS' Homeland Security 
Information Network. According to these officials, this new Web site, 
now in development, will provide government and industry the capability 
for information sharing; disseminating alerts and warnings; sharing 
best practices; and coordinating efforts between the states, industry, 
and federal agencies in a protected environment. However, this effort 
is still in its early stages, and to date the proposed Web site does 
not include after-action reports. In addition, federal, state, and 
industry officials we spoke with were apparently unaware of the Web 
site's development.

USDA Currently Has an Inadequate Number of Area and Regional Emergency 
Coordinators, Resulting in Insufficient Technical Assistance to the 
States: 

USDA faces another management challenge in helping states prepare for 
animal and plant emergencies because of an insufficient number of Area 
and Regional Emergency Coordinators. As a result, states are not 
receiving sufficient federal assistance in developing emergency 
response plans and other activities. In 2002, USDA created 14 Area 
Emergency Coordinator positions for animal health issues, and 1 
Regional Emergency Coordinator position for each of the eastern and 
western regions for plant disease outbreaks. By the time of our report, 
USDA had filled 13 of the 14 coordinator positions on the animal side, 
and both of the plant health positions. However, 2 of the animal health 
emergency coordinator positions--which together span six states, 
including the two biggest agricultural states--were vacant until late 
2004. Federal officials also told us that the current number of 
emergency coordinator positions is insufficient to cover their areas or 
regions, even if all the positions were filled. This is because the 
emergency coordinators are responsible for large geographic areas. On 
average, Area Emergency Coordinators cover 3 states, while Regional 
Emergency Coordinators are responsible for up to 27 states, plus 
territories. As a result of this heavy workload, USDA officials said, 
states are not receiving the maximum benefit of a coordinator's 
guidance and assistance in preparing state emergency response plans and 
other preparedness activities. For example, 10 states had not completed 
their required planning documents to identify resources needed in a 
plant health emergency, by the September 30, 2004, deadline.[Footnote 
79] And of those plans submitted, USDA found some to be of 
unsatisfactory quality. USDA officials attributed these delays and 
deficiencies, in part, to the fact that the Regional Emergency 
Coordinators cannot spend adequate time with state and federal 
agricultural officials in each state. They added that if there were a 
greater number of emergency coordinators, each coordinator would have 
fewer states to cover and thus more time to devote to their advisory 
responsibilities.

USDA is also struggling to attract an adequate number of qualified 
applicants due to the heavy travel involved to cover their areas or 
regions.[Footnote 80] In addition, the job requires traveling to animal 
or plant health emergency locations anywhere in the United States with 
as little as 24 hours notice, and for several weeks or more at a time. 
For example, one animal health emergency coordinator made 29 trips away 
from his duty station in 14 months on the job, not including other 
meetings in his three-state area. These trips were necessary for test 
exercises, conferences, regional FEMA meetings, USDA meetings, and the 
exotic Newcastle disease outbreak, which occurred in a state outside 
his area. USDA officials say that APHIS' goal is to put an Area 
Emergency Coordinator in each of the 43 states where there is an Area 
Veterinarian in Charge, and to increase the Regional Emergency 
Coordinators for plant disease outbreaks.

Shortcomings Exist in DHS' Coordination of Federal Working Groups and 
Research Efforts: 

Government and industry officials have expressed concern about 
shortcomings in DHS' coordination of national efforts to protect 
against agroterrorism. Since the issuance of HSPD-9 in January 2004, 
DHS and other federal agencies established several interagency working 
groups to address the tasks set out in the directive. To oversee these 
working groups, DHS recently established a Government Coordinating 
Council for agriculture. According to DHS officials, the council's 
charter outlines the specific tasks for federal agencies and the 
numerous working groups that have been established to address HSPD- 
9.[Footnote 81] However, other federal officials have expressed concern 
that because the working groups were established prior to the 
development of the council, activities under way are not well 
coordinated. For example, according to agency officials, the task list 
developed by the Government Coordinating Council Charter does not 
correspond to the tasks outlined in other important national guidance 
documents, such as the National Response Plan. This discrepancy could 
lead to confusing implementation of national guidance. Furthermore, 
state and industry officials we interviewed said they did not 
understand the roles and responsibilities of these various groups and 
that no one seemed to be tracking the specific purpose of various 
efforts.

In addition, DHS lacks controls to coordinate research efforts with 
other agencies, even though HSPD-9 specifically designates DHS as the 
agency responsible for coordinating research efforts to protect against 
agroterrorism. For example, some of the DHS-supported activities at the 
Centers of Excellence appear to duplicate research conducted by USDA's 
Agricultural Research Service and the Cooperative State Research, 
Education, and Extension Service. Specifically, one center is 
developing rapid diagnostic tools for FMD and other foreign animal 
disease research that is apparently already under way at USDA. DHS 
officials told us that while program staff at DHS, HHS, USDA, and other 
agencies have engaged in some preliminary discussions, there is no 
overall departmental coordination of policy and budget issues 
concerning agriculture and food security within DHS and with other 
departments and agencies. USDA officials stated that while they are not 
aware of any overlap in the programs supported by USDA and DHS, they 
are also not aware of the full scope of the activities of the Centers 
of Excellence.[Footnote 82] USDA officials agree that more coordination 
and cooperation is needed between USDA and DHS regarding research 
activities.

Agencies' Diagnostic Laboratory Networks Are Not Yet Integrated: 

While the development of USDA and HHS national diagnostic laboratory 
networks is a positive step, their effectiveness in sharing diagnostic 
information about diseases is compromised because their databases are 
not yet integrated. At the time of our review, USDA had not integrated 
the databases of its own national laboratory networks due to 
compatibility and confidentiality issues. Because the USDA-affiliated 
laboratories operated independently prior to the creation in 2002 of 
the National Animal Health Laboratory Network and the National Plant 
Diagnostic Network, the member laboratories are still using their 
individual databases. USDA officials say these individual databases use 
different codes and messaging systems and thus do not communicate well 
with each other. For example, each National Animal Health Laboratory 
Network facility enters animal disease diagnostic information into its 
own database, but neither of the other laboratories in the network nor 
USDA's NVSL--which is responsible for officially testing foreign animal 
diseases--can read that information. Instead, USDA relies on 
traditional communication channels, such as emails and phone calls, to 
relay test results and the recipients do not have electronic access to 
the detailed data. This approach limits USDA's ability to look at 
diagnostic data from across the country, detect trends, and implement a 
response as quickly as it could with an integrated, real-time system. 
USDA officials told us that if their laboratories' diagnostic databases 
were linked to each other nationally, the agency would be able to 
better monitor and respond more quickly to disease outbreaks. USDA 
stresses that the ability to share diagnostic information quickly is 
particularly important for diseases that spread rapidly, such as FMD, 
because response time is critical in controlling the spread of the 
disease and reducing the economic impact.

In addition, the Food Emergency Response Network, CDC's Laboratory 
Response Network, and USDA's National Animal Health Laboratory Network 
and National Plant Diagnostic Network have not yet linked their 
databases to each other for diseases of common concern. USDA and HHS 
officials say it is important for their agencies to rapidly share 
complete diagnostic test results with each other regarding diseases of 
concern to all of the agencies involved. For example, if USDA found a 
chicken with a strain of avian influenza that is transferable to 
humans, it would be important for CDC to immediately become aware of 
this information so that it could take appropriate measures to protect 
human health. Similarly, if USDA confirmed a cow with bovine spongiform 
encephalopathy, it would be important for FDA to know quickly so that 
it could investigate whether the infected products had entered the food 
chain and take any necessary action. In addition, USDA officials say 
that an integrated diagnostic information system would aid federal 
agencies' ability to gather evidence in investigations, including 
criminal ones, of disease outbreaks.

Federal agencies are aware of the importance of integrating databases 
and are taking steps to link their networks. As authorized by the 
Bioterrorism Act of 2002, USDA is currently working on integrating all 
of the National Animal Health Laboratory Network facilities so that 
they are able to send diagnostic information in real-time to a 
national, electronic database. This new database will allow diagnostic 
information to be sorted and analyzed by USDA's Centers for 
Epidemiology and Animal Health to track animal diseases across the 
United States and detect any trends. If a positive test result from any 
of the laboratories enters this new database, it will automatically 
trigger a series of events to notify relevant parties. USDA officials 
say that while they will still rely on phone calls and other 
communication channels, this integrated, real-time database will 
improve accuracy and speed in the event of an emergency. So far, USDA 
has piloted the integration of some of the National Animal Health 
Laboratory Network facilities' databases for two foreign animal 
diseases, and it plans to launch the national database for one of those 
diseases in February 2005. By the end of 2005, USDA plans to integrate 
information from 12 pilot National Animal Health Laboratory Network 
laboratories into the database for the eight diseases of highest 
concern if this project is fully funded.[Footnote 83] In addition, USDA 
is planning to integrate its plant disease and pest databases for use 
in the National Plant Diagnostic Network to monitor outbreaks 
nationwide.[Footnote 84]

USDA officials told us that integrating the different laboratories' 
databases is a challenge because of the concern for the leak of 
information. This concern arises because in the event of an outbreak, 
there would be international trade repercussions, and USDA would be 
responsible for reimbursing producers for animals that would have to be 
destroyed. Other laboratories face similar security concerns. However, 
the member laboratories within CDC's Laboratory Response Network, which 
has been in place since 1999, are able to securely share diagnostic 
results with each other, and officials told us it is important for USDA 
to overcome this problem. Similarly, FDA uses a secure data exchange 
vehicle to share information across its diagnostic laboratory network. 
In an effort to address security concerns, USDA has begun building 
firewalls and developing a set of protocols to protect data and ensure 
confidentiality in such an environment.

As called for in HSPD-9, USDA and HHS created an interagency working 
group in late 2004 to begin the process of coordinating their networks 
for zoonotic disease surveillance.[Footnote 85] For example, USDA and 
FDA are looking at how they can share animal disease and food pathogen 
test results through a secure data exchange. However, the agencies must 
also work out common testing benchmarks and protocols in order to 
interpret each other's diagnostic information accurately. For instance, 
if CDC was aware of the type of diagnostic tools that USDA was using, 
the agency would be better able to interpret results and take 
appropriate action. Agency officials added that DHS' planned National 
Biosurveillance Integration System intends to use information from the 
various federal laboratory networks and combine this with threat and 
intelligence data to further improve surveillance efforts for potential 
terrorist activity. DHS officials indicated that the National 
Biosurveillance Integration System would have an initial capability for 
integrating data from these laboratories by spring 2005.

Conclusions: 

Prior to the terrorist attacks of 2001, relatively little attention had 
been focused on agroterrorism. Recently, however, agriculture is 
receiving more attention as experts and government officials 
increasingly recognize the need to reduce the vulnerability of this 
sector to the deliberate introduction of animal or plant diseases. 
Federal and state agencies are investing considerable resources to 
better identify and manage the risks of agroterrorism and have ramped 
up planning and coordination efforts to respond to such an event. There 
are still, however, several important challenges that should be 
addressed to better equip our nation to manage agroterrorism. First, 
the United States must enhance its ability to quickly identify and 
control diseases. Until USDA requires accredited veterinarians to be 
trained to recognize the clinical signs of foreign animal diseases, 
such diseases may not be detected and confirmed as early as possible, 
wasting valuable time that could be spent containing them. Similarly, 
until USDA evaluates the costs and benefits of using rapid diagnostic 
tools at the site of an outbreak, the agency may be missing an 
opportunity to reduce the impact of agroterrorism. Without on-site 
diagnosis to help monitor neighboring herds, animals would likely be 
slaughtered based on proximity rather than confirmed infection, 
unnecessarily magnifying the impact of an attack. Once diseases have 
been accurately diagnosed, the United States needs to quickly decide 
whether vaccines should be used to control an outbreak and have the 
ability to deploy ready-to-use vaccines within 24 hours. Otherwise, 
during an emergency, valuable time could be lost while deliberating 
whether to use vaccines and waiting for vaccines to be transformed into 
a ready-to-use state.

Several less complex managerial problems should also be addressed in 
the short term to improve the nation's ability to protect against 
agroterrorism. Our nation's ports could be unnecessarily vulnerable to 
the intentional introduction of a disease or pest, unless agencies 
analyze the reasons for declining agricultural inspections and 
streamline the flow of information between USDA and DHS inspectors at 
ports of entry. Furthermore, states and industry may not have the 
ability and information to fulfill their assigned roles in protecting 
agriculture unless DHS provides them with meaningful opportunities to 
comment on national guidance; agencies share after-action reports of 
test exercises and real-life emergencies with these stakeholders; and 
USDA identifies ways to fill and expand Area and Regional Emergency 
Coordinator positions. Finally, until DHS ensures that tasks outlining 
agency responsibilities are consistent with national plans and 
guidelines and DHS develops a method to adequately track federally 
funded research efforts, the United States will lack a coordinated 
national approach to protect against agroterrorism, possibly resulting 
in gaps or needless duplication of effort. By overcoming these 
challenges, the United States will be in a better position to protect 
against and respond to a disease outbreak, whether natural or 
intentional.

Recommendations for Executive Action: 

To address significant and complex challenges that limit the United 
States' ability to quickly and effectively respond to a widespread 
attack on animal agriculture, we recommend that the Secretary of 
Agriculture address the following four challenges in the context of the 
agency's overall risk management efforts: 

* expedite the review and issuance of the draft rule on USDA's 
accreditation process for veterinarians, which would require training 
in recognizing foreign animal diseases;

* evaluate the costs and benefits of using rapid diagnostic tools at 
the site of an outbreak;

* examine the costs and benefits of developing stockpiles of ready-to- 
use vaccines that can be quickly deployed against animal diseases of 
primary concern; and: 

* simplify the decision-making process for determining if and/or when 
to use vaccines to control an outbreak to ensure that rapid decisions 
can be made in the event of a terrorist attack.

To address management problems that reduce the effectiveness of 
agencies' routine efforts to protect against agroterrorism, we 
recommend the following seven actions: 

* the Secretaries of Homeland Security and Agriculture work together to 
identify the reasons for declining agricultural inspections and to 
identify potential areas for improvement;

* the Secretaries of Homeland Security and Agriculture streamline the 
flow of information between USDA and DHS agricultural inspectors, and 
expedite the integration of the two agencies' databases and information 
technology systems at the port level;

* the Secretary of Homeland Security develop a mechanism to promptly 
and effectively seek input from key stakeholders on national guidance 
that affects their roles in protecting agriculture and responding to an 
emergency;

* the Secretaries of Homeland Security, Agriculture, and Health and 
Human Services, and the Acting Administrator of the Environmental 
Protection Agency compile relevant after-action reports from test 
exercises and real-life emergencies and disseminate the reports through 
the Homeland Security Information Network that DHS is developing;

* the Secretary of Agriculture develop a strategy to increase the 
number of Area and Regional Emergency Coordinator positions so that the 
agency faces less difficulty filling these positions and is better able 
to assist states in preparing for an agriculture emergency, including a 
terrorist attack;

* the Secretary of Homeland Security work to ensure that task lists for 
the various agencies and working groups engaged in securing agriculture 
are consistent with national plans and guidelines; and: 

* the Secretary of Homeland Security develop controls to better 
coordinate and track federally funded research efforts with other 
agencies to protect against agroterrorism.

Agency Comments and Our Response: 

We provided USDA, DHS, HHS, EPA, and DOD with a draft of this report 
for their review and comment. We received written comments on the 
report and its recommendations from USDA, DHS, and HHS. EPA and DOD 
provided minor technical clarifications.

USDA commented that the report provided a number of appropriate and 
insightful recommendations. In several instances, USDA said it could 
take actions that relate to our recommendations. For example, USDA said 
that the department could explore the possibility of speeding up its 
process for deciding when to use vaccines and that it will consider 
options to cut some of the delay in obtaining ready-to-use vaccines. 
The department also raised some concerns regarding various aspects of 
our report. For example, as we recommend, USDA noted that there may be 
opportunities to use rapid diagnostic tools to help with diagnosis of 
animal diseases, but said that the tools need to be validated. Further, 
USDA commented that the agency would in all cases still require 
confirmation that relies on traditional testing procedures. As stated 
in our report, we continue to believe that use of these tools at the 
site of an outbreak would help reduce the impact of a terrorist attack 
because, among other things, these tools would help prevent 
laboratories from becoming overwhelmed with test samples. USDA's 
written comments and our detailed responses to their concerns appear in 
appendix VI. USDA also provided technical comments that we 
incorporated, as appropriate, throughout the report.

DHS generally concurred with the report's recommendations and indicated 
that the agency is in the process of taking several corrective actions 
addressing two of our recommendations. For example, as we recommend, 
DHS is working with USDA to identify the reasons for declining 
agriculture inspections and to identify potential areas for 
improvement. Regarding our recommendation that DHS and USDA streamline 
the flow of information between the two agencies' agricultural 
inspectors, DHS stated that it is already working with USDA to enhance 
communication; that is, the two agencies are working to finalize the 
section in the Memorandum of Agreement governing the sharing of 
information. DHS also provided technical comments that we incorporated 
as appropriate. DHS's written comments and our detailed responses 
appear in appendix VII.

Overall, HHS agreed with the report's recommendations. In commenting on 
our recommendation that the agencies compile relevant after-action 
reports from test exercises and real-life emergencies and disseminate 
the reports through the Homeland Security Information Network that DHS 
is developing, HHS officials noted that CDC already has standardized 
after-action reporting procedures in place. HHS officials also noted 
that another challenge in protecting the nation against agroterrorism 
is the shortage of laboratory space to conduct trials for vaccine 
development. HHS's written comments appear in appendix VIII. HHS also 
provided technical comments that we incorporated, as appropriate, 
throughout the report.

We are sending copies of this report to the Secretaries of Agriculture, 
Homeland Security, Health and Human Services, and Defense; the Acting 
Administrator of the Environmental Protection Agency; and interested 
congressional committees. In addition, this report will be available at 
no charge on the GAO Web site at [Hyperlink, http://www.gao.gov].

If you or your staff have any questions concerning this report, I can 
be reached at (202) 512-3841 or [Hyperlink, robinsonr@gao.gov]. Major 
contributors to this report are included in appendix IX.

Signed by: 

Robert A. Robinson: 
Managing Director, Natural Resources and Environment: 

[End of section]

Appendixes: 

Appendix I: Scope and Methodology: 

To determine what changes have taken place since September 11, 2001, in 
federal agencies' roles and responsibilities to protect against 
agroterrorism, we reviewed the relevant laws and presidential 
directives in force before and after September 11, 2001. Specifically, 
our Office of General Counsel reviewed the Robert T. Stafford Disaster 
Relief and Emergency Assistance Act of 1974,[Footnote 86] the 
Agriculture Risk Protection Act of 2000, [Footnote 87] the Farm 
Security and Rural Investment Act of 2002,[Footnote 88] the Public 
Health Security and Bioterrorism Preparedness and Response Act of 
2002,[Footnote 89] and the Homeland Security Act of 2002. We also 
reviewed presidential directives that define agency roles in 
emergencies such as acts of agroterrorism, including Homeland Security 
Presidential Directives 5, 7, 8, and 9. Finally, we interviewed 
numerous agency officials from the U.S. Department of Agriculture 
(USDA), the Department of Homeland Security (DHS), the Department of 
Health and Human Services (HHS), the Environmental Protection Agency 
(EPA), the Department of Defense (DOD), and the Department of Justice.

To determine what steps the federal government has taken to protect 
against agroterrorism, we examined (1) steps taken at the federal 
level, (2) federal action to prepare the states, and (3) coordination 
with industry. To determine what steps have been taken at the federal 
level, we reviewed classified and unclassified agency documents, 
including vulnerability assessments conducted by USDA and HHS for 
agricultural and food products; the draft of the interim National 
Infrastructure Protection Plan and the final version of the National 
Response Plan; and lists of interagency working groups and coordinating 
committees. We also interviewed agency officials involved in creating 
and enforcing U.S. policy concerning agroterrorism, including officials 
from USDA's Office of Homeland Security, Animal and Plant Health 
Inspection Service (APHIS), Agricultural Research Service, and the 
Cooperative State Research Education and Extension Service; DHS' 
Information Analysis and Infrastructure Protection directorate, 
Emergency Planning and Response directorate, Border and Transportation 
Security directorate, Science and Technology directorate, and Office 
for Domestic Preparedness; HHS' Food and Drug Administration and 
Centers for Disease Control and Prevention; and EPA. In addition, we 
contacted USDA's Inspector General and state governments to determine 
what prior work had been done in this area. To identify federal actions 
to strengthen surveillance at the borders we visited or spoke with 
officials at three maritime ports, three airports, one border-crossing, 
and one international mail facility, where we interviewed inspectors in 
DHS' Customs and Border Protection, USDA's Plant Protection and 
Quarantine, and USDA's Veterinary Services. We also reviewed documents 
obtained from officials and inspectors, including samples of inspection 
records, training schedules, as well as interagency agreements that 
clarify agency roles and responsibilities, such as the Memorandum of 
Agreement between DHS and USDA.[Footnote 90] Finally, we spoke with 
officials at DHS' Customs and Border Protection headquarters in 
Washington, D.C. To assess the federal government's coordination of its 
efforts to protect against agroterrorism, we considered the Office of 
Management and Budget Circular A-123, Management Accountability and 
Control,[Footnote 91] and the standards in GAO's Internal Control: 
Standards for Internal Control in the Federal Government.[Footnote 92]

To determine how the federal government is helping states to protect 
against agroterrorism, we used structured interviews of state and 
federal officials in three major agriculture states we visited between 
July and October 2004. We selected these states in part because of 
their status as the top three producers of agricultural commodities 
sold before processing, according to data that we obtained from USDA's 
Economic Research Service. Additionally, prior to our visit to the 
major agricultural states, we visited officials in another state to 
test our structured interview methodology. In these four states, we 
interviewed officials from state agencies overseeing agriculture, 
homeland security, and emergency services; personnel from federal and 
state diagnostic laboratory networks and research centers; and 
officials from the regional or state offices of USDA and the Food and 
Drug Administration. In addition to the three top producing agriculture 
states, we had selected a fourth state to visit to get a wider 
geographic distribution, but due to severe weather during the fall of 
2004, we were only able to interview officials from the state 
department of agriculture by phone. We also reviewed documentation from 
state and federal officials, including state agricultural emergency 
response plans, after-action reports from disease outbreaks and test 
exercises, and federal guidance to the states.

To determine how the federal government is coordinating with industry 
to protect against agroterrorism, we reviewed federal guidance to 
industry. We also interviewed officials from organizations representing 
agriculture interests in Washington D.C., and officials from DHS, USDA, 
and HHS who are involved in coordinating with industry. Finally, we 
attended coordinating meetings in Washington, D.C., involving 
representatives from the food and agriculture sector and federal 
agencies.

To determine what challenges remain to protect against agroterrorism, 
we used knowledge gained in addressing our other objectives. Using 
structured interviews, we consulted with nongovernment experts in the 
fields of agricultural security and counterterrorism. We selected our 
experts based on their professional and research qualifications and 
experience in the field of agroterrorism. We then analyzed the content 
of the experts' responses to identify common themes. Finally, we 
analyzed the content of relevant peer-reviewed journal articles to 
identify common themes.

We conducted our work from February 2004 through January 2005 in 
accordance with generally accepted government auditing standards.

[End of section]

Appendix II: List of Experts GAO Consulted and Summary of Observations: 

This appendix provides the names and affiliations of nongovernment 
experts from academia and other research organizations that we 
interviewed during our work and summarizes key observations they made. 
The information presented in this appendix does not reflect absolute 
consensus of opinion among the experts on each topic; however, it 
summarizes their observations on issues where many of the experts held 
similar views. The information contained in this appendix should not be 
considered to be the views of GAO.

List of Experts Interviewed: 

* Roger Breeze, B.V.M.S., Ph.D., M.R.C.V.S., CEO, Centaur Science 
Group, Former Director, Plum Island Animal Disease Center;[Footnote 93]

* Corrie Brown, D.V.M., Ph.D., Professor and Coordinator of 
International Activities, Department of Veterinary Medicine, University 
of Georgia;[Footnote 94]

* Rocco Casagrande, Ph.D. in Biology, Director, The Center for Homeland 
Security, Abt Associates;

* Peter Chalk, Ph.D. in Political Science, Security and Political 
Analyst, the Rand Corporation, Santa Monica, California;

* R. James Cook, Ph.D., Interim Dean, College of Agricultural, Human, 
and Natural Resource Sciences, Washington State University, Pullman, 
Washington;

* Radford Davis, D.V.M., M.P.H., Assistant Professor of Public Health, 
College of Veterinary Medicine, Department of Veterinary Microbiology 
and Preventive Medicine, Iowa State University;[Footnote 95]

* Jacqueline Fletcher, Ph.D., Past President of the America 
Phytopathological Society, Currently Sarkeys Distinguished Professor, 
Department of Entomology and Plant Pathology, Oklahoma State University;

* David R. Franz, D.V.M., Ph.D., Director, National Agricultural 
Biosecurity Center, Kansas State University;

* Brian Jenkins, Senior Advisor to the President of the Rand 
Corporation, Member of the Comptroller General of the United States' 
Advisory Board;

* Harley Moon, D.V.M., Ph.D., Chair, National Research Council 
Committee on Biological Threats to Agricultural Plants and Animals, 
Veterinary Medical Research Institute, Iowa State University;

* James A. Roth, D.V.M., Ph.D., Distinguished Professor of Immunology, 
Assistant Dean, International Programs and Public Policy; Director, 
Center for Food Security and Public Health, College of Veterinary 
Medicine, Iowa State University;

* John L. Sherwood, Ph.D., Chair, American Phytopathological Society 
Public Policy Board, Professor and Department Head, Department of Plant 
Pathology, University of Georgia;

* Mark C. Thurmond, D.V.M., Ph.D., Professor, Department of Medicine 
and Epidemiology, University of California, Davis;

* Alfonso Torres, D.V.M., MS, Ph.D, Executive Director, New York State 
Animal Health Diagnostic Laboratory, and Associate Dean for Veterinary 
Public Policy, College of Veterinary Medicine, Cornell 
University;[Footnote 96] and: 

* Mark Wheelis, Senior Lecturer in Microbiology, University of 
California.

Summary of Experts' Observations: 

We conducted structured interviews with nongovernment experts in the 
fields of animal and plant diseases, terrorism, bioterrorism, and 
agroterrorism. Before conducting our interviews, we reviewed the 
experts' relevant studies and publications and provided them with a 
list of questions. We sought their views on a range of topics, 
including the vulnerability of U.S. agriculture, government agencies' 
roles and responsibilities, and agencies' efforts to protect against 
agroterrorism.

Vulnerability of U.S. Agriculture: 

* In general, experts agree that U.S. agriculture is vulnerable to 
agroterrorism because of the relative ease with which highly contagious 
diseases can be introduced in livestock and crops. An agroterrorism 
event could not only cause severe economic losses to farmers and rural 
communities, it could also halt or slow down international trade, and 
negatively impact consumer confidence in the government's ability to 
ensure the safety of our food supply. For these reasons, many experts 
believe that agriculture is an attractive target for terrorists. Some 
experts note that the methods for containing the spread of highly 
infectious animal diseases--the highly visible and costly slaughter, 
incineration, and/or burial of large numbers of animals--creates the 
incentive for terrorists to attack.

* Most experts note that livestock presents a more attractive target 
for terrorists than crops, although both are vulnerable. The biggest 
threat at the farm level would be the deliberate introduction of FMD, a 
highly contagious animal disease that has been eradicated in the United 
States. Highly contagious animal diseases can spread more quickly than 
plant diseases, and the concentration of animals in feedlots and 
livestock markets would contribute to the rapid spread of infection. 
Experts remarked that an attack of this sort would be cheap, requires 
no technical expertise, and would not harm the perpetrator. Some 
experts remark that transportation of live cattle, hogs, and poultry, 
across the country further enables diseases to spread quickly and 
easily over large areas. On the other hand, some of the experts state 
that plant diseases often need particular weather and environmental 
conditions for them to take hold and flourish, making them a less 
attractive target.

* Most experts identify the same group of animal diseases as the most 
likely to be used against agriculture--those include FMD, avian 
influenza, classical and African swine fevers, and exotic Newcastle 
disease. However, there is wide consensus among experts that FMD poses 
the highest risk because it is highly contagious, it results in the 
need to destroy large numbers of animals which, in turn, generates a 
great deal of media attention, and can inflict severe economic losses. 
Some of the experts also raise concerns about zoonotic diseases such as 
Rift Valley fever, Nipah Virus, and highly pathogenic avian influenza, 
but not all experts agree that zoonotic diseases pose a significant 
threat. On the plant side, some experts identify soybean rust as the 
disease of most concern because it is easy to introduce and can spread 
by wind-borne spores. Another expert raises concerns about the threat 
of contamination with genetically engineered seeds and observes that it 
would only take one or two seeds to contaminate an entire cargo of 
product.

Government Agencies' Roles and Responsibilities: 

* Some experts we interviewed agree that the federal government is 
undertaking significant initiatives to protect against agroterrorism. 
They have generally favorable comments regarding the role that DHS 
plays in protecting against agroterrorism. Some see the emergence of 
DHS as a coordinator for agroterrorism activities within the federal 
government as a major change that signals the importance of the 
agriculture sector. Some experts also indicate that there was initial 
confusion about DHS' role and that, because the agency is still very 
new, their role is still evolving.

* Many experts identify the lack of communication at the federal level 
as their biggest concern and observe that within the federal government 
there is no clear understanding of the initiatives that are in place to 
protect against an attack and that there appears to be a duplication of 
efforts. Some experts believe that there is little coordination between 
federal and state agencies, or between states, and that federal 
agencies are not sufficiently sharing information with state and local 
officials. Also, there is insufficient coordination and communication 
with industry groups.

Agencies' Efforts to Protect against Agroterrorism: 

* In terms of planning efforts, several experts indicated that the 
development of a National Response Plan and associated Emergency 
Support Functions is exactly what was needed. They believe that it is 
important to include the states' input in the preparation of those 
documents since the states will be the first responders. Several 
experts state that preparing a response plan for dealing with an 
unintentional outbreak would also be useful in preparing for an 
agroterrorism event. Many experts note that test exercises can help 
identify potential problems in response plans that may arise in 
application.

* Many experts agree that focusing the majority of efforts on 
preventing agroterrorism is not the answer because it is impossible to 
prevent all disease introductions, whether accidental or intentional. 
Instead, several experts note that agencies need to focus more on rapid 
detection and identification of diseases and in establishing quick 
response mechanisms.

* Most experts agree that USDA's creation of the National Animal Health 
Laboratory Network and the National Plant Diagnostic Network is a 
positive development. However, some experts disagree as to whether the 
networks can provide sufficient surge capacity or if they need to be 
expanded.

* Some experts recommend additional research and development to create 
FMD vaccines that contain markers to differentiate animals that are 
merely vaccinated from those that are infected.

* While some experts agree that training of veterinarians in foreign 
animal diseases is inadequate, others note that actual training and 
awareness of the importance of such training has improved. Some experts 
explain that foreign animal disease training is not required in all 
veterinary schools. This training is also not a prerequisite to become 
a USDA-accredited veterinarian. On the plant side, some experts note 
that the United States does not have an adequate number of people 
trained in plant pathology. Many experts agree that more federal 
funding should be dedicated to plant pathology research and job 
creation.

* Some experts recommend using rapid diagnostic tools at the site of an 
outbreak, rather than shipping samples to USDA reference laboratories. 
They state that this would save valuable time in containing diseases, 
whether naturally occurring or resulting from agroterrorism. The use of 
these rapid tools on site would also help prevent laboratories from 
becoming overwhelmed with samples, particularly if a terrorist attack 
involved the multi-focal introduction of a disease or if diseases were 
repeatedly introduced over long periods of time.

[End of section]

Appendix III: Animal and Plant Diseases that Pose a Severe Threat to 
Agriculture: 

Table 1: List of Select Animal Diseases Identified by USDA Pursuant to 
the Bioterrorism Act of 2002 as a Severe Threat to the Livestock 
Industry and Human Health: 

Diseases and agents: Avian Influenza (highly pathogenic); 
Animals affected: Chicken, turkey, wild birds, water fowl; 
Route of transmission: Body fluids; aerosols; fomites; 
Availability of vaccine: Yes; 
Can affect humans: Yes.

Diseases and agents: Exotic Newcastle Disease; 
Animals affected: Poultry, other avian species; 
Route of transmission: Direct contact with body fluids; aerosols; feces 
or respiratory droplets; 
Availability of vaccine: Yes; 
Can affect humans: Yes.

Diseases and agents: Nipah; 
Animals affected: Pigs, horses, cats, dogs; 
Route of transmission: Close direct contact with contaminated tissue or 
body fluids; 
Availability of vaccine: No; 
Can affect humans: Yes.

Diseases and agents: Hendra; 
Animals affected: Horses, cats, guinea pigs; 
Route of transmission: Direct contact; oranasal; ingestion of 
contaminated material; fruit bats; 
Availability of vaccine: No; 
Can affect humans: Yes.

Diseases and agents: Eastern Equine Encephalitis; 
Animals affected: Horses; 
Route of transmission: Vectors infected with virus; 
Availability of vaccine: Yes; 
Can affect humans: Yes.

Diseases and agents: Venezuelan Equine Encephalomyelitis; 
Animals affected: All equine, bats, birds, rodents; 
Route of transmission: Mosquito (vectors) infected with virus; 
Availability of vaccine: Yes; 
Can affect humans: Yes.

Diseases and agents: Foot and Mouth Disease; 
Animals affected: All cloven hoofed animals including cattle, sheep, 
goats, pigs; 
Route of transmission: Aerosol; direct contact; ingestion; fomites; 
Availability of vaccine: Yes; 
Can affect humans: Yes, but rarely infects humans.

Diseases and agents: Rift Valley Fever; 
Animals affected: Cattle, sheep, goats, dogs, cats, camels, monkeys; 
Route of transmission: Insect vectors (mosquitoes); direct contact with 
blood or tissue; 
Availability of vaccine: Yes; 
Can affect humans: Yes.

Diseases and agents: Rinderpest; 
Animals affected: Cattle, sheep, goats; 
Route of transmission: Direct or close contact with body fluids; 
Availability of vaccine: Yes; 
Can affect humans: No.

Diseases and agents: African Swine Fever; 
Animals affected: Domestic and wild pigs; wart hogs; 
Route of transmission: Direct contact with body fluids, especially 
blood; fomites; tick vectors; 
Availability of vaccine: No; 
Can affect humans: No.

Diseases and agents: Classical Swine Fever; 
Animals affected: Domestic pigs; 
Route of transmission: Ingestion (uncooked garbage); fomites; aerosol; 
direct contact; 
Availability of vaccine: Yes; 
Can affect humans: No.

Sources: GAO analysis and 9 CFR ß121.3.

Note: Other animal diseases identified by the Bioterrorism Act of 2002 
that have the potential to pose a severe threat to livestock and human 
health include bacillus anthracis, brucella abortusm, brucella 
melitensis, brucella suis, burkholderia mallei, burkholderia 
pseudomallei, clostridium botulinum, coccidioides immitis, francisella 
tularensis, botulinum neurotoxins, clostridium perfringens epsilon 
toxin, shigatoxin, staphylococcal enterotoxins, T-2 toxin, African 
horsesickness, contagious bovine pleuropneumonia, peste des petits 
ruminants, vesicular stomatitis virus, swine vesicular disease virus, 
lumpyskin disease virus, bluetongue virus, and sheep pox and goat pox.

[End of table]

Table 2: List of All Plant Diseases Identified by USDA as Severe 
Threats to Plants Pursuant to the Bioterrorism Act of 2002: 

Diseases and agents: Soybean Rust; 
Plants affected: Soybeans; 
Route of transmission: Wind-borne spores.

Diseases and agents: Southern Bacteria Wilt; 
Plants affected: Potatoes, geraniums, tomatoes, peppers, eggplants, 
beans, bittergourds, beets, and tobacco; 
Route of transmission: Soil, contaminated water, equipment.

Diseases and agents: Plum Pox; 
Plants affected: Peaches, plums, apricots, almonds; 
Route of transmission: Grafting from infected trees or aphid vectors.

Diseases and agents: Downy Mildew of Corn; 
Plants affected: Sugarcane, corn; 
Route of transmission: Wind-borne, seedborne, infected soil.

Diseases and agents: Brown Stripe Downy Mildew of Maize; 
Plants affected: Corn; 
Route of transmission: Wind, rain, water, and physical contact between 
plants.

Diseases and agents: Synchytrium Endobioticum (potato wart); 
Plants affected: Potatoes; 
Route of transmission: Soil, on tubers grown in infected soil, 
machinery and implements used in potato cultivation, on footwear and 
manure from animals that have fed on infected tuber.

Diseases and agents: Bacterial Leaf Streak of Rice; 
Plants affected: Rice; 
Route of transmission: Wind-borne, seeds, infected soil and water, 
irrigation, rain.

Diseases and agents: Citrus Greening; 
Plants affected: Citrus fruit trees; 
Route of transmission: Insect vector, grafting from infected trees.

Diseases and agents: Pierce's Disease; 
Plants affected: Grapes, almonds, peaches, pears, citrus, alfalfa, 
coffee, oleander, oak, sycamore, maple, elm, mulberry, ornamental 
grasses; 
Route of transmission: Insect vector.

Sources: GAO analysis and 7 CFR ß331.3.

[End of table]

[End of section]

Appendix IV: U.S. Concentration of Cattle, Chicken, and Corn Production 
in 2002: 

Figure 6: Top Cattle-Producing States in 2002: 

[See PDF for image] 

Note: Cattle production consists of milk and beef cattle.

[End of figure] 

Figure 7: Top Chicken-Producing States in 2002: 

[See PDF for image] 

Note: Chicken production consists of broilers and layers. Two states 
did not disclose their information.

[End of figure] 

Figure 8: Top Corn-Producing States in 2002: 

[See PDF for image] 

Note: One state did not produce corn.

[End of figure] 

[End of section]

Appendix V: Additional Information on National and Agency-Specific 
Steps Taken to Protect against Agroterrorism: 

National Infrastructure Protection Plan: 

DHS worked jointly with other federal agencies to develop the interim 
National Infrastructure Protection Plan, a standardized plan to 
safeguard the nation's critical infrastructure, including agriculture, 
before a terrorist attack occurs. USDA and HHS, in consultation with 
DHS, developed sector-specific plans for agriculture and food, which 
were incorporated into the interim National Infrastructure Protection 
Plan. These sector-specific plans outline activities including: 

* Identifying the sector's assets;

* Identifying and assessing the vulnerabilities and interdependencies 
among assets, and analyzing potential risks based on threats and 
consequences;

* Prioritizing assets based on an analysis and normalization of 
vulnerability data;

* Developing sustainable programs to protect assets and implementing 
these programs when necessary; and: 

* Using metrics to measure and communicate the effectiveness of the 
sector-specific plans.

The National Infrastructure Protection Plan outlines roles and 
responsibilities for federal, state, and local governments to safeguard 
agriculture. The plan includes a description of coordination activities 
to reduce the vulnerability of critical infrastructures. According to 
DHS officials, the department--along with other federal departments and 
agencies--will work with state and local governments and the private 
sector to further refine stakeholder roles and responsibilities in 
order to implement the National Infrastructure Protection Plan. In 
addition, these entities will work together to implement sector- 
specific plans that will support the National Infrastructure Protection 
Plan. The results of these implementation efforts will be reflected in 
the next version of the National Infrastructure Protection Plan, which 
according to DHS officials, will be issued within 270 days of issuance 
of the current interim plan.

National Response Plan: 

In addition to the National Infrastructure Protection Plan, DHS 
coordinated the integration of various interagency and agency-specific 
incident management plans into a single all-hazard National Response 
Plan that would be used in the event of a terrorist attack. The 
National Response Plan includes appendixes, known as Emergency Support 
Functions, that detail the responsibilities of federal agencies for 
coordinating resources during national emergencies. One of the these 
appendixes, Emergency Support Function-11, outlines the roles and 
responsibilities of local, state, and federal responders in addressing 
the national response to outbreaks or other emergencies in the food and 
agriculture sector. For example, Emergency Support Function-11: 

* Assigns USDA, through APHIS, as the lead agency for responding to a 
disease outbreak, and outlines USDA's role in supporting such 
activities as detection, control, and eradication;

* Assigns state agencies, along with USDA's Area Veterinarian-in- 
Charge, the task of establishing a Joint Operations Center, which will 
serve as the focal point for coordinating the disease management and 
decision-making process; and: 

* Assigns local or county governments with the task of activating an 
Emergency Operations Center to provide a local base of operations.

National Incident Management System: 

As directed by HSPD-5, DHS is overseeing the adoption of a National 
Incident Management System by federal and state agencies that will be 
used in an agroterrorism event. According to HSPD-5, the National 
Incident Management System, released in March 2004, is intended to 
provide a consistent nationwide approach for federal, state, and local 
governments to work effectively and efficiently together to prepare 
for, respond to, and recover from domestic incidents, regardless of 
cause, size, and complexity. The National Incident Management System is 
a management framework rather than a plan. It is intended to ensure 
coordinated responses to disasters and terrorist attacks by outlining 
common standards for preparedness training, exercises, and 
certification. A key component of the National Incident Management 
System is the Incident Command System, which is designed to coordinate 
the communications, personnel, and procedures of different agencies and 
levels of government within a common organizational structure during an 
emergency. The Incident Command System, which was initially developed 
by the USDA Forest Service and the state of California to help fight 
forest fires, has already been adopted by a number of agencies and 
state governments. According to USDA and state officials, the Incident 
Command System has already been used in two natural animal disease 
outbreaks--an outbreak of low-pathogenic avian influenza among turkeys 
in Virginia and an exotic Newcastle disease outbreak among chickens in 
California.

Test Exercises: 

Since 2001, exercises have simulated animal and plant disease outbreaks 
and have tested aspects of the new National Incident Management System 
protocols and the latest federal and state emergency response plans. 
These exercises are in line with HSPD-9's goal of ensuring that the 
combined federal, state, and local response capabilities are adequate 
to respond quickly and effectively to a terrorist attack. For example, 
in July 2004, Kansas State University sponsored "Exercise High Plains 
Guardian," a 2-day exercise to test the ability of federal and state 
military and civilian first responders to cooperate in responding to an 
outbreak of FMD. The scenario addressed quarantines, highway closings, 
elapsed time waiting for federal lab results to confirm the suspicions 
of state veterinarians, and, after positive confirmation, massive 
euthanizing and carcass disposal efforts. As a result of these 
exercises, federal, state, and industry officials told us that in 
general, the exercises have been useful in allowing players to better 
understand their roles and responsibilities in a real-life event, 
uncover shortfalls they had not necessarily foreseen in planning, and 
test solutions. For example, the 2002 FMD exercise "Crimson Sky" made 
it clear that USDA would be the lead federal department in providing 
policy and direction for detecting, controlling, and eradicating an 
animal disease outbreak. At the same time, the exercise indicated the 
importance of interdependence between federal, state, and industry 
stakeholders in carrying out emergency management and logistical 
response functions. Furthermore, the exercise raised key issues 
concerning information-sharing between these players and the public, 
stopping and resuming movement of animals, mobilizing federal 
resources, indemnity, vaccination of herds, and decontamination policy.

Vulnerability Assessments: 

FDA's initial vulnerability assessment utilized an analytical framework 
called Operational Risk Management that considered both the severity of 
the public health impact and the likelihood of such an event taking 
place. FDA incorporated threat information received from the 
intelligence community. To validate the findings, FDA contracted with 
the Institute of Food Technologists to conduct a review of the initial 
assessment and provide a critique of its application to food security. 
This review validated FDA's vulnerability assessment and provided 
additional information on the public health consequences of a range of 
scenarios involving various products, agents, and processes. FDA also 
contracted with Battelle Memorial Institute to conduct a "Food and 
Cosmetics, Chemical, Biological, and Radiological Threat Assessment." 
This assessment provided another decision-making tool and validated 
previous findings.

FDA updated and refined these assessments using a process developed by 
DOD for use in assessing the vulnerabilities of military targets. This 
assessment tool is known as "CARVER + Shock" and takes into 
consideration information such as accessibility, vulnerability, and 
shock (the shock value of an attack on a target due to the heinous 
nature of terrorist events).[Footnote 97] FDA plans to use the results 
of these updated assessments to develop technology interventions and 
countermeasures, identify research needs, and provide guidance to the 
private sector. Similarly, USDA is using the CARVER + Shock tool for 
assessing vulnerabilities in USDA-regulated products, based on subject 
matter experts and intelligence information. USDA was still developing 
the assessment at the time of our review.

Interagency Working Groups: 

In addition to the Government Coordinating Council and the Food and 
Agriculture Sector Council, federal agencies have established a number 
of interagency working groups. One such interagency working group 
composed of DHS, USDA, and CDC, is overseeing the development of a 
national disease surveillance system. This system, when established, 
will allow DHS to incorporate information on disease outbreaks from 
other agencies to determine whether an outbreak is natural or 
intentional. USDA, with support from DHS and EPA, is leading another 
working group that is preparing a plant disease recovery system that is 
intended to allow U.S. crop production to quickly recover from an 
attack. A final example of one of the interagency working groups is one 
led by EPA and supported by USDA, HHS, DHS, and DOD that has laid out 
interagency roles in supporting state and local governments in 
decontamination and disposal of infected plants and diseased animals 
following a major disease outbreak.

Research Efforts: 

DHS, USDA, and other agencies are funding research to protect 
agriculture. Of note, DHS has established two Centers of Excellence 
that, along with partner institutions, will oversee research to protect 
agriculture and the food supply. DHS is providing $15 million in 
funding to the University of Minnesota to oversee research into post- 
harvest food protection and $18 million to Texas A&M University to 
oversee research into diseases that affect food animals. This funding 
is for a 3-year period of time. For example, the Center of Excellence 
at Texas A&M will support efforts to model the outbreak of FMD, which 
will allow responders to develop accurate plans to counter an outbreak. 
The center will also support research into the development of real-time 
diagnostic equipment and vaccines against foreign animal and zoonotic 
diseases. Furthermore, the center will develop training curricula for 
first responders, industry officials, and production workers to 
increase response capability and awareness of possible threats. USDA is 
also funding efforts to increase agricultural security through the ARS, 
the research arm of USDA, and the Cooperative State Research Education 
and Extension Service, which supports research at universities and 
other institutions. USDA funding supported research at facilities such 
as the National Agricultural Biosecurity Center at Kansas State 
University, which will conduct projects including the evaluation of 
contaminated carcass disposal efforts, assessments of animal and plant 
disease test exercises, and the analysis of pathways by which foreign 
animal and plant disease can enter the United States. Finally, other 
agencies are supporting research into agricultural security. For 
example, CDC provided $1 million per year to Iowa State University to 
fund a center for food security and public health. This center will 
support efforts such as "train the trainer" programs to educate 
veterinarians in foreign animal diseases.

National Animal Health Emergency Management System: 

USDA's National Animal Health Emergency Management System incorporates 
a nationwide network of state and federal personnel in each state, a 
National Animal Health Laboratory Network, and Area Emergency 
Coordinators operating within the National Response Plan and the 
National Incident Management System. The system also includes a 
steering committee consisting of representatives of the animal health 
community and other stakeholders that provides a means of communication 
and coordination on issues of emergency management and response. The 
central principles of the National Animal Health Emergency Management 
System are provided in a single set of written guidelines that 
consolidate strategy, operations, facility management, and 
administrative procedures.

[End of section]

Appendix VI: Comments from the U.S. Department of Agriculture: 

USDA:

United States Department of Agriculture:
Animal and Plant Health Inspection Service:
Marketing and Regulatory Programs:

Mr. Robert A. Robinson, Managing Director: 
Natural Resources and Environment:
United States Government Accountability Office: 
Washington, DC 20548:

Dear Mr. Robinson:

Washington, DC 20250:

The U.S. Department of Agriculture (USDA) has reviewed the Government 
Accountability Office's Draft Report, "Homeland Security: Much is Being 
Done to Protect Agriculture from a Terrorist Attack, but Important 
Challenges Remain" (GAO 05-214). We found that the report provided a 
number of insightful and appropriate recommendations. We appreciate 
this opportunity to comment on your findings.

Rapid Diagnostic Testing:

The current process and procedures for investigating a suspected animal 
health event include several layers of precautionary actions. These 
actions are embedded in Animal and Plant Health Inspection Service 
(APHIS), Veterinary Services (VS) policies and requirements to protect 
the industry and minimize losses due to international and interstate 
trade restrictions.

The first precaution concerns VS "front lines" defense. When a 
veterinary foreign animal disease diagnostician (FADD) is sent to a 
premises to investigate a situation, that person has authority from the 
State to act immediately upon his/her findings. If the FADD suspects 
that a foreign animal disease (FAD) is present in the livestock on the 
premises, a State hold order or quarantine is placed on all movement of 
livestock and the producer is required to provide additional 
information on his/her overall operation production system. These 
actions are necessary to prevent movement of the disease agent through 
movement off the premises of livestock, feed, or other materials and 
support immediate biosecurity and containment of the disease agent.

In addition, VS works with its Federal and State counterparts to 
minimize the time from when an FAD is suspected to the point of disease 
confirmation through laboratory testing. Within this system, the 
disease is immediately contained and thus, the response at the local 
level is progressing while the samples are in route to the laboratory 
for confirmatory testing. Employing methods of rapid assay detection 
may be useful for confirming suspicions but would be inadequate for 
release of hold orders or quarantines and would not affect control 
strategies already being employed.

The National Veterinary Services Laboratories (NVSL), which includes 
the Foreign Animal Disease Diagnostic Laboratory (FADDL), is officially 
responsible for testing and confirming foreign animal disease. Those 
labs have the expertise and resources to make informed diagnoses. 
Furthermore, USDA performs such confirmatory testing to eliminate the 
possibility of a false positive, which could have serious repercussions 
on producers and the economy. During a large-scale animal health event 
covering multiple locations across several States, VS does deploy rapid 
disease diagnostic tools directly to the affected site to efficiently 
identify infected livestock.

For example, in two recent outbreaks, exotic Newcastle disease (END) 
samples were rapidly tested by real time PCR in California's San 
Bernardino Laboratory, and avian influenza (AI) samples were tested in 
Harrisonburg, Virginia. APHIS relied on its network of local 
laboratories in these cases; because these laboratories were located 
closer to the outbreak, shipping samples there saved valuable 
diagnostic time. NVSL continued to test samples during both outbreaks, 
but the bulk of the rapid tests (PCR for AI and END, and DirectigenR 
for Al) were performed locally. Even if rapid pen-side tests were 
developed, validated, and used by FADDs to test for FAD suspicious 
animals on routine investigations (before an outbreak was confirmed), 
confirmatory testing would still be necessary as these tests are 
designed to be sensitive and not specific. This would occur for several 
reasons including economics, virus isolation and typing, and trade 
relations. USDA believes that caution should be used in spending public 
funds and that the particular virus and strain or type of virus must be 
known before expending resources. Trading partners including other 
States will impose restrictions on the infected areas depending on the 
type of virus or organism present.

The report states that "USDA developed state-of-the-art, rapid 
diagnostic tools to detect FMD, classical swine fever, African swine 
fever, Rinderpest, avian influenza, and Newcastle disease... designed 
to yield results in less than an hour and ... intended to be used 
outside of specialized laboratories at the site of an outbreak." While 
proof-of-concept tools have been developed, it is important to note 
that these tools have not been validated to the extent necessary to be 
used to identify and confirm an FAD. Before a definitive diagnosis is 
made, care must be taken to rule out diseases with similar clinical 
signs or those with conserved genomic or protein sequences that might 
result in a false-positive result. Therefore, initial diagnosis must be 
confirmed using well-validated test procedures and must be interpreted 
by trained and experienced diagnosticians, especially when there are 
enormous economic and trade consequences to the results.

Then, once the initial diagnosis of an infectious FAD is confirmed, 
there may be opportunities to use validated rapid diagnostic tools to 
evaluate herd health either at the facility (farm) or at a near-by 
laboratory. For any highly-infectious FAD, it may be unrealistic to 
assume that any tool would be used to determine that some animals in a 
herd could be diagnosed as infected and others spared if the results 
were negative.

No tool is sensitive enough to detect all exposed animals prior to the 
replication of an infectious agent in an animal; therefore, in an 
outbreak, once the infectious agent is detected in a herd, the entire 
herd is known to be exposed. Continuous repeat testing of individual 
animals is a poor use of resources for controlling outbreaks. In 
addition, the report suggests that use of the rapid diagnostic tools 
would help identify the index case "definitively in less than an hour." 
It is unlikely that the rapid diagnostic tools would be used to test 
animals with no known risk factors, no clinical signs, and no known 
exposure to FAD agents. Furthermore, current rapid diagnostic tools 
primarily utilize nucleic- acid amplification and detection methods. VS 
continues to explore newer technologies (such as chip technologies) 
that could have even greater potential for improving rapid diagnostic 
capabilities.

Additionally, the report's assumption that an outbreak can be 
effectively countered by vaccine use is misleading. There are a limited 
number of diseases that can be "treated" by using vaccines during an 
outbreak. Vaccines may have some use in limiting disease spread when 
they are used in areas adjacent to the outbreak or in populations 
likely to become exposed or when used to decrease shedding of an agent 
from infected animals. But even then, most vaccines will not prevent 
infection (since vaccines are based on an immune response, it can take 
approximately 10 days for maximum efficacy) and can hinder surveillance 
during an outbreak. While APHIS will continue its efforts to develop 
the National Veterinary Stockpile (NVS), the report incorrectly implies 
that having a stockpile of ready-to-use vaccines translates to the 
quick control of any outbreak. Also, since vaccines are specific to 
variations of strains and have a shelf-life of approximately 18 months, 
it would not be cost-effective to have a continuous resupply of every 
possible permutation of each disease of concern. See below for more 
information on the Stockpile strategy.

In the case of foot-and-mouth disease (FMD), having vaccine stocks 
available in 24 hours is likely prudent; however, as the report also 
points out, the vaccine use decision tree is complex. While APHIS can 
explore the possibility of designing a more rapid decision making 
process, the report does not mention the amount of time it would take 
to select, deploy, equip, and direct vaccination crews to administer 
vaccine in a manner that would be advantageous to disease eradication. 
In fact, hastily applied vaccination programs could prove detrimental. 
For example, the "Eradication of Exotic Newcastle Disease in Southern 
California 1971-74" report concludes "in the massive vaccination 
program, it also appeared that increased activity and traffic of 
vaccinators among the poultry ranches contributed to the disease's 
rapid spread." An ill-conceived or mismanaged FMD vaccination program 
could presumably be equally damaging in that by encouraging 
vaccination, FMD virus could spread more easily from farm to farm. 
Before a full scale vaccination program could be effected, it is likely 
that several days or more might pass.

One area not addressed in the above section of the report is the need 
to develop marker vaccines. Since the ability to differentiate 
vaccinates from animals infected with live agents has a large impact on 
trade, a discussion of the value of marker vaccines to be used for at- 
risk animals is needed. Marker vaccines would provide the ability to 
differentiate vaccinated animals from infected ones. Such vaccines may 
be used more strategically in control and eradication efforts and to 
facilitate movement of animals.

National Veterinary Stockpile:

USDA will use the NVS to consider options to cut some of the time delay 
for obtaining finished final "ready-to-use" vaccine product. USDA's 
goal is for the NVS to be one component of an overall response planning 
and recovery effort to provide the best possible protection against an 
attack on our agriculture and food system. This goal will be 
accomplished through the NVS Steering Committee which serves as the 
recommending body that determines what is contained in the NVS (and 
what constitutes sufficient amounts of which products and appropriate 
time for their deployment) as stipulated in the Response Planning and 
Recovery Section of HSPD-9: "...animal vaccine, antiviral, or 
therapeutic products to appropriately respond to the most damaging 
animal diseases affecting human health and the economy and that will be 
capable of deployment within 24 hours of an outbreak. The NVS will 
leverage where appropriate the mechanisms and infrastructure that have 
been developed for the management, storage, and distribution of the 
Strategic National Stockpile."

The mission of the NVS Steering Committee is to ensure that decisions 
regarding the composition, inventory, storage, deployment, use, and 
staffing of the NVS are based on the most current threat assessments, 
the most rigorous science available, the best predictive modeling 
possible, and the best expert advice available.

The NVS Steering Committee is chaired by VS' Associate Deputy 
Administrator for Emergency Management and Diagnostics. The Steering 
Committee is composed of voting members from these Departments and 
Agencies (USDA, Department of Homeland Security, the Environmental 
Protection Agency, and the Department of Health and Human Services, 
Centers for Disease Control). The Steering Committee also has voting 
representation from the U.S. Food and Drug Administration (FDA) which 
has jurisdiction over products which may be contained in the NVS, and 
from the Department of Defense (DOD), which has numerous experts on 
logistical issues of managing and deploying the NVS to mitigate damage 
from biological, chemical, nuclear, and explosive weapons.

Additional non-voting ex-officio representatives from CDC, FDA, DOD or 
other agencies may attend meetings of the Committee to offer 
information, observations, and comments. Non-voting ex-officio 
representatives from the Armed Forces Medical Intelligence Center, the 
Central Intelligence Agency, and the Federal Bureau of Investigation 
may be invited to provide current assessments of terrorist risks that 
may affect the composition of the NVS. There will also be a non-voting 
liaison representative from the National Institutes of Health for the 
Bioshield initiative and Lawrence Livermore Biodefense Knowledge 
Center. Membership on the Committee may be expanded, as deemed 
necessary for the Committee to effectively carry out its functions, by 
VS' Deputy Administrator. All members of the Committee will need to 
maintain a security clearance at the Secret Level or greater. This 
Steering Committee was formed in late 2004.

Veterinary Accreditation and FAD Training:

The information in the section on veterinary training should be 
clarified. The document incorrectly assumes that veterinary students 
who do not receive a specific course on FADs receive no training on the 
subject at all. Moreover, the quotation from the Wenzel study is 
misleading. All relevant disease information is covered in the 
veterinary curriculum; however, this information is not presented in 
one FAD course. All students must take instruction in infectious 
diseases and in pathology (during which instruction, FADs are covered). 
Additionally, each year since 1990, APHIS has run the Smith-Kilborne 
Program on foreign animal diseases offered to one student in each U.S. 
veterinary school. Each participant is expected to present information 
from the course:

to his or her classmates. Furthermore, APHIS has worked to develop web- 
and CD-ROM-based training, and worked with veterinary schools on 
curriculum development.

The requirement that an accredited veterinarian is licensed ensures 
that personnel have received this basic training. USDA is working to 
update the Veterinary Accreditation system to emphasize continuing 
education. APHIS is developing an information system to streamline the 
accreditation of veterinarians, which will allow them to apply and 
maintain accreditation as well as receive credit for FAD and emergency 
response training.

In fact, USDA already has a cadre of certified private veterinary 
practitioners who partner with APHIS to report any suspected FAD cases 
to Federal officials. These surveillance efforts are further augmented 
by the work of 450 specially trained animal disease diagnosticians from 
State, Federal, and military ranks who actively search for FMD and 
other FADs across the country. USDA continues to train an additional 
100 FADDs annually. These FADDs respond to calls from the general 
public, private practitioners, and animal disease diagnostics 
laboratories to evaluate any disease recognized as outside the norm for 
any reason. However, USDA realizes that additional training is needed. 
Specifically, APHIS is seeking to strengthen its presence in veterinary 
colleges to provide information on various aspects of regulatory 
medicine. APHIS is also working to increase the visibility of public 
practice careers making veterinary students and veterinarians aware of 
public service career potential. These efforts will increase the number 
of veterinarians entering public service.

National Animal Health Laboratory Network:

USDA will integrate information from the laboratory networks by mid- 
2005 (though the laboratories themselves will not be integrated by that 
time). USDA leads the development of a Memorandum of Agreement (MOA) 
for an Integrated Consortium of Laboratory Networks (ICLN) which was 
drafted in late 2004. USDA, Departments of Homeland Security, State, 
Defense, Justice, Interior, Energy and Human Health Services, and the 
Environmental Protection Agency are parties to the agreement.

The MOA provides a framework for the Federal government to work 
collaboratively to provide timely, high quality, and interpretable 
results for early detection and effective consequence management of 
acts of terrorism and other events requiring an integrated laboratory 
response. The ICLN will provide surge capacity capabilities for all 
hazard incidents that overwhelm existing laboratory systems within 
individual Departments.

Once again, I appreciate the opportunity to offer comments on the 
report. The report was informative and thorough. I hope that our 
observations prove helpful.

Sincerely,

Signed by: 

W. Ron DeHaven: 
Administrator: 
Animal and Plant Health Inspection Service: 

The following are GAO's comments on the U.S. Department of 
Agriculture's letter dated February 23, 2005.

GAO Comments: 

1. Regarding USDA's comments about the use of rapid diagnostic tools at 
the site of an outbreak, our report acknowledges that USDA has already 
utilized these tools for the control of exotic Newcastle disease and 
avian influenza, but notes that USDA has only done so in a laboratory 
setting. The report also acknowledged USDA's concern for using this 
technology at the site of an outbreak. For example, we noted that rapid 
diagnostic tools still need to be validated for many diseases, 
including FMD. Furthermore, the report acknowledges USDA's concern that 
samples need to be sent to USDA's reference laboratories for final 
confirmation to determine the disease subtype, which must be known to 
deploy the correct type of vaccine. However, we continue to believe 
that use of these tools at the site of an outbreak would help reduce 
the impact of a terrorist attack because the tools would allow for a 
more rapid diagnosis so that informed control measures could be 
implemented as quickly as possible, and they would also permit the 
monitoring of nearby herds before symptoms appeared so that only 
infected herds would have to be killed. We understand that it would not 
be appropriate or cost-effective to test all animals within a herd for 
any highly infectious foreign animal disease because in all likelihood, 
if one tests positive, the other animals in that herd would already be 
infected. Also, as noted by state officials, the use of these tools 
would help prevent laboratories from becoming overwhelmed with test 
samples in the event of a terrorist attack involving the introduction 
of diseases at multiple locations.

2. Regarding USDA's comments about the use of vaccines to control an 
outbreak, we acknowledge that using vaccines to control an outbreak has 
some limitations; however, as our report states, a recent USDA test 
exercise of an intentional introduction of FMD in multiple locations 
suggests that the current "stamping out approach" would have 
catastrophic results. Also, in February 2005, the National Audit Office 
in the United Kingdom reported that based on experience from the 2001 
FMD outbreak in the United Kingdom, the ability to vaccinate, in 
conjunction with culling, may be necessary to contain an FMD outbreak. 
The report further states that the government in the United Kingdom has 
substantially increased stocks of vaccines for FMD in order to better 
contain the spread of FMD should another outbreak occur. Furthermore, 
USDA's draft response plan for an outbreak of foot and mouth disease or 
other highly contagious animal disease notes that vaccines may be used 
strategically to create barriers between infected zones and disease- 
free zones. We have added this information to the report.

Furthermore, our report does not imply that it is cost effective to 
maintain a supply of vaccines for every possible permutation of each 
disease of concern. In fact, the report clearly states that it is 
unlikely that vaccines will ever be developed for all strains of 
diseases and the report also notes that vaccines should be developed 
for those of primary concern to USDA. We do not state that vaccines are 
necessary for all foreign animal diseases. We acknowledge, however, 
that our report did not address the need to develop marker vaccines, 
and we have modified the report to reflect this need. Finally, in 
response to USDA's comment about simplifying the decision-making 
process on vaccine use, we have added language to the report to clarify 
USDA's position.

3. We modified our report to state that while all U.S. veterinary 
schools offer information about foreign animal diseases, only about 26 
percent of the nation's veterinary graduates have taken a course 
specifically dedicated to foreign animal diseases. We also revised the 
report to note that, according to USDA officials, all veterinary 
students must take instruction in infectious diseases and pathology 
which, according to these officials, includes foreign animal diseases.

In addition, we modified the report to state that USDA officials 
believe that requiring accredited veterinarians to be licensed ensures 
that they receive basic training in foreign animal diseases. 
Furthermore, we note that there are a small number of personnel trained 
specifically in the diagnosis of foreign animal diseases.

Finally, we modified the report to state that USDA officials told us 
that new efforts are being made to strengthen APHIS' role in colleges 
of veterinary medicine to provide information on various aspects of 
regulatory medicine and that USDA intends to increase the number of 
veterinarians entering public service by working to increase the 
veterinary student awareness of potential careers in public service.

4. We modified our report to include a statement about USDA's 
Memorandum of Agreement.

[End of section]

Appendix VII: Comments from the Department of Homeland Security: 

U.S. Department of Homeland Security: 
Washington, DC 20528:

February 14, 2005:

Mr. Robert A. Robinson:
Managing Director, Natural Resources and Environment: 
U.S. Government Accountability Office:
Washington, DC 20548:

Re: Draft Report GAO-05-214, Homeland Security: Much is Being Done to 
Protect Agriculture from Terrorist Attack, but Important Challenges 
Remain:

Dear Mr. Robinson:

Thank you for the opportunity to review and comment on the subject 
draft report. We are providing general comments for your use in 
preparing the final report and have submitted technical comments under 
separate cover.

The draft report indicates that there has been a decline in agriculture 
inspections at ports of entry. In fiscal year 2002, there were 40.9 
million agricultural inspections at ports of entry. In fiscal year 
2003, as the agriculture inspection mission was transitioning to the 
Department of Homeland Security (DHS), 35.0 million inspections were 
performed. In fiscal year 2004, there were 37.5 million agricultural 
inspections. In June of 2003, the U.S. Department of Agriculture (USDA) 
transferred 1,507 agriculture inspectors to DHS; however, by October 
2004, the number of inspectors had decreased to 1,452. Despite an 
initial drop in the volume of inspections during this year of 
transition, total inspections increased in 2004 even as the number of 
inspectors was decreasing.

There are developments currently being undertaken by DHS that will 
impact agriculture inspections. Among these is the development of the 
first agroterrorism rule set for the Automated Targeting System (ATS). 
This rule set will be used by agriculture specialists stationed at 
Advanced Targeting Units (ATU). The agriculture specialists are 
receiving training in ATS and risk management skills to focus on high- 
risk agricultural cargo. This includes the development of specific 
selectivity criteria for the prevention of foreign animal disease in 
commercial cargo.

There are also efforts underway to hire approximately 500 agriculture 
specialists. The combination of additional personnel with specialized 
knowledge in the biological sciences together with advanced targeting 
systems and risk management will produce a more efficient inspection 
process.

The draft report also references a lack of coordination of research 
efforts among DHS and other agencies. However, since the summer of 
2003, DHS's Science and Technology Directorate has worked with USDA's 
Agricultural Research Service (ARS) and Animal Plant Health Inspection 
Service (APHIS) to develop and coordinate "A Joint Strategy for Foreign 
Animal Disease Research and Diagnostic Programs" (including assays and 
diagnostics, and vaccines and therapeutics), with an initial focus on 
foot-and-mouth disease. A report summarizing this strategy was 
submitted in January 2005 in response to a request by the U.S. House of 
Representatives Appropriations Subcommittee for Homeland Security.

In addition, a Board of Directors has been chartered to provide an 
inter-agency forum for coordination of use of the Plum Island Animal 
Disease Center (PIADC) by representatives from DHS, USDA, and other 
agencies as appropriate. This will allow both DHS and USDA to 
efficiently utilize the unique capabilities at PIADC for the 
accomplishment of their respective mission directed requirements. Also, 
a charter is being drafted for a Joint Federal Working Group on 
Research and Diagnostic Development for Foreign Animal and Zoonotic 
Diseases that will continue the coordination of research efforts 
against agroterrorism. Further, the DHS National Center for Foreign 
Animal and Zoonotic Diseases, led by Texas A&M University, is working 
closely with PIADC to coordinate their respective efforts on research 
and development on foot and mouth disease, and is in dialogue with 
researchers in the other respective fields of their efforts, e.g., 
avian influenza, to prevent any overlap.

GAO also indicates that "...there is no overall departmental 
coordination of policy and budget issues concerning agricultural and 
food security within DHS and with other departments and agencies" (page 
40). However, since HSPD-9 was issued in February 2004, there have been 
extensive interactions between program staff across DHS, and with other 
federal departments and agencies. Successful realization of the 
implementation of HSPD-9 now requires engaging senior policy and 
decision makers across DHS organizational elements, along with other 
federal departments and agencies, to resolve necessary policy, mission, 
and budget related issues.

GAO states that DHS may not be providing sufficient guidance to the 
states on using the Homeland Security Grant Program (HSGP) to obtain 
federal emergency preparedness assistance to support the agriculture 
sector. However, it is important to note that the agricultural 
component was an optional part of the FY 2003 Assessment and Strategy 
process. As such, the Department did not give explicit guidance on how 
to use federal financial assistance towards agroterrorism when it may 
not be applicable in all cases. However, Fiscal Year 2004 and Fiscal 
Year 2005 program guidance clearly notes that states may expend funds 
towards the prevention, response and mitigation of agroterrorism 
incidents through the purchase of equipment, training, exercises or 
planning. However, any funds expended must be in accordance with the 
goals and objectives outlined in the State or Urban Area Homeland 
Security Strategy. As noted, DHS gives the states maximum flexibility 
to determine the needs of their state and local entities; agricultural 
issues may not necessarily be a concern for them. In the FY 2005 
program guidance, equipment, training or exercises related to 
agroterrorism is only noted as an allowable item in the State Homeland 
Security Program (SHSP) and the Urban Areas Security Initiative (UASI). 
These two programs are the most broad-based and well-funded sections of 
the overall HSGP. The other four programs do not allow for 
agroterrorism because they are much more focused program areas. For 
example, the Metropolitan Medical Response System (MMRS) grant may only 
be spent for ongoing activities related to MMRS, and the Emergency 
Management Performance Grant (EMPG) funds are only to be used for all-
hazards, emergency management costs.

Finally, with respect to the report's recommendations, the Department 
generally concurs with the recommendations. Various corrective actions 
have already taken place to implement at least two of these 
recommendations and they are articulated below:

Recommendation: The Secretaries of Agriculture and Homeland Security 
work together to identify the reasons for declining agricultural 
inspections and to identify potential areas for improvement.

USDA and DHS have entered into a Joint Agency Quality Assurance Plan 
(JAQAP) and have agreed to conduct joint quality assurance reviews of 
ports of entry (POE). This joint program is intended to study the 
performance of the agricultural mission under DHS and identify the best 
business practices of individual ports. If the JAQAP does a port review 
and finds a decline in inspections, the reasons for a port's declining 
inspections will be explored and actions to improve the port's 
performance will be recommended. This program is part of the overall 
agreement between the two agencies. The vision statement of the Joint 
Quality Assurance Plan reads as follows:

JAQAP will provide suggestions for preventing terrorists and terrorist 
weapons in the form of agroterrorism from entering the United States. 
JAQAP will assist Customs and Border Protection to safeguard 
agricultural and natural resources from the intentional (agroterrorism) 
or unintentional introductions of animal and plant pests and disease 
into the United States.

The joint teams' first review was in December 2004. At least four port 
reviews are expected to take place during the next calendar year. These 
cooperative efforts will identify weaknesses in the port's agricultural 
operations and suggest areas and ways to address those areas of concern.

The Department also plans to increase hiring of agriculture specialist 
and agriculture supervisors. In November 2004, DHS advertised 129 
government-wide agricultural specialist positions. These positions are 
presently being processed. In addition, DHS approved 14 training 
classes for new officers which began in the summer of 2004 and will 
continue through January 2006. It is estimated that these training 
classes will result in 720 new officers. As of February, 2005, 109 new 
agricultural specialists have passed New Officer Training (NOT) and are 
working at Ports of Entry.

In addition to new officers, DHS has identified the need to replace and 
increase the number of agricultural supervisors. The Department began 
issuing vacancy announcements for new agricultural supervisors during 
the week of February 7, 2005.

The added supervisors will enhance the DHS agricultural inspection 
infrastructure as the number of specialists and their workloads 
increase.

The Department also plans to improve agricultural targeting to make 
more interceptions of pests and diseases. The assignment of 
Agricultural Specialists to the Advance Targeting Units (ATU) will 
greatly enhance the ability of DHS to more effectively target 
passengers and commodities at all the POEs. "Smarter" targeting will 
increase the number of interceptions by focusing on the people and 
commodities of greater risk. A number of agricultural specialists have 
already received the ATS targeting training necessary to be part of an 
ATU team.

DHS has developed and delivered ATS training aimed solely at 
agricultural specialists. Eighteen agricultural specialists from 
various seaports successfully completed the agriculture specific 
training on February 10, 2005. An additional class of ATS for the 
agricultural specialists will be held in June 2005 for seaport based 
specialists. It is planned to have ATS training for agricultural 
specialists in air cargo and land border POEs completed by the end of 
FY 2005.

Recommendation: The Secretaries of Agriculture and Homeland Security 
streamline the flow of information between USDA and DHS agricultural 
inspectors, and expedite the integration of the two agencies' databases 
and information technology systems at the port level.

DHS is working with USDA to complete Appendix 8 of Article 8 of the 
Memorandum of Agreement (MOA) between USDA APHIS and DHS to .enhance 
communication. The relevant databases maintained by USDA APHIS are now 
available to all DHS agricultural specialists electronically. Initially 
there had been problems achieving connectivity between the two agencies 
but to date these problems have been resolved and DHS officers now have 
full access to the necessary databases.

As for USDA access, after extensive negotiations with USDA APHIS, DHS 
is now reviewing the final version of Article 8 of the MOA. This is the 
crucial article that solidifies the ability of USDA to gain access to 
relevant databases held by DHS. As agreed to in the draft Appendix 8, 
USDA has already identified those positions for which they are 
requesting access to DHS databases. This request is currently being 
processed. Additionally, USDA will soon be placing two employees at the 
National Targeting Center (NTC) to work with the DHS targeters.

The Department is also working to improve information sharing with 
USDA's Food Safety and Inspection Service (FSIS). DHS has gained access 
to the relevant database in FSIS. In turn, FSIS has now stationed two 
individuals at the NTC to assist with targeting meat and poultry 
commodities. DHS is continuing to work with FSIS to gain more access 
for FSIS personnel. In addition to these efforts, FSIS has developed, 
in conjunction with the NTC and the Office of Strategic Trade, rule 
sets for meat. The rule set is presently undergoing final adjustments 
and will be piloted shortly.

In conjunction with USDA, DHS is developing rule sets for agroterrorism 
targeting. The agencies have identified a plan of action for this 
targeting effort and established ownership of responsibilities for 
subsequent actions. USDA has agreed to form a working group to 
coordinate the risk assessment and rules refinement work. DHS is in the 
process of forming a corresponding work group.

In summary, DHS is in the process of implementing six corrective 
actions in response to the GAO's review addressing agroterrorism. These 
actions include: jointly identifying problem areas and solutions; 
increased hiring of personnel; improved automated targeting; and, 
increased information sharing between agencies. These actions are 
expected to be completed by January 2006.

We thank you again for the opportunity to provide comments on this 
draft report and look forward to working with you on future homeland 
security issues:

Sincerely,

Signed by: 

Steven J. Pecinovsky: 
Acting Director, Departmental GAO/OIG Liaison: 
Office of the Chief Financial Officer: 

The following are GAO's comments on the Department of Homeland 
Security's letter dated February 14, 2005.

GAO Comments: 

1. DHS provided minor modifications to the total number of agricultural 
inspectors transferred from USDA as well as the number of inspectors 
remaining as of October 2004. We have added a footnote to our report to 
address this change. DHS commented that following the transition of 
inspectors from USDA to DHS in mid-2003, the number of agricultural 
inspections increased. We agree, and our report clearly identifies this 
increase, but also states that between 2002 and 2004, the overall 
number of inspections declined.

2. At the time of our draft report, USDA noted that they were unaware 
of the full scope of research efforts supported by DHS, and DHS 
officials told us that there was no overall departmental coordination 
of policy and budget issues concerning agriculture security research. 
DHS now states that since the summer of 2003, the agency has been 
working with USDA's Agricultural Research Service and with the Animal 
and Plant Health Inspection Service to develop a joint strategy for 
foreign animal disease research and diagnostic programs, and that a 
report summarizing this strategy was submitted to the House of 
Representatives Appropriations Subcommittee for Homeland Security in 
January 2005. We have modified our report to reflect this comment. 
Regarding DHS's other comments about research at the Plum Island Animal 
Disease Center and at the National Center for Foreign Animal and 
Zoonotic Diseases at Texas A&M University, our report acknowledges 
these efforts so we made no further modifications.

3. We agree that, as DHS states, the fiscal year 2004 and 2005 grant 
program guidance notes that states may expend funds towards the 
prevention, response, and mitigation of agroterrorism incidents through 
the purchase of equipment, training, exercises or planning. However, as 
our report states, we believe that the guidance continues to provide 
limited emphasis on agriculture relative to other funding priorities. 
As a result, state governments, which have been accustomed to seek 
funding for traditional emergency disciplines such as law enforcement, 
may not be sufficiently informed about the availability of DHS grant 
funds to protect their agriculture industries.

[End of section]

Appendix VIII: Comments from the Department of Health and Human 
Services: 

DEPARTMENT OF HEALTH & HUMAN SERVICES: 
Office of Inspector General:
Washington, D.C. 20201:

FEB 17 2005:

Mr. Robert A. Robinson:
Managing Director, Natural Resources and Environment: 
U.S. Government Accountability Office:
Washington, DC 20548:

Dear Mr. Robinson:

Enclosed are the Department's comments on the U.S. Government 
Accountability Office's (GAO's) draft report entitled, "Homeland 
Security-Much Is Being Done to Protect Agriculture from a Terrorist 
Attack, but Important Challenges Remain" (GAO-05-214). The comments 
represent the tentative position of the Department and are subject to 
reevaluation when the final version of this report is received.

The Department provided several technical comments directly to your 
staff.

The Department appreciates the opportunity to comment on this draft 
report before its publication. 

Sincerely,

Signed by: 

Daniel R. Levinson: 
Acting Inspector General:

Enclosure:

The Office of Inspector General (OIG) is transmitting the Department's 
response to this draft report in our capacity as the Department's 
designated focal point and coordinator for U.S. Government 
Accountability Office reports. OIG has not conducted an independent 
assessment of these comments and therefore expresses no opinion on 
them. 

COMMENTS OF THE DEPARTMENT OF HEALTH AND HUMAN SERVICES FOR THE U.S. 
GOVERNMENT ACCOUNTABILITY OFFICE'S (GAO's) DRAFT REPORT ENTITLED 
"HOMELAND SECURITY-MUCH IS BEING DONE TO PROTECT AGRICULTURE FROM A 
TERRORIST ATTACK, BUT IMPORTANT CHALLENGES REMAIN" (GAO-05-214):

The Department of Health and Human Services (HHS) appreciates the 
opportunity to review and comment on GAO's draft report entitled 
"Homeland Security-Much is Being Done to Protect Agriculture from a 
Terrorist Attack, but Important Challenges Remain" (GAO-05-214).

Overall, HHS agrees with the recommendations in the draft report and 
welcomes the attention given to the implications of animal diseases.

The draft report frequently asserts that the costs and benefits of 
developing stockpiles of ready-to-use vaccines should be evaluated. The 
Centers for Disease Control and Prevention (CDC) suggests including 
information on the process required for U.S. Department of Agriculture 
licensure, such as the BL-3, B1-3 agriculture laboratory space that 
would be sufficient to conduct Good Laboratory Practice vaccine 
efficacy trials among statistically appropriate numbers of livestock- 
type animals. The shortage of sufficient space to conduct efficacy 
trials is a formidable barrier to vaccine development.

In response to GAO's recommendation that HHS and other agencies compile 
after-action reports and submit them to the Department of Homeland 
Security network under development, it should be noted that CDC has 
standardized after-action reporting procedures currently in place that 
are refined following events.  

[End of section]

Appendix IX: GAO Contacts and Staff Acknowledgments: 

GAO Contacts: 

Robert A. Robinson (202) 512-3841; 
Maria Cristina Gobin (202) 512-8418; 
Mary Denigan-Macauley (202) 512-8552: 

Acknowledgments: 

In addition to the persons named above, Josey Ballenger, Jill Ann Roth 
Edelson, and Steve Rossman made key contributions to this report. Other 
contributors included Kevin Bray, Karen Keegan, Amanda Kutz, Lynn 
Musser, Omari Norman, Cynthia Norris, and Claire van der Lee.

[End of section]

Related GAO Products: 

Drinking Water: Experts' Views on How Federal Funding Can Best Be Spent 
to Improve Security. 
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-04-1098T] 
Washington, D.C.: September 30, 2004.

Emerging Infectious Diseases: Review of State and Federal Disease 
Surveillance Efforts. 
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-04-877] 
Washington, D.C.: September 30, 2004.

Homeland Security: Observations on the National Strategies Related to 
Terrorism. 
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-04-1075T] 
Washington, D.C.: September 22, 2004.

9/11 Commission Report: Reorganization, Transformation, and Information 
Sharing. 
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-04-1033T] 
Washington, D.C: August 3, 2004.

Status of Key Recommendations GAO Has Made to DHS and Its Legacy 
Agencies. 
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-04-865R] 
Washington, D.C.: July 2, 2004.

Coast Guard: Key Management and Budget Challenges for Fiscal Year 2005 
and Beyond. 
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-04-636T] 
Washington, D.C.: April 7, 2004.

Homeland Security: Summary of Challenges Faced in Targeting Oceangoing 
Cargo Containers for Inspection. 
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-04-557T] 
Washington, D.C.: March 31, 2004.

Homeland Security: Risk Communication Principles May Assist in 
Refinement of the Homeland Security Advisory System. 
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-04-538T] 
Washington, D.C.: March 16, 2004.

Homeland Security: Preliminary Observations on Efforts to Target 
Security Inspections of Cargo Containers. 
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-04-325T] 
Washington, D.C.: December 16, 2003.

Bioterrorism: A Threat to Agriculture and the Food Supply. 
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-04-259T] 
Washington, D.C.: November 19, 2003.

Combating Bioterrorism: Actions Needed to Improve Security at Plum 
Island Animal Disease Center. 
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-03-847] 
Washington, D.C.: September 19, 2003.

Food-Processing Security: Voluntary Efforts Are Under Way, but Federal 
Agencies Cannot Fully Assess Their Implementation. 
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-03-342] Washington, 
D.C.: February 14, 2003.

Homeland Security: CDC's Oversight of the Select Agent Program. 
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-03-315R] 
Washington, D.C.: November 22, 2002.

(360436): 

FOOTNOTES

[1] These agricultural activities include such items as farming, food- 
processing, and transportation.

[2] See appendix II for a summary of experts' observations; many 
experts held similar views.

[3] U.S. Government Accountability Office, U.S. Agriculture: 
Vulnerability of Crops and Livestock to a Biological Attack, GAO/C- 
RCED-98-1 (Washington, D.C.: May 8, 1998).

[4] Farmers may be the first to recognize the presence of an animal 
disease through normal routine care and would then request a 
veterinarian--usually USDA-accredited--to diagnose the disease. 
Accredited veterinarians are supposed to recognize clinical signs and 
lesions of exotic animal diseases.

[5] FDA is responsible for ensuring the safety and security of certain 
farm products including fruits, vegetables, and milk.

[6] We also reviewed classified documents, but none of that information 
is included in this report.

[7] U.S. Government Accountability Office, Homeland Security: A Risk 
Management Approach Can Guide Preparedness Efforts, GAO-02-208T 
(Washington, D.C.: Oct. 31, 2001).

[8] See appendix IV illustrating the concentrated nature of production 
for other select animals and plants.

[9] The North American Foot and Mouth Disease Vaccine Bank located at 
Plum Island Animal Disease Center was developed in 1982 and is jointly 
owned by the United States, Canada, and Mexico.

[10] APHIS also has a Wildlife Services Program, which conducts 
surveillance and monitoring of wild animal populations that may 
potentially impact livestock by spreading disease. Wildlife Services 
employees have been especially trained to assist Veterinary Services 
personnel during animal health emergencies.

[11] The OIE is also known as the World Animal Health Organization.

[12] According to USDA officials, OIE now recognizes that countries may 
regionalize. This means that, in the past, when OIE evaluated the 
animal disease situation in a country intending to export animals 
and/or animal products, it judged the country as a whole. If an 
infectious disease existed somewhere within a country's borders, or if 
its presence was suspected, the whole country was considered infected. 
Today, a country may be able to trade if that country can demonstrate 
that the disease is regionalized. In light of this, USDA officials told 
us that they would remain flexible about how to handle the "stamping 
out process"; however, according to USDA's draft procedure manual for 
contagious animal diseases, all susceptible animals on infected farms 
and those within certain proximity would still be depopulated as 
quickly as possible to stop the spread of the disease.

[13] Homeland Security Act of 2002, Pub. L. No. 107-296, 116 Stat. 2135.

[14] In addition to receiving authority from the Homeland Security Act, 
DHS derives its authority to oversee planning, response, and recovery 
functions, through FEMA, from the Robert T. Stafford Disaster Relief 
and Emergency Assistance Act of 1974, Pub. L. No. 93-288, as amended.

[15] Through an interagency agreement, FEMA, working under the 
authority of the Secretary of Agriculture, can support federal, state, 
and local governments in agricultural emergencies.

[16] Although most of the inspectors from USDA's Plant Protection and 
Quarantine unit transferred to DHS, all of USDA's inspectors in its 
Veterinary Services unit remained in USDA.

[17] DHS Agreement Number BTS-03-0001.

[18] Though neither the Homeland Security Act of 2002 nor the 
Memorandum of Agreement between USDA and DHS define "conveyance," the 
term typically means ships, aircraft, vehicles, buses, and rail cars.

[19] The emergency preparedness grant programs administered by HHS, 
including those of CDC and FDA, were not transferred to DHS.

[20] The FY 2005 Homeland Security Grant Program combines six separate 
grant programs into one application. These programs are the State 
Homeland Security Program, the Law Enforcement Terrorism Prevention 
Program, the Citizen Corps Program, Emergency Management Performance 
Grants, the Metropolitan Medical Response System Program, and the Urban 
Areas Security Initiative.

[21] Any expenditure by state or local entities must be made in 
accordance with the state or urban area's homeland security strategy, 
which each state has submitted to DHS.

[22] Agencies from which functions were transferred include the 
Departments of Justice, Defense, and Energy.

[23] HSPD-9 calls for nationwide laboratory networks for food, 
veterinary, and plant health that integrate existing federal and state 
laboratory resources and are interconnected.

[24] Pub. L. No. 107-188, 116 Stat. 594.

[25] DHS released the interim National Infrastructure Protection Plan 
on February 9, 2005.

[26] The appendixes in the National Response Plan are referred to as 
Emergency Support Functions.

[27] Minnesota and Iowa are two of the nation's biggest soybean- 
producing states.

[28] In addition to FDA and the Food Safety and Inspection Service, 
other federal agencies playing a role in the development of the network 
are CDC, EPA, and the Department of Energy.

[29] Sudden oak death is a disease affecting oak and tan oak trees, 
which appeared in California nurseries in March 2004.

[30] Other official participants in the Government Coordinating Council 
include EPA, DOD, the Association of State and Territorial Health 
Officials, the National Association of State Departments of 
Agriculture, the National Association of County and City Health 
Officials, and the National Assembly of State Chief Livestock Health 
Officials. In addition, the council includes ex-officio non-voting 
participants that possess relevant expertise. Ex-officio members 
include the Associations of Food and Drug Officials, the Departments of 
Commerce, Interior, and Justice.

[31] USDA homeland security research is supported by ARS and the 
Cooperative State Research, Education and Extension Service, which 
awards grants to universities and other institutions to conduct 
research in agriculture.

[32] APHIS also created one National Wildlife Disease Coordinator 
position to coordinate state and federal surveillance of wildlife 
diseases.

[33] These coordinators also assist in administrating emergency 
management grants to states; develop communication and training to 
state and local entities; and serve as technical resources for states, 
industry, and other stakeholders.

[34] Wenzel, James G.W. "Assessment of Training for Veterinary 
Accreditation and Foreign Animal Disease Recognition at US Colleges and 
Schools of Veterinary Medicine," Auburn University. Contracted Research 
for USDA-APHIS-VS (2004).

[35] APHIS's Veterinary Services administers the National Veterinary 
Accreditation Program. This voluntary program certifies private 
veterinary practitioners to work cooperatively with federal 
veterinarians and state animal health officials. Producers that export 
animals rely on the expertise of accredited veterinarians to help 
ensure that exported animals will not introduce diseases into another 
state or country. Private practitioners were first used to perform 
regulatory work in 1907, when a large number of horses were exported to 
Canada. As there were inadequate numbers of federal veterinarians to 
meet these demands, the Canadian government agreed to accept health 
inspections and certifications performed by private practitioners 
qualified by the Bureau of Animal Industry (now APHIS). The services of 
practicing veterinarians were used again in 1917, when the Tuberculosis 
Eradication program was established.

[36] USDA officials told us that it has a cadre of certified private 
veterinary practitioners who partner with APHIS to report any suspected 
foreign animal disease cases to federal officials. These surveillance 
efforts are further augmented by the work of 450 specially trained 
foreign animal disease diagnosticians who actively search for FMD and 
other foreign animal diseases across the country. USDA continues to 
train 100 foreign animal disease diagnosticians annually.

[37] A USDA official told us that continuing education is a requirement 
of every state licensing process. All accredited veterinarians must be 
licensed by a state and therefore are required to have continuing 
education to maintain their licenses.

[38] To maintain accreditation status under the new standards, 
veterinarians will have to periodically complete supplemental education 
requirements. These supplemental training modules will be available on- 
line to the entire accredited veterinarian population. Through a 
cooperative agreement with Iowa State University, APHIS has already 
initiated development of 6 supplemental training modules for the new 
accreditation process. These modules focus heavily on the recognition 
of the clinical signs of many of the most prominent foreign animal 
diseases and on how to respond to a potential foreign animal disease 
outbreak. The new program will institute a 3-year renewal period for 
veterinary accreditation for all veterinarians. If documented 
supplemental training is not completed before the 3-year renewal period 
expires, the accreditation status of the veterinarian will be 
inactivated.

[39] The American Veterinary Medical Association reports that there are 
approximately 61,000 practicing veterinarians.

[40] The Association of American Veterinary Medical Colleges (AAVMC) 
defines public practice as federal, state (including state, public 
health, and extension veterinarians, as well as those who inspect 
meat), and industry. According to AAVMC, there are approximately 4,000 
additional veterinarians in academia, most of whom are engaged in 
research.

[41] During the early phase of foreign animal disease surveillance, 
samples will most likely be sent to NVSL in Ames, Iowa, or the Foreign 
Animal Disease Diagnostic Laboratory located on Plum Island, New York, 
depending on the disease agent. Once the disease agent in the outbreak 
has been confirmed and an emergency response effort has started, 
samples may be sent to local laboratories, including one of USDA's 
National Animal Health Laboratory Network laboratories.

[42] According to USDA officials, confirmatory testing is done for 
several reasons, including economics and trade relations. USDA 
officials told us they believe that caution should be used in spending 
public funds and that the particular virus and strain or type of virus 
must be known before expending resources. If FMD were officially 
confirmed in the United States, the international community would be 
notified and all exports of susceptible animals and animal products 
would temporarily cease until the scope of the outbreak could be 
determined. Trading partners would also impose restrictions.

[43] USDA officials told us that a tool is being developed for Rift 
Valley fever as well.

[44] While rapid diagnostic tools can diagnose the presence of FMD, 
they cannot determine the disease subtype, which must be known to 
deploy the correct type of FMD vaccine. Therefore, a sample of the 
suspect virus would still have to be flown to Plum Island Animal 
Disease Center, where its complete genetic sequence would be determined 
in order to identify the subtype.

[45] CDC and FDA officials told us they have not used rapid diagnostic 
tools outside of a laboratory setting. According to CDC officials, they 
are concerned about possible cross-contamination as well as the lack of 
an integrated plan among local, state, and federal officials for 
responding to reported results. However, resources are being devoted to 
support the ongoing evaluation of field detection products. FDA 
officials told us they are also concerned about cross-contamination as 
well as the sensitivity of reagents to temperature changes. In 
commenting on a draft of this report, FDA officials told us that a 
number of different types of rapid diagnostic tools are in use by FDA 
laboratories and others for the detection of pathogenic microorganisms, 
biologically derived toxins, and toxic chemicals. Real-time polymerase 
chain reactions and immunoassays are two examples of such tests; other 
technologies exist. FDA officials noted that while these can be useful 
outside a laboratory setting, these techniques generally have several 
requirements that have limited their field application. FDA officials 
also commented that in most instances, it is actually more time 
efficient to rapidly transport samples to one of a series of 
strategically located regional laboratories where all aspects of the 
analytical process can be completed. However, FDA officials also told 
us that resources are being devoted to support the ongoing evaluation 
of field detection products and the agency plans to use diagnostic 
tools in its mobile laboratories.

[46] According to USDA, the rapid diagnostic tools for these diseases 
have been scientifically validated. Tools for the detection of FMD, 
classical swine fever, and vesicular stomatitis virus are still 
undergoing validation at the time of our report. Once validated, the 
rapid diagnostic tools are to be deployed to select laboratories within 
the National Animal Health Laboratory Network in 2005.

[47] The mobile unit would be located just off the farm to eliminate 
contaminating the unit. Procedures would be the same as those for any 
official taking a sample from a farm suspected of having a highly 
contagious disease.

[48] Depending on the situation, the rapid diagnostic tools are set up 
in a tent near the sampling site or, if sampling is required at 
multiple sites, the tools are set up in a mobile unit and driven to 
each location.

[49] If an animal tests positive for a foreign animal disease such as 
FMD, current USDA procedures to contain the outbreak are to slaughter 
all susceptible animals within a 10-kilometer radius.

[50] Results could be reviewed over the Internet by experts in the 
laboratories, or the tests could be conducted by technical experts at 
the site of an outbreak.

[51] In addition, technicians who are sampling are typically supervised 
by individuals with clinical laboratory credentials and/or advanced 
degrees, according to DOD.

[52] Samples that test positive at the site are shipped back to DOD's 
reference laboratory for further analysis, but personnel in the field 
will make medical decisions based on these rapid diagnostic tools. For 
example, if anthrax is detected, then medicine would be distributed.

[53] See appendix III for a list of these diseases.

[54] We reported in 2002 that an outbreak of FMD could range up to $24 
billion in current dollars, depending, among other things, on the 
extent of the outbreak.

[55] The Department for Environment, Food and Rural Affairs. Foot and 
Mouth Disease: Applying the Lessons. Report by the Comptroller and 
Auditor General (HC 184 session 2004-2005). February 2, 2005.

[56] This participation includes senior representatives from CDC's 
Strategic National Stockpile. Their participation also supports HSPD-9.

[57] CDC officials also noted that if testing indicates a vaccine is 
still efficacious, USDA could potentially extend the shelf life of the 
vaccine.

[58] For those diseases where there is no market for a vaccine, the 
vaccine would simply have to be disposed and restocked.

[59] According to USDA officials, the extent to which the vaccine could 
be applied would be limited to the number of available trained 
personnel, and these personnel are limited.

[60] USDA officials noted that there is a need to develop "marker" 
vaccines to differentiate vaccinated animals from those infected with 
live agents, as this would have a large impact on trade.

[61] DHS and USDA-APHIS-PPQ inspect imports of plants, (dead) animal 
products, seeds, farm instruments, and other items of agricultural 
interest, including packing materials that could contain pests. USDA- 
APHIS' Veterinary Services retains sole authority over inspections of 
live animals.

[62] See the Congressional Research Service's Border Security: 
Inspections Practices, Policies, and Issues, May 26, 2004, and 
Agroterrorism: Threats and Preparedness, August 13, 2004, both of which 
are available at http://www.crs.gov; and America at Risk: Closing the 
Security Gap by the Democratic Members of the House Select Committee on 
Homeland Security, February 2004, available at 
http://www.house.gov/hsc/democrats.

[63] USDA has retained responsibility for maintaining agricultural 
inspections data, including data on interceptions. The agency provided 
us with the total number of agricultural inspections and interceptions 
for fiscal years 2002 through 2004 as of December 22, 2004. These 
numbers came from USDA-APHIS-PPQ's Work Accomplishment Data System 
(WADS), the primary database both USDA and DHS agricultural inspectors 
use to record inspections of plant and animal products and 
interceptions of prohibited agricultural items, and the Port 
Information Network (PIN) 309 database, which USDA uses to track 
interceptions of reportable insects and pests. These databases do not 
include inspections data from USDA-APHIS-Veterinary Services, which 
still maintains authority over inspections of live animals, nor does it 
include inspections of food items performed by USDA's Food Safety and 
Inspection Service or FDA. For a comprehensive review of the entire 
food and agricultural sector, those agencies' inspections would have to 
be included. We did not independently assess the reliability of the 
WADS data provided to us by USDA.

[64] USDA and DHS refer to the different types of ports of entry--land 
border crossings, airports, and maritime (sea) ports--as "pathways." 
Within those pathways, agricultural items can enter the United States 
through different means: ships, aircraft, vehicles, buses, rail cars, 
passenger and crew baggage, regulated cargo, miscellaneous cargo, 
pedestrians, and international mail.

[65] An inspection team that reviews the paperwork accompanying foreign 
cargo can decide to "hold" an item for further review, which may result 
in an inspection, fumigation, or other appropriate action.

[66] USDA's Economic Research Service reports that the total value of 
agricultural imports was $41.0 billion in fiscal year 2002, $45.7 
billion in fiscal year 2003, and $51.5 billion in fiscal year 2004. 
Meanwhile, USDA's inspections data show that international air 
passenger and crew arrivals at U.S. airports increased from 64.9 
million to 67.1 million to 72.6 million over the same time frame.

[67] Under the memorandum of agreement between the two agencies, USDA 
is responsible for providing risk analysis guidance to DHS, and DHS is 
responsible for targeting high-risk agricultural passenger and cargo 
shipments for inspections, using USDA data.

[68] During our audit, DHS officials told us USDA transferred 1,872 
full-time agricultural inspector positions, of which 355 were vacant in 
March 2003, including supervisors. However, in commenting on a draft of 
this report, DHS officials stated that USDA transferred 1,507 
agricultural inspectors to DHS in June 2003 and that by October 2004 
the number of inspectors had decreased to 1,452, including supervisors.

[69] According to DHS officials, the personnel vacancies also include 
agricultural specialists assigned to K-9 units, resulting in fewer 
inspections of this nature. DHS officials told us that they are in the 
process of assessing K-9 needs and filling vacancies.

[70] At the time of our report, DHS and USDA officials told us they 
were drafting another memorandum of agreement between the two agencies 
on data and information-sharing. However, we have not seen this 
document and some officials told us it may not address the information- 
sharing issues we have raised concerning agriculture inspections.

[71] DHS refers to inspectors who transferred from the U.S. Customs 
Service and the Immigration and Naturalization Service as "legacy" 
customs and immigration officers. All DHS inspectors are cross-trained 
on immigration, customs, and agriculture laws, policies, and procedures 
in order to assist each other and make appropriate referrals to each 
other regarding specialized inspections.

[72] USDA is responsible for the supervision and development of 
educational support and systems to ensure that DHS employees receive 
the training necessary to carry out the USDA functions transferred to 
DHS, as specified in Article 4 of the memorandum of agreement between 
USDA and DHS.

[73] DHS officials told us that some ports of entry provide agriculture-
related information to customs and immigration inspectors. Although 
this training is not officially certified by DHS or USDA, the training 
does provide an overview to the inspectors of agriculture- related 
items and pests such as wood borers, "hitchhiker" pests such as snails, 
and prohibited packing material and contaminants. According to DHS, 
this unofficial training has led to some referrals by these legacy 
inspectors to DHS agricultural specialists and has resulted in some 
interceptions.

[74] Some recent, naturally occurring disease outbreaks since the 
transfer to DHS include sudden oak death, Sapote and Mexican fruit 
flies, exotic Newcastle disease, and karnal bunt.

[75] As a result of the outbreak of soybean rust in late 2004 in 
multiple southern states, USDA expects the 2005 crop to be infected and 
anticipates the need for emergency response personnel to control the 
disease.

[76] According to USDA's 2002 agriculture census, California has 
342,053 acres of citrus fruit, compared with #1 Florida's 871,733 
acres. Florida's industry has an approximate $9 billion economic impact 
on the state.

[77] The FY 2005 Homeland Security Grant Program combines six separate 
grant programs into one application. These programs are the State 
Homeland Security Program, the Law Enforcement Terrorism Prevention 
Program, the Citizen Corps Program, Emergency Management Performance 
Grants, the Metropolitan Medical Response System Program, and the Urban 
Areas Security Initiative.

[78] The $20 million is the allocation available through one component 
of the Homeland Security Grant Program, the State Homeland Security 
Program. All of the funding for the state's agroterrorism projects for 
FY 2004 came through the State Homeland Security Program.

[79] This was required for USDA's Standards for Plant Health Emergency 
System. In addition, the District of Columbia and the American Virgin 
Islands did not complete their plant health emergency planning 
documents by the September 30, 2004, deadline.

[80] The USDA job announcement for these positions warns the job is 
trying, involving long hours at a computer or on the phone, and up to 
10 days of travel per month regionally, nationally, or internationally-
-not including emergencies.

[81] DHS officials did not provide us with a copy of the Government 
Coordinating Council Charter during the course of our engagement.

[82] In commenting on a draft of this report, DHS officials noted that 
since the summer of 2003, the agency has been working with USDA's 
Agricultural Research Service and with APHIS to develop a joint 
strategy for foreign animal disease research and diagnostic programs, 
and that a report summarizing this strategy was submitted to the House 
of Representatives Appropriations Subcommittee for Homeland Security in 
January 2005.

[83] Those diseases, as identified by the National Animal Health 
Laboratory Network's steering committee, are bovine spongiform 
encephalopathy, FMD, classical swine fever, exotic Newcastle disease, 
avian influenza, scrapie, chronic wasting disease, and vesicular 
stomatitis virus.

[84] USDA officials told us that a memorandum of agreement was drafted 
in late 2004 between USDA, HHS, DHS, and other agencies to work 
collaboratively to provide timely, high-quality, and interpretable 
results for early detection and effective consequence management of 
acts of terrorism and other events requiring an integrated laboratory 
response.

[85] HSPD-9 calls for nationwide laboratory networks for food, 
veterinary, and plant health that integrate existing federal and state 
laboratory resources and are interconnected. Specifically, HSPD-9 
requires USDA and HHS to develop robust, comprehensive, and fully 
coordinated surveillance and monitoring systems that provide early 
detection and awareness of disease, pest, or poisonous agents.

[86] Pub. L. No. 93-288, 88 Stat. 143.

[87] Pub. L. No. 106-224, 114 Stat. 358.

[88] Pub. L. No. 107-171, 116 Stat. 134; portions of this law are 
referred to as the Animal Health Protection Act.

[89] Pub. L. No. 107-188, 116 Stat. 594.

[90] DHS Agreement Number BTS-03-0001.

[91] Office of Management and Budget, OMB Circular A-123 Management 
Accountability and Control (Washington, D.C.: 1995). This document 
provides the specific requirements for assessing and reporting on 
controls within the executive branch.

[92] U.S. Government Accountability Office, Internal Control: Standards 
for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1 
(Washington, D.C., November 1999). The Federal Managers' Financial 
Integrity Act of 1982 (FMFIA) requires us to issue standards for 
internal controls in government. Among other things, the standards 
provide the overall framework for establishing and maintaining internal 
controls.

[93] B.V.M.S., is a Bachelor of Veterinary Medicine degree. M.R.C.V.S., 
is a Member of the Royal College of Veterinary Surgeons. Ph.D. is a 
Doctorate of Philosophy degree.

[94] D.V.M., is a Doctorate of Veterinary Medicine degree.

[95] M.P.H., is a Master in Public Health degree.

[96] MS is a Master of Science degree.

[97] CARVER is an acronym for Criticality, Accessibility, 
Recuperability, Vulnerability, Effect, and Recognizability.

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