USDA's Evaluations of Foreign Animal Health Systems Could Benefit from Better Guidance and Greater Transparency
GAO-17-373: Published: Apr 28, 2017. Publicly Released: Apr 28, 2017.
Foot-and-mouth disease is highly contagious and affects certain livestock, including cattle. A domestic outbreak could cost the U.S. beef industry billions, and infected imported beef could lead to such an outbreak.
The U.S. Department of Agriculture evaluates the animal health systems of countries seeking to export beef to the U.S.—only approving those that they determine can assure disease-free beef.
Although USDA has a process for conducting such evaluations, it lacks detailed guidance for how its staff should document their analyses and results—leading to reliability and transparency concerns. We recommended USDA enhance its guidance.
Status of Foot-and-Mouth Disease Animal Health System Evaluations Conducted by USDA's Animal and Plant Health Inspection Service (APHIS), March 2017
World map showing March 2017 status of USDA's animal health system evaluations.
What GAO Found
The U.S. Department of Agriculture's (USDA) Animal and Plant Health Inspection Service's (APHIS) process for evaluating the animal health systems of countries seeking to export beef to the United States consists of five steps:
- A country requests that APHIS evaluate its animal health system.
- APHIS gathers information about the country's system, including documents identifying (1) veterinary control and oversight programs, (2) vaccination programs, (3) animal identification and movement controls, (4) laboratory diagnostic capabilities, and (5) animal-disease emergency-response measures.
- APHIS conducts in-country visits to verify and supplement this information.
- APHIS does a risk analysis to determine whether the country's beef products pose a risk to U.S. livestock and begins to draft a risk analysis report.
- APHIS determines an estimated risk level, which is included in the risk analysis report with a description of any mitigation measures the country must implement to ensure the safety of its beef exports. A report is completed and made public only for countries whose beef presents low risk. Countries whose beef poses a greater risk will not be eligible to export beef to the United States.
APHIS could strengthen its evaluation of foreign animal health systems by improving transparency to stakeholders, including the public. APHIS guidance instructs staff to adhere to timeframes for carrying out evaluations to ensure a lengthy process is completed efficiently. But the guidance does not instruct staff how to ensure evaluations are fully transparent. For example, APHIS guidance does not
- direct staff to document their analysis of country information and include all problems and concerns identified and how they were resolved;
- direct staff how to effectively document results of in-country visits, although the guidance requires these visits be documented; and
- indicate how to incorporate guidance on transparency from USDA's Chief Information Officer and the Office of Management and Budget into final risk analysis reports.
Without sufficient guidance instructing staff to document such items, it is unclear (1) how APHIS verifies country information and assesses its reliability; (2) how problems identified are ultimately addressed to APHIS's satisfaction; and (3) what methodologies, sources, assumptions, and uncertainties may influence its risk analysis. Further, according to the World Organisation for Animal Health, because risk analysis is inherently subjective, the process must be documented transparently. During GAO's review, APHIS acknowledged the weaknesses in its guidance and formed a team to begin work to address them. By completing this effort, APHIS may be better able to ensure that it has assessed risks fairly and consistently across countries and over time, and that the process is transparent to the public and other stakeholders.
Why GAO Did This Study
Foot-and-mouth disease (FMD) is a virus that causes painful lesions, making it difficult for livestock to stand or eat and greatly reducing meat and milk production. No FMD cases have been recorded in the United States since 1929. Federal regulations restrict fresh beef imports from countries where the disease is present because the disease may survive in untreated, uncooked beef (beef), and can be costly to control and eliminate. According to USDA, an outbreak of FMD could cause grave damage to the U.S. beef industry, which had a retail value of $95 billion in 2014.
GAO reviewed (1) USDA's process for evaluating the animal health systems of countries seeking to export beef products to the United States, and (2) how this process could be improved. GAO analyzed documentation supporting seven countries' requests for FMD animal health system evaluations. GAO also reviewed federal regulations, guidance, and a key trade agreement; and interviewed knowledgeable USDA and industry officials.
What GAO Recommends
GAO is making three recommendations including that USDA clarify its guidance on how staff should document analysis of a foreign country's animal health system and the results of in-country visits to verify information. USDA agreed with GAO's recommendations and described actions it is taking or plans to take to implement them.
For more information, contact Steve D. Morris at (202) 512-3841 or email@example.com.
Recommendations for Executive Action
Comments: In its official response to the GAO report, USDA stated that APHIS has developed agency guidance addressing the major components needed to evaluate information received from foreign authorities. All staff members have been instructed to use this guidance for current and future animal health system evaluations. APHIS also has plans to assess use of this guidance in the next 6-12 months to ensure that it is working as intended and to identify any needed revisions. To assist staff in ensuring their analyses are transparent, consistent, and complete, USDA said APHIS has developed a special analytical tool that will document information provided to APHIS by foreign authorities and provide a method for recording any staff concerns. Existing guidance also has been clarified to ensure that staff members understand site visit reports are mandatory, and not optional.
Recommendation: To improve USDA's evaluations of foreign countries' animal health systems, the Secretary of Agriculture should direct the Administrator of APHIS to complete its efforts to develop agency guidance, clarifying that (1) staff must document, separately from the final risk analysis report, how key information gathered about a foreign country's animal health system was analyzed and how the information supports each of eight evaluation factors, and (2) in-country site visits must be appropriately and consistently documented in trip reports and should detail verification activities
Agency Affected: Department of Agriculture
Comments: In its official response to the GAO report, USDA stated that APHIS has completed a new centralized Project Tracking System to better manage the documentation. All APHIS staff have access to the system, so all documents can be stored in one location. The system includes a Project Tracking Form for each evaluation that provides an overview of who is working on the project, status of major milestones, and final deliverables when complete. USDA said that the new tracking system also establishes a framework for each project and allows documents to be stored in one place, such as correspondence, references, risk analysis, and rulemaking.
Recommendation: To improve USDA's evaluations of foreign countries' animal health systems, the Secretary of Agriculture should direct the Administrator of APHIS to complete its efforts to develop an information management system to better store, organize, and manage documentation gathered about a foreign country's animal health system.
Agency Affected: Department of Agriculture
Comments: In its official response to the GAO report, USDA stated that APHIS will develop guidance that will include such things as standards for disclosing the reliability of data used in risk assessments, in particular assumptions and uncertainties. The guidance also will outline key source documents that can be made publicly available along with the final risk assessment for an evaluation. In addition, USDA said that APHIS has instructed its staff that it is mandatory that all documents submitted by another country for an evaluation must be in English.
Recommendation: To improve USDA's evaluations of foreign countries' animal health systems, the Secretary of Agriculture should direct the Administrator of APHIS to develop guidance promoting greater transparency in risk analysis reports in accordance with the quality information guidelines issued by USDA's Chief Information Officer and guidance from the Office of Management and Budget.
Agency Affected: Department of Agriculture