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United States Government Accountability Office: 


Before the Subcommittee on Oversight of Government Management, the 
Federal Workforce, and the District of Columbia, Committee on Homeland 
Security and Governmental Affairs, U.S. Senate: 

For Release on Delivery: 
Expected at 2:30 p.m. EDT:
Tuesday, September 13, 2011: 

Homeland Security: 

Challenges for the Food and Agriculture Sector in Responding to 
Potential Terrorist Attacks and Natural Disasters: 

Statement of Lisa Shames, Director: 
Natural Resources and Environment: 


Chairman Akaka, Ranking Member Johnson, and Members of the 

I am pleased to be here today as you examine issues related to food 
and agriculture emergencies. Agriculture is critical to public health 
and the nation's economy. It annually produces $300 billion worth of 
food and other farm products and is estimated to be responsible for 1 
out of every 12 U.S. jobs. As a result, any natural or deliberate 
disruption of the agriculture or food production systems--including 
natural disasters, disease outbreaks, and food contamination--can 
present a serious threat to the national economy and human health and 
can halt or slow trade. The food and agriculture systems are also 
vulnerable to terrorist attacks, such as the intentional introduction 
of a foreign animal or plant disease or the intentional contamination 
of food products. 

Recognizing the vulnerability of the U.S. food and agriculture 
systems, the President issued Homeland Security Presidential Directive 
(HSPD)-9 in January 2004 to establish a national policy to defend 
these systems against terrorist attacks, major disasters, and other 
emergencies. HSPD-9 assigns various emergency response planning and 
recovery responsibilities to federal agencies, including the 
Departments of Agriculture (USDA), Health and Human Services (HHS), 
and Homeland Security (DHS), and also the Environmental Protection 
Agency (EPA). Separately, DHS's 2008 National Response Framework 
outlines how the nation will collectively respond to any emergency, 
regardless of its cause or size. The framework includes 15 emergency 
support functions (ESF) for the federal response to an emergency or 
for federal support to states during an emergency. DHS activates 
individual ESFs when a threat or emergency necessitates a specific 
type of coordinated federal response. ESF-11 specifically addresses 
the federal food and agriculture response during emergencies, and USDA 
is designated as coordinator. 

Protecting food and agriculture has been a topic of interest to the 
Subcommittee for many years. For example, in 2005, we reported to this 
Subcommittee that, although many steps had been taken to protect 
agriculture from a terrorist attack, complex challenges limited the 
nation's ability to quickly and effectively respond to a widespread 
attack on agriculture.[Footnote 1] In 2007, we also reported to this 
Subcommittee that USDA and DHS had not determined how they will work 
together during an outbreak of highly pathogenic avian influenza that 
is sufficient in scope to warrant various federal disaster 
declarations.[Footnote 2] Our prior work has shown that roles and 
responsibilities must be clearly defined and understood to facilitate 
rapid and effective decision making.[Footnote 3] This issue has yet to 
be resolved. 

In 2009, we testified before this Subcommittee that the lack of a 
government-wide initiative to address current and future veterinarian 
shortages may place human health, the economy, and the nation's food 
supply at risk.[Footnote 4] We made numerous recommendations, 
including that agencies with food safety responsibilities assess their 
veterinarian workforces to identify current and future workforce 
needs, including training and employee development, and that a 
government-wide approach be used to address these shortcomings. In 
response, agencies created an interagency forum and developed a 
strategic workforce plan to obtain a government-wide understanding of 
the current status and future needs of the federal veterinary 
workforce. This is a positive step, but more work remains to be done. 
For example, steps are still necessary to understand the veterinarian 
workforce needed during a potential catastrophic event--whether a 
pandemic or an attack on the food supply. 

Most recently, you asked us to look at response and recovery from 
potential terrorist attacks and natural disasters affecting food and 
agriculture. This statement summarizes our report being released today 
[Footnote 5] that (1) evaluates the extent to which there is oversight 
of federal agencies' overall progress in implementing the nation's 
food and agriculture defense policy (HSPD-9); (2) evaluates the steps 
USDA has taken to implement its response and recovery responsibilities 
outlined in this policy, and identifies challenges, if any, that the 
department faces in implementing these responsibilities; and (3) 
identifies the circumstances under which USDA has coordinated the 
federal food and agriculture response for an emergency for which ESF-
11 was activated and challenges, if any, that the parties involved 

I will focus my testimony today on three key points. First, there is 
no centralized coordination to oversee federal agencies' overall 
progress in implementing the nation's food and agriculture defense 
policy. Second, USDA does not have a strategy for implementing its 
HSPD-9 responsibilities and faces challenges implementing these 
responsibilities. Third, USDA faces challenges in coordinating the 
federal food and agriculture response for natural disasters for which 
ESF-11 was activated. 

My statement summarizes the findings in our report, being released by 
the Subcommittee today, on response and recovery efforts for food and 
agriculture emergencies. To perform this work we, among other things, 
reviewed key documents; surveyed animal health officials from all 50 
states and five U.S. territories; and interviewed state and industry 
officials, as well as officials from USDA, DHS, HHS, and EPA--because 
these agencies have the most responsibilities under HSPD-9. Our report 
contains a detailed overview of our scope and methodology. We 
conducted this work in accordance with generally accepted government 
auditing standards. 

No Centralized Coordination Exists to Oversee Federal Agencies' 
Overall Progress in Implementing the Nation's Food and Agriculture 
Defense Policy: 

There is no centralized coordination to oversee the federal 
government's overall progress implementing the nation's food and 
agriculture defense policy. Because the responsibilities outlined in 
this policy (HSPD-9) cut across several different agencies, 
centralized oversight is important to ensure that efforts are 
coordinated to avoid fragmentation, efficiently use scarce funds, and 
promote the overall effectiveness of the federal government. 
Previously, the White House Homeland Security Council conducted some 
coordinated activities to oversee federal agencies' HSPD-9 
implementation by gathering information from agencies about their 
progress, and DHS supported these activities by coordinating agencies' 
reporting of HSPD-9 implementation progress. However, the Homeland 
Security Council and DHS's efforts are no longer ongoing. Top-level 
review can help ensure that management's directives are carried out 
and determine if agencies are effectively and efficiently using 
resources. Because there is currently no centralized coordination to 
oversee agencies' HSPD-9 implementation progress, it is unclear how 
effectively or efficiently agencies are using resources in 
implementing the nation's food and agriculture defense policy. As a 
result, the nation may not be assured that crosscutting agency efforts 
to protect agriculture and the food supply are well-designed and 
effectively implemented in order to reduce vulnerability to, and the 
impact of, terrorist attacks, major disasters, and other emergencies. 

USDA Does Not Have a Department-wide Strategy for Implementing Its 
Response and Recovery Responsibilities: 

USDA does not have a department-wide strategy for setting priorities 
and allocating resources for implementing its numerous HSPD-9 
responsibilities. Instead, according to USDA, the department assigned 
HSPD-9 implementation responsibilities to its agencies based on their 
statutory authority and expertise and allowed individual agencies to 
determine their implementation and budget priorities. We have 
previously reported that developing a strategy to accomplish national 
security goals and desired outcomes helps agencies manage their 
programs more effectively and is an essential mechanism to guide 
progress in achieving desired results.[Footnote 6] Moreover, effective 
strategies help set priorities and allocate resources to inform 
decision making and help ensure accountability. Such priority setting 
and resource allocation is especially important in a fiscally 
constrained environment. Without such a strategy, USDA cannot be 
assured that its agencies' efforts are making progress to align with 
departmental priorities and effectively allocate resources. Therefore, 
USDA also cannot be assured that it is fulfilling its HSPD-9 
responsibilities. According to USDA officials, the department would 
benefit from strategic direction from the National Security Staff-- 
which supports the White House Homeland Security Council under the 
current administration--to help prioritize specific activities and 
funding decisions, given this time of limited resources. 

Moreover, although USDA agencies have taken steps to implement the 
department's response and recovery responsibilities, they also face 
challenges. For example: 

* National Veterinary Stockpile (NVS): USDA's Animal and Plant Health 
Inspection Service (APHIS)--which is responsible for issuing orders 
and regulations to prevent the introduction or dissemination of animal 
and plant pests and diseases--has developed the NVS to respond to the 
17 most damaging animal diseases, such as highly pathogenic avian 
influenza. This disease is associated with high morbidity and 
mortality in poultry, and the H5N1 strain of avian influenza is 
associated with illness and death in humans. Among the steps APHIS 
took to develop the NVS, was the acquisition of critical supplies to 
respond to animal disease outbreaks. APHIS also took steps to prepare 
states to use these supplies, such as developing guidance and hiring a 
full-time liaison to, among other things, help states develop a plan 
to manage these supplies. 

However, APHIS also experiences complex implementation challenges. For 
example, although the NVS has acquired various supplies to respond to 
each of the 17 animal disease threats, vaccines and diagnostic test 
kits for certain diseases have either not yet been developed or may be 
too costly for the NVS to purchase. In addition, APHIS officials told 
us that although they have the capability to deploy certain supplies 
within 24 hours--as required by HSPD-9--it will take longer to deliver 
certain vaccines to states. Furthermore, states may not be adequately 
prepared to receive and use NVS supplies. About one-third of all the 
states and territories responding to our survey reported completing an 
NVS plan, which, according to guidance, is needed to ensure emergency 
responders get the NVS supplies they need. Finally, NVS may be missing 
opportunities to leverage resources, where appropriate, from the 
Strategic National Stockpile, as directed by HSPD-9. The Strategic 
National Stockpile contains medical supplies to address public health 
emergencies affecting humans, and as such, may have resources that are 
also useful in emergencies affecting animals. HHS's Centers for 
Disease Control (CDC), which manages the Strategic National Stockpile, 
and APHIS have taken some steps to help the NVS leverage these 
resources. However, confusion about the mission and infrastructure of 
each stockpile, and disagreement about whether additional resources 
can be leveraged, may be impeding efforts to identify further 
leveraging opportunities. Because they have no formal agreement 
regarding if and when leveraging is appropriate, USDA and HHS may miss 
opportunities to more effectively utilize federal and state resources. 

* National Plant Disease Recovery System (NPDRS): USDA's Agricultural 
Research Service (ARS)--which is the department's chief research 
agency--has taken steps to develop the NPDRS, a system intended to 
help the nation recover from high-consequence plant disease outbreaks 
that could devastate the nation's production of economically important 
crops. According to the NPDRS's 2010 draft strategic plan, ARS's 
principal method for fulfilling this responsibility is to develop an 
estimated 30 to 50 recovery plans for select high-consequence plant 
diseases that may enter the United States. As of May 2011, ARS had 
completed 13 plans, which are intended to provide a brief primer on 
each plant disease and identify research gaps and priorities. For 
example, the NPDRS recovery plan for stem rust of wheat--one of the 
most devastating plant diseases worldwide--states that current 
understanding of the disease is based largely on 50-year-old data that 
must be reexamined and identifies 13 specific areas that require 
updated research. ARS also uses NPDRS funds as a flexible source of 
funding to help ARS initiate research on new, emerging plant disease 
problems as they arise. 

However, ARS lacks a systematic process to monitor and fill research 
gaps included in the plans. According to ARS officials, they rely on a 
variety of entities--including other federal agencies, state 
governments, land grant universities, and the private sector--to 
conduct research on high-consequence plant diseases that may fill 
research gaps identified in the recovery plans. Without a documented, 
systematic process to monitor the extent to which research gaps are 
filled, USDA may not have critical information needed to help the 
nation recover from high-consequence plant disease outbreaks. 
Moreover, NPDRS guidance states that recovery plans provide an 
opportunity to indicate where research dollars need to be concentrated 
in the future. ARS also has not effectively communicated the NPDRS to 
key stakeholders that need to know about these plant disease recovery 
plans. The NPDRS draft strategic plan states that recovery from high-
consequence plant diseases will require coordination between USDA and 
states. However, the 12 USDA and state plant health officials we met 
with all had limited or no knowledge about NPDRS recovery plans, even 
though ARS officials told us that they were sharing plans through a 
variety of venues. As a result, key state and federal plant health 
officials may not have the necessary information to facilitate 
recovery from high-consequence plant diseases. 

* Recovery from an emergency: Various USDA agencies have taken steps 
to enhance recovery efforts for emergencies affecting food and 
agriculture. For example, several USDA agencies participated in a 2005 
EPA-led effort that produced guidance on federal roles and 
responsibilities for disposing of contaminated animals, crops, and 
food products and decontaminating affected areas in order to prevent 
the spread of disease. APHIS also is partnering with universities, 
states, and industry to develop continuity-of-business plans for some 
animal disease emergencies. 

However, recovery efforts face critical challenges. For example, there 
may not be sufficient workforce capacity to depopulate--or slaughter-- 
animals quickly in the event of a catastrophic outbreak of a highly 
contagious animal disease, such as foot-and-mouth disease, a viral 
disease of cattle, swine, sheep, and other cloven-hoofed animals. Foot-
and-mouth disease could create the need to depopulate millions of 
animals to control the outbreak. However, APHIS officials told us that 
it could take as long as 80 days to depopulate a single feedlot with 
about 100,000 cattle. Also, burial has traditionally been the 
preferred method for disposal, but USDA officials told us that this 
may not be feasible on a large scale because, among other things, it 
is labor intensive and may be limited by topography, soil type, and 
environmental regulations. According to APHIS officials, the public 
health consequences of carcass burial on a large scale are 
unacceptable, as recent outbreaks of foot-and-mouth disease in Japan, 
Korea, and the United Kingdom have shown. For example, the media 
reported groundwater contaminations in Korea near some burial sites-- 
including near several schools--that made the water unfit for human 
use. USDA's November 2010 draft foot-and-mouth disease response plan 
takes into consideration alternative approaches to depopulation and 
disposal--such as increasing the use of vaccines for at-risk animals-- 
that could help mitigate the depopulation and disposal resource 

USDA Faces Challenges Coordinating the Federal Food and Agriculture 
Response for Natural Disasters: 

According to USDA, from 2007 through May 2011, it coordinated the 
federal food and agriculture response for 28 natural disasters, 
including hurricanes, floods, winter storms, and other weather-related 
emergencies. USDA and state officials we met with said that having a 
single USDA coordinator to facilitate communication during ESF-11 
emergencies contributed to the success of USDA's ESF-11 response. 
However, they also identified some challenges. For example, when ESFs 
are activated and multiple federal agencies become involved, agencies' 
responsibilities for disposing of animal carcasses are not always 
clear, which has delayed previous disposal efforts and could pose a 
public health risk. In one case, during Hurricane Ike in Texas in 
2008, water surges washed cattle, horses, and poultry 15 to 20 miles 
inland, leaving dead livestock in backyards, in front of hospitals, 
and on roads and highways. Texas officials involved with the response 
told us that valuable time was lost as federal officials debated 
whether the U.S. Army Corps of Engineers or USDA would carry out the 
disposal. Ultimately, DHS's Federal Emergency Management Agency 
(FEMA)--which directs response to emergencies and major disasters--
asked USDA's Natural Resources Conservation Service to do so. The 
Natural Resources Conservation Service administers a number of 
programs that encourage conservation, development, and productive use 
of the nation's land. However, according to officials from that 
agency, FEMA did not make the request until several days after the 
hurricane struck, and the carcasses had begun to decompose. We have 
previously reported that a lack of clarity in leadership roles and 
responsibilities can result in disjointed federal emergency response 
efforts among collaborating agencies and confusion about what 
resources would be provided within specific time frames.[Footnote 7] 
To address such a lack of clarity in leadership roles among 
collaborating agencies, we have reported that a practice to enhance 
and sustain collaboration is for agencies to work together to define 
and agree on their respective roles and responsibilities, including 
how the collaborative effort will be led.[Footnote 8] 

In addition, we found that USDA has not consistently prepared after- 
action reports--documents that summarize what went well and what 
needed improvement during an emergency response. Specifically, USDA 
completed 14 after-action reports--including one that covered the 2008 
hurricane season--for various emergencies, even though USDA officials 
reported to us that ESF-11 has been activated for about 28 
emergencies.[Footnote 9] Moreover, not all of the after-action reports 
that USDA completed contained the perspectives of key parties involved 
in the response, such as FEMA officials, relevant USDA officials at 
the state level, and state officials. Without a more consistent and 
comprehensive after-action reporting process, USDA managers may not 
have the necessary information to identify gaps or challenges and 
address them through corrective actions to help ensure that past 
mistakes are not repeated. Moreover, in February 2006, a White House 
report on Hurricane Katrina stated that "too often, after-action 
reports for exercises and real-world incidents highlight the same 
problems that do not get fixed."[Footnote 10] According to the report, 
all departments and agencies should translate findings of homeland 
security gaps and vulnerabilities into concrete programs for 
corrective action that are fully implemented in a timely fashion. 

In our report, we are making nine recommendations to help ensure that 
the federal government is effectively implementing the nation's food 
and agriculture defense policy and to ensure that the nation is 
adequately prepared to respond to and recover from emergencies 
affecting food and agriculture. In written comments on the report, 
USDA, HHS, and DHS generally concurred with the recommendations. In 
addition, in an e-mail received July 22, 2011, the National Security 
Staff's Deputy Legal Advisor stated that the National Security Staff 
agrees that a review of HSPD-9 is appropriate and that they will look 
for an opportunity to do so. The report contains a complete list of 
our recommendations, along with agencies' comments, and our evaluation 
of those comments. 

Chairman Akaka, Ranking Member Johnson, and Members of the 
Subcommittee, this concludes my prepared remarks. I would be happy to 
respond to any questions that you may have at this time. 

GAO Contact and Staff Acknowledgments: 

For questions or further information regarding this testimony, please 
contact Lisa Shames, Director, Natural Resources and Environment, at 
(202) 512-3841 or Contact points for our Offices of 
Congressional Relations and Public Affairs may be found on the last 
page of this testimony. Key contributors to this testimony include 
Mary Denigan-Macauley, Assistant Director, and Amanda Krause. Kevin 
Bray and Benjamin Shouse also made important contributions. 

[End of section] 


[1] GAO, Homeland Security: Much Is Being Done to Protect Agriculture 
from a Terrorist Attack, but Important Challenges Remain, [hyperlink,] (Washington, D.C.: Mar. 8, 

[2] See, GAO, Avian Influenza: USDA Has Taken Important Steps to 
Prepare for Outbreaks, but Better Planning Could Improve Response, 
[hyperlink,] (Washington, D.C.: 
June 11, 2007). 

[3] GAO, Catastrophic Disasters: Enhanced Leadership, Capabilities, 
and Accountability Controls Will Improve the Effectiveness of the 
Nation's Preparedness, Response, and Recovery System, [hyperlink,] (Washington, D.C.: Sept. 6, 

[4] GAO, Veterinarian Workforce: The Federal Government Lacks a 
Comprehensive Understanding of Its Capacity to Protect Animal and 
Public Health, [hyperlink,] 
(Washington, D.C.: Feb. 26, 2009). 

[5] GAO, Homeland Security: Actions Needed to Improve Response to 
Potential Terrorist Attacks and Natural Disasters Affecting Food and 
Agriculture, [hyperlink,] 
(Washington, D.C.: Aug. 19, 2011). 

[6] See, for example: GAO, Combating Terrorism: Evaluation of Selected 
Characteristics in National Strategies Related to Terrorism, 
[hyperlink,] (Washington, 
D.C.: Feb. 3, 2004). 

[7] See [hyperlink,]. 

[8] GAO, Results-Oriented Government: Practices That Can Help Enhance 
and Sustain Collaboration among Federal Agencies, [hyperlink,] (Washington, D.C.: Oct. 21, 

[9] Three of these 28 emergencies occurred in spring 2011 and, 
therefore, the agency would not have developed after-action reports at 
the time we completed our audit work. 

[10] The White House, The Federal Response to Hurricane Katrina: 
Lessons Learned (Washington, D.C.: Feb. 26, 2006). 

[End of section] 

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