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Report to the Ranking Democratic Member, Committee on Agriculture, 
Nutrition, and Forestry, U.S. Senate: 

February 2006: 

Agriculture Production: 

USDA Needs to Build on 2005 Experience to Minimize the Effects of Asian 
Soybean Rust in the Future: 

[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-337]: 

GAO Highlights: 

Highlights of GAO-06-337, a report to the Ranking Democratic Member, 
Committee on Agriculture, Nutrition, and Forestry, U.S. Senate: 

Why GAO Did This Study: 

In 2005, U.S. agriculture faced potentially devastating losses from 
Asian Soybean Rust (ASR), a fungal disease that spreads airborne 
spores. Fungicides approved by the Environmental Protection Agency 
(EPA) can protect against ASR. In 2005, growers in 31 states planted 
about 72.2 million soybean acres worth about $17 billion. While 
favorable weather conditions limited losses due to ASR, it still 
threatens the soybean industry. In May 2005, GAO described the U.S. 
Department of Agriculture’s (USDA) efforts to prepare for ASR’s entry, 
(Agriculture Production: USDA’s Preparation for Asian Soybean Rust, GAO-
05-668R). This report examines (1) USDA’s strategy to minimize ASR’s 
effects in 2005 and the lessons learned to improve future efforts and 
(2) USDA, EPA, and others’ efforts to develop, test, and license 
fungicides for ASR and to identify and breed soybeans that tolerate it. 

What GAO Found: 

USDA developed and implemented a framework—with federal and state 
agencies, land grant universities, and industry—that effectively 
focused national attention on ASR in 2005 and helped growers make 
informed fungicide decisions. The framework was effective in several 
ways. For example, sentinel plots—about 2,500 square feet of soybeans 
or other host plants planted early in the growing season in the 31 
soybean-producing states—provided early warning of ASR. Officials in 23 
of 25 states GAO surveyed reported that this effort was effective. 
Researchers could also promptly identify and report on the incidence 
and severity of the disease on a USDA Web site, alerting officials and 
growers to ASR’s spread. Going forward, however, differences in how 
researchers monitor, test, and report on the disease could lead to 
incomplete or inaccurate data and detract from the value of future 
prediction models. For example, models to forecast ASR’s spread partly 
rely on states’ observations of sentinel plots. USDA asked states to 
report results weekly, but updates ranged from 4 reports, in total, 
during the growing season in one state to 162 reports in another state. 
Inconsistencies also occurred in the designation and placement of plots 
and in the testing of samples for ASR. Further, changes to the 
successful management approach employed by USDA in 2005 raise questions 
about how the program will perform in 2006. For 2006, most operational 
responsibility for ASR will shift from USDA headquarters to a land 
grant university. GAO is concerned that USDA’s lack of a detailed 
action plan describing how program responsibilities will be assumed and 
managed in 2006 could limit the effectiveness of ASR management for 
this year. 

EPA, USDA, and others increased the number of fungicides growers can 
use to combat ASR while efforts continue to develop ASR-tolerant 
soybeans. As of December 2005, EPA had approved 20 fungicides for 
treating ASR on soybeans, including 12 that had emergency exemptions. 
According to officials in the nine states where ASR was confirmed in 
2005, growers had access to fungicides. USDA, universities, and private 
companies are also developing ASR-tolerant soybeans and have identified 
800 possible lines of resistant soybeans, out of a total of 16,000 
lines. USDA estimates it may take 5 to 9 years to develop commercially 
available ASR-tolerant soybeans. 

Soybean Plants Treated with Fungicides Next to ASR-infected Plants: 

[See PDF for image] 

[End of figure] 

What GAO Recommends: 

GAO recommends that the Secretary of Agriculture provide additional 
guidance on the monitoring, testing, and reporting on the incidence of 
ASR and develop a detailed action plan describing how USDA plans to 
manage the ASR program in 2006 to maintain the level of coordination, 
cooperation, and national priority achieved in 2005. In commenting on a 
draft of this report, USDA stated that the recommendations reflect its 
ongoing efforts with states to combat the disease. 

www.gao.gov/cgi-bin/getrpt?GAO-06-337. 

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact Daniel Bertoni at (202) 
512-3841 or bertonid@gao.gov. 

[End of section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

2005 ASR Efforts Showed Benefits of a National Coordination Strategy 
and Highlight the Importance of Consistent Data and Strong Leadership: 

EPA, USDA, and Others Have Made More Fungicides Available While 
Continuing to Develop Longer-Term Solutions: 

Conclusion: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendixes: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: Results of GAO's Survey of Soybean-Producing States: 

Appendix III: 2005 Sentinel Plots and Soybean Acreage: 

Appendix IV: Approved Fungicides for Treating Soybeans for ASR: 

Appendix V: Progression of ASR during the 2005 Growing Season: 

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

Appendix VII: GAO Contacts and Staff Acknowledgments: 

Related GAO Products: 

Tables: 

Table 1: Type of Testing Performed on Samples Suspected of ASR in 2005: 

Table 2: Fungicides Approved by EPA for Treating ASR on Soybeans, as of 
December 31, 2005: 

Table 3: Section 18 Fungicides Approved for ASR and States Where 
Approved, as of December 31, 2005: 

Figures: 

Figure 1: Progression of Infection on a Soybean Plant: 

Figure 2: Spread of ASR across the World: 

Figure 3: Number of Sentinel Plots in Each State, 2005: 

Figure 4: Spraying at a Fungicide Trial in Colquitt County, Georgia: 

Figure 5: An Agricultural Research Containment Facility: 

Abbreviations: 

APHIS: Animal and Plant Health Inspection Service: 

ASR: Asian Soybean Rust: 

CSREES: Cooperative State Research, Education, and Extension Service: 

EPA: Environmental Protection Agency: 

ERS: Economic Research Service: 

FIFRA: Federal Insecticide, Fungicide, and Rodenticide Act: 

RMA: Risk Management Agency: 

SRIPMC: Southern Region Integrated Pest Management Center: 

USDA: U.S. Department of Agriculture: 

Letter February 24, 2006: 

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

Dear Senator Harkin: 

In 2005, U.S. agriculture faced potentially devastating losses from 
Asian Soybean Rust (ASR), a fungal disease that has caused significant 
crop losses in other parts of the world. When ASR infects a soybean 
plant, spots and pustules begin to form on its leaves, which eventually 
turn yellow and drop prematurely, damaging the plant and decreasing the 
number and size of beans.[Footnote 1] ASR can destroy an entire field 
within a few weeks. Weather conditions, such as rainfall, humidity, and 
temperature, affect both the severity and incidence of ASR. However, 
fungicides provide protection against ASR if they are applied correctly 
and at the proper time. In 2005, U.S. growers in 31 states planted 
about 72.2 million acres in soybeans that had a total estimated value 
of about $17 billion. 

The U.S. Department of Agriculture (USDA) has been preparing for the 
arrival of ASR in the continental United States since its presence was 
first detected in Brazil in 2002. ASR was discovered for the first time 
in the continental United States, in Louisiana in November 2004--after 
most of the crop had been harvested--and had little effect on soybean 
production. During 2005, researchers confirmed the presence of ASR in 
138 counties across nine southern states. Currently, no commercial 
soybeans are resistant to ASR, and fungicides are generally recognized 
as the most effective means for controlling the disease. USDA had 
predicted that U.S. economic losses from ASR could reach as high as $2 
billion annually, but growers experienced few crop losses from ASR in 
2005 because weather conditions and other factors were not favorable to 
the spread of the disease. In some cases, it appears that growers 
experienced higher yields than expected because the threat of ASR 
caused them to be more attentive to their crop. While few losses 
occurred in 2005, ASR still poses a significant threat to the U.S. 
soybean industry, depending on the severity and extent of subsequent 
outbreaks. 

In May 2005, we reported on the status of USDA's efforts to prepare for 
ASR's entry into the United States.[Footnote 2] This report examines 
(1) USDA's strategy for minimizing the effects of ASR in the 2005 crop 
year and the lessons learned that could be used to improve future 
efforts and (2) the progress USDA, the Environmental Protection Agency 
(EPA), and others have made in developing, testing, and licensing 
fungicides to treat ASR and in identifying and breeding ASR-resistant 
or ASR-tolerant soybeans. 

In conducting our work, we met with USDA and EPA officials and reviewed 
agency documents on strategy, planning, and funding. We interviewed 
university extension faculty and laboratory diagnosticians in Georgia, 
Florida, Alabama, Indiana, and Iowa. We selected the first three states 
because they were the most significantly affected by ASR in 2005 and 
the latter two because they are among the largest producers of soybeans 
in the United States. We also surveyed officials from the 31 soybean- 
producing states that were included in USDA's sentinel plot program to 
obtain information about the events that occurred in 2005 as well as 
their states' preparations for dealing with ASR in 2006 (see app. II 
for a summary of survey results). We pretested the content and format 
of the survey questionnaire with several state officials. We also 
interviewed industry and trade representatives to discuss fungicides, 
fungicide application equipment, and other issues related to ASR. A 
more detailed description of our scope and methodology is presented in 
appendix I. We performed our work between May 2005 and January 2006 in 
accordance with generally accepted government auditing standards. 

Results in Brief: 

In 2005, USDA developed and implemented a coordinated framework that 
was effective in focusing national attention on ASR and enabling 
growers to make informed decisions about fungicide application. The 
framework includes a surveillance and monitoring network; a Web-based 
information management system; criteria for deciding when to apply 
fungicides; predictive modeling; and outreach. The framework was 
effective in several respects. For example, the sentinel plot program-
-plots planted a few weeks before the beginning of the growing season 
to serve as an advance warning system--allowed researchers to identify 
and report on the incidence and severity of the disease immediately or 
within a few days on USDA's ASR Web site, thereby alerting officials 
and growers to the spread of the disease. Researchers also advised 
growers about whether and what type of fungicide might be needed. State 
officials in most of the soybean-producing states that we surveyed 
characterized the 2005 sentinel plot program as effective in providing 
timely information on the spread of ASR. However, certain 
inconsistencies in implementation could hamper long-term efforts to 
contain ASR. For example, models developed to forecast the spread of 
ASR will need several years of consistently collected data to be most 
effective. These models rely, in part, on states' observations of the 
sentinel plots. Although USDA asked the states to report results at 
least once a week, not all states did so. For example, two states 
reported only four times during the entire growing season while another 
reported almost daily. We also noted inconsistency in the designation 
of sentinel plots. Some plots were stand-alone and some were part of 
existing commercial fields. Stand-alone plots are generally easier to 
access by monitors and may facilitate more regular monitoring and 
reporting. In addition, we noted differences in the diagnostic testing 
of plant samples. Some test results were based on visual inspection and 
others were based on advanced screening techniques, which tend to 
identify ASR earlier in the infection process. Going forward, such 
inconsistencies could eventually undermine the value of predictive 
modeling, whose accuracy depends upon collecting and analyzing timely, 
uniform, and complete data. Finally, leadership is key to the continued 
effectiveness of the ASR effort. The 2005 effort was directed by senior 
USDA officials in headquarters. In 2006, however, USDA plans to 
transfer most operational responsibility for ASR to a land grant 
university in North Carolina. Changes to the successful management 
approach employed by USDA in 2005 raise questions about how the program 
will perform in 2006. At the time of our review, USDA lacked a plan 
showing how all of the responsibilities carried out in 2005 would be 
carried out in 2006. It is important that the department have such a 
plan prior to the 2006 growing season to help ensure that it maintains 
the level of coordination, cooperation, and national priority that was 
achieved in 2005 to address ASR. 

EPA, USDA, and others have made progress in increasing the number of 
fungicides that growers can use to combat ASR, while researchers 
continue their efforts to develop ASR-resistant or -tolerant soybeans. 
As of December 31, 2005, EPA had approved a total of 20 fungicide 
products for treating ASR on soybeans, including 12 for which emergency 
exemptions were granted, and officials in the nine states where ASR was 
confirmed reported that growers had access to fungicides. EPA also 
established maximum residue levels for these exempted fungicides in 
time for soybean growers to export their products to foreign markets. 
To further minimize crop losses, USDA and private companies funded 
fungicide efficacy trials at universities across the United States. 
However, the trials produced inconsistent results, in part because 
different protocols were followed, and the researchers concluded that 
future trials should use uniform protocols to ensure consistent data 
collection and interpretation. USDA, universities, and private 
companies are also working to develop ASR-resistant or -tolerant 
soybeans, and they identified about 800 possible resistant lines of 
soybeans, out of a total of about 16,000 lines of soybeans. USDA 
estimates it may take 5 to 9 years to develop and make commercially 
available ASR-resistant or -tolerant soybeans. Until then, fungicides 
will continue to be the primary method for controlling ASR. 

To ensure continued progress in minimizing the effects of ASR and to 
facilitate research, we are recommending that the Secretary of 
Agriculture provide additional guidance to state ASR program managers 
on monitoring, testing, and reporting on the incidence of ASR and 
ensure that a detailed action plan for managing ASR in 2006 is in place 
prior to the 2006 growing season. 

We provided a draft of this report to USDA and EPA for their review and 
comment. EPA provided oral technical comments, which we incorporated 
into the report as appropriate. In its written comments, USDA said that 
the report fairly describes USDA's preparations related to ASR and that 
both of the report's recommendations reflect its ongoing cooperative 
efforts with states to combat the disease. USDA also provided technical 
comments, which we incorporated into the report as appropriate. 

Background: 

ASR, a disease caused by the fungus Phakopsora pachyrhizi, requires 
living host cells to survive. It can infect over 90 host species of 
legumes, such as kidney beans, chickpeas, and kudzu. When ASR infects 
soybeans, it causes the plants to lose their leaves prematurely, which 
reduces the size and number of the beans. In areas where the disease 
commonly occurs, up to 80 percent yield losses have been reported. 

Environmental factors are critical to the incidence and severity of 
ASR. Long periods of leaf wetness, high humidity, and temperatures 
between 60 and 80 degrees Fahrenheit are ideal for spore germination. 
About 7 days after plants are infected with ASR, small brown spots 
surrounded by yellow rings appear on the leaf's upper surface (stage 
1). Within 10 days, pustules form in the spots, primarily on the 
undersides of the leaves (stage 2). These pustules have raised centers 
that eventually break open to reveal masses of fungal spores, called 
urediniospores (stage 3). Pustules can produce urediniospores for about 
3 weeks. When the wind blows, the spores are dispersed, spreading the 
infection to other fields. Once windborne, the spores can reportedly 
travel hundreds of miles within a single day. Figure 1 shows the 
progression of infection on a soybean plant. 

Figure 1: Progression of Infection on a Soybean Plant: 

[See PDF for image] 

[End of figure] 

ASR was first detected in Japan in 1902. By 1934, the disease was found 
in several other Asian countries as well as Australia. In 1951, the 
disease was first reported on soybeans in India. The disease was 
confirmed, and widespread infestations occurred in several African 
countries in 1996. In 2001, ASR was found in Paraguay and was detected 
in Argentina the following year. By 2002 the disease was widespread 
throughout Paraguay and in some limited areas of Brazil. ASR was first 
discovered in the continental United States in Louisiana on November 9, 
2004. Researchers believe the disease was carried to the United States 
by tropical storms. Figure 2 shows the pattern of ASR's spread 
throughout the world. 

Figure 2: Spread of ASR across the World: 

[See PDF for image] 

[End of figure] 

USDA has been following the path of the disease and planning for its 
introduction into the United States for several years. In May 2002, 
three USDA agencies--the Animal and Plant Health Inspection Service 
(APHIS), the Cooperative State Research, Education, and Extension 
Service (CSREES), and the Agricultural Research Service--together with 
the National Plant Board, industry, and several land grant universities 
formed the ad hoc Soybean Rust Committee. In addition, USDA established 
the National Plant Diagnostic Network to enable diagnosticians, state 
regulatory personnel, and first detectors to communicate images and 
methods of detection for ASR as well as other diseases in a timely 
manner. 

USDA determined that once ASR arrived in the United States it could not 
be eradicated because of its rapid transmission rate and an abundance 
of host species. Thus, it decided fungicides would be the primary means 
of managing ASR in the United States and Canada until researchers can 
develop acceptable soybean cultivars that are resistant to the disease. 
Although the disease has resulted in significant losses in yield and 
production in other countries, soybean growers have learned to 
successfully manage the disease by applying appropriate fungicides. 
However, the use of such fungicides increases the production costs 
associated with soybeans, which had typically required relatively 
little or no management in the United States. For example, during the 
2003 to 2004 growing season, Brazilian growers spent close to $1 
billion on fungicides to prevent and reduce the spread of the disease. 
In the United States, the costs of applying fungicides for ASR are 
estimated to range from $10 to $35 per acre for each application. The 
total cost of applying fungicides will depend on the number of acres 
treated. 

All pesticides, including fungicides, must be registered and labeled in 
accordance with EPA regulations in order for them to be sold or used in 
the United States. If emergency conditions exist, however, EPA can 
grant an emergency exemption to state and federal agencies that allows 
the unregistered use of the pesticide under section 18 of the Federal 
Insecticide, Fungicide, and Rodenticide Act (FIFRA).[Footnote 3] EPA 
regulations require state and federal agencies to submit an application 
for emergency exemptions and set limits on the duration of those 
exemptions. Under the Federal Food, Drug, and Cosmetic Act, as amended 
by the Food Quality Protection Act, EPA sets tolerances for pesticides-
-the maximum residue levels of pesticides permitted on foods. Unlike 
its process for registering fungicides, EPA may grant an emergency 
exemption for the use of a fungicide before it sets a tolerance for 
that fungicide. 

Fungicides for ASR are classified as preventative or curative. 
Preventative fungicides, such as strobilurins, prevent fungi from 
successfully infecting and/or penetrating the host tissue of the plant, 
while curative fungicides, such as triazoles, inhibit or stop the 
development of infections that have already begun. In addition, some 
fungicides contain both preventative and curative chemicals. 

To properly manage ASR, growers must apply the right class of 
fungicides at the appropriate time and with proper equipment. Applying 
fungicides too early can increase production costs, and the fungicide 
could wear off by the time an infection actually occurs. However, if 
growers wait too long to apply the fungicide, the disease could 
progress to an untreatable stage, and some crop could be lost. In order 
for fungicides to be optimally effective, they must be applied to the 
whole plant and be placed as deeply into the canopy as possible because 
the disease usually begins in the lower canopy before traveling into 
the middle and upper canopies as the crop matures. Fungicides can be 
applied by ground sprayers or from the air. Aerial application is a 
viable alternative when rainfall makes the fields too muddy or when 
large amounts of soybean acreage need to be sprayed within a short 
time. 

In April 2004, USDA's Economic Research Service (ERS) conducted a study 
to project the potential economic losses associated with various 
degrees of ASR infestation in the United States. ERS concluded that the 
extent of economic impacts from ASR will depend on the timing, 
location, spread, and severity of the disease as well as the response 
of growers, livestock producers, and consumers of agricultural 
commodities. For the first year of ASR's establishment in the United 
States, ERS estimated that the expected value of net economic losses 
could range from $640 million to $1.3 billion, depending on the 
geographic extent and severity of the disease's initial entry. 

When ASR was discovered in Louisiana in November 2004, it was too late 
in the crop year to damage 2004 soybean production. Since ASR must have 
a living host to survive the winter, USDA believed the disease could 
only successfully survive over the winter in the southernmost areas of 
the United States and would have to be reintroduced each year into more 
northern soybean-producing areas. Therefore, its arrival provided an 
early warning to USDA, growers, and industry, allowing them time to 
prepare strategies for minimizing the impact of the disease before the 
2005 crop year. 

2005 ASR Efforts Showed Benefits of a National Coordination Strategy 
and Highlight the Importance of Consistent Data and Strong Leadership: 

USDA's development and implementation of a coordinated framework was 
instrumental in providing an effective response to ASR on soybeans in 
2005. The framework includes (1) a surveillance and monitoring network, 
(2) a Web-based information system, (3) decision criteria for fungicide 
application, (4) predictive modeling, and (5) outreach for training, 
education, and information dissemination. The goal of the framework was 
to provide stakeholders with effective decision support for managing 
soybean rust during the 2005 growing season, and USDA was generally 
successful in doing so. However, inconsistencies in how researchers 
monitor, test, and report on the disease could lead to incomplete or 
inaccurate data and detract from the value of future prediction models. 
Furthermore, the success of the 2005 framework was due in part to the 
leadership of senior USDA officials, who were able to mount a national 
campaign. The transfer of operational responsibilities to a land grant 
university, under the direction of USDA, raises concerns about the 
department's ability to maintain the level of coordination, 
cooperation, and national priority that was achieved in 2005 to address 
ASR.[Footnote 4] 

The Surveillance and Monitoring Network Was Generally Implemented 
Effectively, but Inconsistencies Could Impair Future Predictive 
Efforts: 

The early detection of ASR through the sentinel plot network--one of 
the key components of the surveillance and monitoring program--was 
effective, according to officials in 23 of the 25 states we 
surveyed.[Footnote 5] Sentinel plots--typically about 2,500 square feet 
of soybeans, other host plants, or a combination of the two--are 
planted a few weeks before the beginning of the growing season and 
serve as an advance warning of approaching ASR. In total, states 
monitored more than 1,000 sentinel plots in 2005. USDA and the North 
Central Soybean Research Program, in affiliation with the United 
Soybean Board, funded the sentinel plot network established under the 
framework. USDA provided about $800,000 for a total of 300 plots in the 
31 soybean-producing states and an additional 20 plots in 4 other 
states that produce dry beans, such as navy beans and chick 
peas.[Footnote 6] (USDA plans to fund a similar number of sentinel 
plots in 2006.) The North Central Soybean Research Program and United 
Soybean Board provided approximately $390,000 for a total of 400 plots 
in 20 states (20 plots per state).[Footnote 7] In addition, some states 
established and monitored other plots during the growing season. 
Officials of the 31 states we surveyed provided data on the number of 
sentinel plots sponsored by USDA and others during 2005 (see fig. 3). 
[Footnote 8] 

Figure 3: Number of Sentinel Plots in Each State, 2005: 

[See PDF for image] 

[End of figure] 

State personnel monitored these plots throughout the growing season to 
determine the presence and severity of ASR. Within each state, a 
designated official entered the monitoring data from the plots into 
USDA's ASR Web site, an online, real-time data system. Once the data 
were entered, growers and others could access the information to 
determine in which counties ASR-infected plants were found. In 
addition, state specialists used the Web site to provide guidance to 
growers about whether and what type of fungicides should be applied. 

Once ASR was detected and confirmed in a state, the framework specified 
that mobile monitoring teams--one assigned to each of five regions-- 
would be dispatched to the affected areas to help determine the 
severity and spread of the disease. During the 2005 growing season, the 
disease was confined to the southeastern region, and therefore only the 
team assigned to that region was deployed. 

Researchers use the information from states on sentinel plot 
monitoring, including diagnostic testing results, to develop prediction 
models that estimate where and how severe ASR will be in certain areas 
of a state or county. These models depend in large part on timely and 
consistent data from the state observations and diagnostic testing 
results. Researchers will rely on this information, in part, to 
validate the predictive models over the next few years, while extension 
personnel and growers rely on this information to make informed and 
timely decisions on the need to apply fungicides. 

USDA asked the states to monitor their sentinel plots at least once a 
week and report the results on a weekly basis by posting them to a 
restricted USDA Web site.[Footnote 9] Monitoring results from the 
sentinel plots supported by USDA and the North Central Soybean Research 
Program were to include, for example, the location, host, and severity 
of the disease.[Footnote 10] However, state officials did not 
consistently report weekly updated information to the Web site during 
the 2005 growing season. Updates from the states ranged from a total of 
4 each for two states to 162 for another. USDA also provided states 
considerable flexibility in how they designated sentinel plots. In some 
cases, fields were planted as stand-alone surveillance fields while in 
other cases, sentinel plots were part of commercial fields. Such 
differences might affect the extent to which crops are accessible for 
crop monitors. While there is no evidence that this variation in plots 
affected data reporting in 2005, a lack of consistency in designating 
sentinel plots could ultimately affect the quality of data that are 
essential to alerting USDA to the initial presence and spread of ASR in 
future years. 

Diagnostic testing was important to confirming suspected cases of ASR 
because several plant diseases resemble it and because U.S. growers 
have little experience in identifying ASR. States are to send the first 
suspected sample of ASR on soybeans and each new host to USDA's APHIS 
laboratory in Beltsville, Maryland, for confirmation testing. However, 
subsequent samples submitted within each state may be tested at either 
a state or National Plant Diagnostic Network laboratory. According to 
our survey of officials in the 31 soybean-producing states, state 
diagnostic laboratories received about 12,100 samples for ASR research 
and screening. Of these samples, about 9,500 were submitted for routine 
research or monitoring and about 2,600 were submitted specifically 
because of suspected ASR. Of the total number of samples tested, only 
877, or about 7 percent, tested positive for ASR. For samples suspected 
of having ASR, states primarily relied on morphological examinations-- 
i.e., examining the spores from lesions on leaf samples, visually or 
under a microscope--to screen the samples suspected of ASR. However, in 
selected cases, the states conducted advanced screening using the 
polymerase chain reaction (PCR) test or an enzyme-linked immunosorbent 
assay (ELISA) test to detect the presence of ASR.[Footnote 11] Table 1 
summarizes the results of states' tests performed on samples suspected 
of having ASR in 2005. 

Table 1: Type of Testing Performed on Samples Suspected of ASR in 2005: 

Type of testing: Morphological examination only; 
Number of samples screened or tested: 2,202. 

Type of testing: Morphological exam and PCR; 
Number of samples screened or tested: 195. 

Type of testing: Morphological exam and ELISA; 
Number of samples screened or tested: 137. 

Type of testing: Morphological exam, ELISA, and PCR; 
Number of samples screened or tested: 71. 

Total; 
Number of samples screened or tested: 2,605. 

Source: GAO's survey of soybean-producing states. 

[End of table] 

The National Plant Diagnostic Network issued standard operating 
procedures for how to submit samples to a diagnostic laboratory and 
procedures for initially screening the samples and conducting advanced 
screening. However, the procedures did not specify how often or under 
what circumstances, the laboratory should conduct advanced screening to 
confirm an initial diagnosis of ASR. Advanced screening might be 
warranted because a morphological examination of a sample in the early 
stages of the disease may fail to detect ASR. Also, in some cases, 
diagnosticians may have limited experience in detecting the disease 
morphologically. Conversely, officials in some states where ASR 
appeared to be no real threat in 2005 may have believed that advanced 
screening was not necessary. Officials in 13 of the states that we 
surveyed reported that a morphological examination was the only type of 
testing they performed on samples of suspected ASR. Officials in 13 
states also indicated that they performed a morphological examination 
as well as at least one other type of advanced screening test, and 
officials in 3 states reported that they only performed advanced 
screening on suspected cases of ASR.[Footnote 12] The various methods 
used to diagnose ASR, and hence to report the results to the Web site, 
could determine the difference between detecting the disease early, 
when it is most easily treated, or delaying detection until it is well 
established. 

As of October 31, 2005, state laboratories had spent an estimated total 
of $465,800 on screening and testing samples for ASR; about $14,600 of 
this cost was offset by the fees the state laboratories charged for 
sample testing. Most of the state officials we surveyed reported that 
their states had sufficient funding and staffing to perform diagnostic 
screening and testing for ASR during 2005. For 2006, officials from 30 
of the states that we surveyed indicated that they plan to have the 
same number or more laboratory staff. However, officials from nine of 
the states indicated that they still lacked sufficient equipment to 
perform recommended diagnostic testing. In addition to testing field 
samples, USDA sampled rainwater to help in the early detection of 
ASR.[Footnote 13] With these samples, scientists can detect spore 
concentrations before ASR is apparent on the plant. Positive samples 
were found in most of the regions tested, including the Midwest and the 
Northeast, where ASR was not apparent on the plant. USDA is using this 
information for research and plans to publish its findings in a 
professional journal.[Footnote 14] 

USDA's Web-Based Information System Was Viewed Favorably, but Users 
Suggested Improvements: 

As a means to share information among all interested parties, in March 
2005, USDA activated the public ASR information Web site, which 
provided disease observations, management recommendations, and scouting 
information, among other things.[Footnote 15] The site allows growers 
and other interested parties to go to a single location for real-time, 
county-level information on the spread of the disease in soybean-
producing states. The Web site displays two maps of the United States. 
One map shows the counties in which researchers scouted for ASR and did 
not find it (in green) and counties in which ASR was confirmed (in 
red). Another map allows the public to click on a state and obtain 
information on ASR management, such as disease management, scouting 
results, growth stages, and forecast outlook. In addition, the Web site 
provides a chronology of positive ASR detection by date confirmed, 
county, and state; information on the spread of ASR nationwide; and 
links to related Web sites. 

USDA has also established a restricted Web site that has several access 
levels for various users, such as state specialists, observers, 
researchers, and selected industry representatives. Among other things, 
this site presents information on observed and predicted disease 
severity and spore deposition. The Web site is restricted to prevent 
unauthorized users from entering erroneous data and to allow state 
specialists to share and assess data before distributing information to 
the public. The information in this restricted Web site then becomes 
the basis for the information on the public Web site. 

Officials in the soybean-producing states that we surveyed 
characterized USDA's Web sites (public and restricted) as useful to 
their states. However, several officials provided suggestions for 
improvement. These suggestions included making the Web sites easier to 
use, giving multiple officials within each state access to update the 
Web sites, considering the needs of the colorblind, providing better 
instructions to users, recognizing the efforts of extension service 
personnel on the Web site, considering the needs of users without high- 
speed Internet connections, and publicizing the Web sites to a greater 
extent. 

Decision Criteria for Fungicide Application Useful to Advisers and 
Soybean Growers in Responding to ASR: 

To educate and assist growers and extension personnel in making 
decisions regarding the use of fungicides to combat ASR, state land 
grant university extension specialists and USDA developed a fungicide 
guide. The April 2005 ASR fungicide manual--Using Foliar Fungicides to 
Manage Soybean Rust--was developed under a USDA grant by state 
extension and scientists at 22 U.S. universities, USDA, and the Ontario 
Ministry of Agriculture and Food. It was widely available to state 
officials, growers, and other stakeholders. The manual provides basic 
fungicide information, such as the chemistry involved and the brand 
names of different products, as well as information on factors involved 
in making fungicide spray decisions, including whether to use a 
preventative or curative fungicide, and how and when to apply the 
fungicide. Over 150,000 copies of the manual were distributed during 
2005. In addition, extension officials in the states we visited 
commented that the manual was very useful to growers in deciding when 
and how to apply fungicides during the 2005 crop season. Using 
information from USDA's Web site and the ASR fungicide manual, 
extension service offices in five states where ASR was confirmed 
suggested that some growers apply fungicides for ASR at least once 
during the 2005 growing season.[Footnote 16] 

Predictive Modeling Is a Work in Progress and Will Depend on Good Data 
in the Future: 

During the 2005 growing season, state specialists could obtain ASR 
forecast information from various models, synthesize the information, 
and use it to prepare state forecast outlooks for dissemination on 
USDA's public Web site. These models included one supported by USDA 
that predicted the aerial spread of ASR spores from active source 
regions in the United States to other soybean-growing areas; the 
results of this model were published on USDA's restricted Web 
site.[Footnote 17] Other ASR prediction models available during 2005 
included one from the North American Disease Forecast Center at North 
Carolina State University and another developed by researchers at Iowa 
State University. These models depend in large part on timely and 
consistent data from the states' observations and diagnostic testing 
results. 

According to researchers who used the models, ASR prediction models 
tended to overstate the spread of ASR in 2005. However, this was the 
first full year that ASR was in the United States and it generally 
takes several years to calibrate and validate models like these. One 
researcher has proposed that USDA use an "ensemble approach" to predict 
the spread of ASR in 2006--that is, using forecast information from 
several ASR models in predicting the spread of ASR. Regardless of which 
models are used, inconsistencies in defining or designating sentinel 
plots, in diagnosing ASR, and hence in reporting the results to the Web 
site could affect the development of predictive models and ultimately 
could determine the difference between detecting ASR early, when it is 
most easily treated, or delaying detection until ASR is well 
established. 

Outreach for Training, Education, and Information Dissemination Was 
Effective in 2005 and Is Planned to Continue in 2006: 

In preparation for the 2005 growing season, USDA and the 31 soybean- 
producing states we surveyed sponsored about 1,500 presentations, 
programs, and workshops on ASR. Officials in these states reported that 
they planned to offer over 400 presentations, programs, and workshops 
on ASR between November 1, 2005, and April 30, 2006. According to the 
state officials we surveyed, the three most important topics to include 
in these workshops are identification of ASR and "look-alike" diseases, 
availability and use of fungicides, and observations and results from 
2005. 

During the 2005 growing season, several other outreach efforts were 
also conducted to help growers. For example: 

* Some states supported telephone hotlines that presented the latest 
information on ASR, enabling growers using cellular phones to get 
information when they were out in the fields. 

* The University of Kentucky created two ASR electronic mailing lists-
-one that facilitated discussion and information sharing about ASR 
among 137 industry, state, federal, and university officials and 
another that facilitated communication among 108 individuals regarding 
the soybean rust sentinel plot and surveillance network. 

* The American Phytopathological Society organized a symposium in 
November 2005--attended by over 350 participants--to discuss ASR and 
lessons learned during the past growing season. 

* Several states also displayed ASR information on their state Web 
sites. 

Lack of an Action Plan Describing How Leadership Responsibilities Will 
Be Assumed and Managed in 2006 Raises Concerns About a Sustained 
National Effort for ASR: 

The national effort for ASR during the 2005 growing season was directed 
by senior APHIS headquarters officials, who coordinated the federal, 
state, and industry effort to develop the framework. Before and during 
the growing season, they conducted regular meetings with state 
specialists. According to a representative of the American Soybean 
Association, soybean growers were pleased with the central, coordinated 
effort led by APHIS to fight against ASR. In addition, 30 of the 
officials in the states we surveyed reported that communication was 
effective between their state and USDA in addressing ASR during 2005. 

APHIS has been involved in preparing for ASR because of its 
responsibility to protect the nation from the introduction of foreign 
plant pests. However, now that ASR is in the United States, CSREES is 
responsible for managing efforts to minimize its effects.[Footnote 18] 
In November 2005, USDA formally announced the transition of operational 
responsibility for managing ASR in 2006, from APHIS to the Southern 
Region Integrated Pest Management Center (SRIPMC) at North Carolina 
State University, under the direction and coordination of 
CSREES.[Footnote 19] The current ASR national system will be expanded 
to provide growers with information about additional legume pests and 
diseases in 2006. SRIPMC and USDA recently signed a cooperative 
agreement that will provide about $2.4 million to fund ASR monitoring, 
diagnostics, and communication efforts in 2006.[Footnote 20] Total 
funding includes $1 million for sentinel plots and $800,000 for 
diagnostic testing. In 2005, USDA provided nearly $1.2 million for 
these activities. 

During 2006, selected APHIS personnel will assist with the transition 
to CSREES. One key APHIS official will serve as the national coleader 
of the USDA Web site and train SRIPMC personnel, and a contractor will 
continue to serve as data manager to help ensure that the Web site 
continues to provide current, useful information. In addition, the 
contractor will continue to provide meteorology and modeling expertise. 
However, as of January 25, 2006, USDA lacked a detailed plan describing 
how it plans to ensure that all elements of the 2005 framework will be 
effectively implemented in 2006. In commenting on a draft of this 
report, USDA reported that it was developing, but had not completed, 
such a plan. 

Changes to the successful management approach employed by USDA in 2005 
raise questions about how the program will perform in 2006. We are 
concerned that without a detailed action plan in place prior to the 
2006 growing season, describing how CSREES will assume and manage 
important responsibilities, USDA may not be able to ensure that the 
level of coordination, cooperation, and national priority that was 
achieved in 2005 to address ASR will continue in 2006. 

EPA, USDA, and Others Have Made More Fungicides Available While 
Continuing to Develop Longer-Term Solutions: 

As of December 31, 2005, EPA had approved a total of 20 fungicide 
products for treating ASR on soybeans, including 12 for which emergency 
exemptions were granted. Officials in the nine states where ASR was 
confirmed reported no problems in obtaining access to fungicide 
application equipment. While officials in three of these states 
reported that not all fungicide products were available to their 
growers, they did not indicate that growers experienced fungicide 
shortages overall. To determine which fungicides are the most effective 
under given conditions, USDA and private companies also supported 
research efforts at universities across the United States. For the 
longer term, USDA, universities, and private companies are conducting 
research to develop ASR-resistant or -tolerant soybeans but expect that 
these will not be available commercially for 5 to 9 years. 

EPA and USDA Worked Cooperatively to Make Multiple Fungicides Available 
in 2005: 

Efforts to ensure that fungicides would be approved for treating ASR on 
soybeans have been under way for some time. (See app. IV for a complete 
list of approved fungicides.) Before March 2004, 4 fungicides had been 
registered for preventing ASR on soybeans. However, between March 2004 
and June 2005, EPA approved another 16 fungicides--all in time for 
application during the 2005 growing season. These fungicides included 
the following: 

* 4 registered fungicides that are preventative; and: 

* 12 fungicides for which emergency exemptions were granted.[Footnote 
21] Nine of these products are curative,[Footnote 22] and 3 have both 
preventative and curative properties. 

As of November 2005, five additional fungicides for ASR were pending 
approval for emergency exemption, and two others were pending full 
registration. 

EPA was able to act expeditiously, in part because, in July 2002, USDA 
and EPA began discussing preparations for emergency exemptions and 
working with private industry and state departments of agriculture to 
prepare for ASR. They identified fungicides with known efficacy against 
ASR and fungicides that needed additional testing to gain EPA approval. 
During 2003, USDA's Office of Pest Management Policy hosted several 
teleconferences and meetings with researchers, EPA, and state officials 
to discuss the development of emergency exemptions for soybeans and 
other legumes. In November 2003, EPA suggested a procedure for states 
to follow for requesting emergency exemptions. That is, although each 
state typically submits a unique request to EPA for an emergency 
exemption, EPA allowed Minnesota and South Dakota to prepare a joint 
request for treating ASR on soybeans and allowed other states to copy 
this request. USDA also began contacting states to offer help preparing 
requests for emergency exemptions. 

As a result of these preparations, when ASR was first confirmed in the 
continental United States in November 2004, 26 states, representing 99 
percent of the U.S. soybean acreage, had requested emergency exemptions 
for fungicides to treat ASR, and 25 of these states had received at 
least one emergency exemption. Furthermore, although emergency 
exemptions are usually granted for a single year, EPA approved the 
exemptions for ASR fungicides through November 2007, as quarantine 
emergency exemptions. These exemptions may be authorized for up to 3 
years in an emergency condition to control the introduction or spread 
of any pest new to or not known to be widely prevalent or distributed 
within and throughout the United States. Consequently, in 2007, states 
will have to renew their emergency status, with the support of the 
manufacturer; work to have these fungicides registered; or use already 
registered fungicides.[Footnote 23] In addition to these efforts, in 
April 2004, USDA met with the American Soyfoods Association of North 
America to plan efficacy research on chemicals permitted to treat 
organically grown soybeans and to discuss organic certification of 
fields treated with conventional chemicals. Furthermore, by August 
2005, EPA had established maximum residue levels for the exempted 
fungicides in time for soybean growers to export their products to 
foreign markets. 

At the November 2005 ASR symposium, EPA announced that it remains 
receptive to receiving future registration and exemption requests for 
additional fungicides to treat ASR.[Footnote 24] According to state 
officials with whom we spoke, the variety of fungicides available as a 
result of the exemption process helped reduce the risk that ASR would 
become resistant to fungicides and ensured that a supply of fungicides 
would be available to growers. 

In terms of the availability of application equipment and fungicides in 
2005, the officials we surveyed in the nine states where ASR was 
confirmed reported no problems with access to equipment. Although 
officials in three of these states indicated that their growers did not 
have access to all fungicide products, none of the states reported that 
growers encountered any shortages of fungicides to treat their crop. 
State, EPA, and USDA officials cautioned that actual fungicide 
inventory and availability depends largely on market forces outside 
their control. These officials also stated that it is not possible to 
determine the sufficiency of fungicides and equipment for 2006 because 
of uncertainties about (1) the timing and potential spread of ASR into 
northern states, which do not generally apply fungicides on soybeans 
and therefore may not have supplies and equipment available and (2) the 
potential need in southern states for growers to use fungicides and 
equipment for other major crops, such as peanuts, thereby creating a 
shortage for use on soybeans. 

USDA and Other Sponsors Have Supported Research Efforts to Determine 
the Most Effective Types of Fungicides and Application Methods: 

USDA began evaluating fungicide efficacy for ASR in 2001,[Footnote 25] 
and it supported its own field work in this area from 2003 through 2005 
in Africa and South America with funding from private companies and the 
United Soybean Board.[Footnote 26] In addition, beginning in 2002, the 
agency began contacting approximately 20 companies and trade 
organizations to participate in efficacy trials for the registration of 
ASR fungicides at several U.S. universities and international 
locations. Efficacy trials examine the impact fungicides have on 
factors such as crop yield and disease severity by testing the: 

* effectiveness of fungicides under various spray conditions, such as 
volume, pressure, and application frequency; 

* effectiveness of fungicides under different crop conditions, such as 
maturity, row spacing, and plant varieties; and: 

* impact of various application techniques and equipment on such things 
as coverage and penetration of the crop canopy. 

Figure 4 shows the application of fungicides at a trial in 2005. 

Figure 4: Spraying at a Fungicide Trial in Colquitt County, Georgia: 

[See PDF for image] 

[End of figure] 

Conducting trials at different locations allows researchers to study 
the effectiveness of fungicides and application methods in different 
climates and on different strains of ASR. EPA can use efficacy data 
from these trials to evaluate fungicides for emergency exemptions. USDA 
started posting fungicide efficacy data, including some data from 
private companies,[Footnote 27] to a USDA research Web site in 
2003.[Footnote 28] According to agency officials, these trials showed 
that (1) fungicides reduced crop losses, (2) some fungicides were more 
effective than others, and (3) different fungicides with different 
active ingredients were necessary to combat ASR because what works best 
in one region may not be as effective in another. In terms of 
equipment, the trials showed that better coverage of the plant using 
higher spray volume is more important for effective spraying than the 
type of nozzles used. USDA has not taken a position concerning the 
application of fungicides on soybeans not threatened by ASR, although 
some private companies have promoted such an approach.[Footnote 29] 

Most recently, in 2005, researchers at southern universities conducted 
efficacy trials on several fungicides approved by EPA and some 
fungicides only approved for use in Brazil. Many of these trials were 
conducted in areas infected with ASR. These trials produced mixed 
results, but researchers concluded that timing the first spray may be 
the most critical factor when applying fungicides to treat ASR. 
Fungicide trials were also conducted in 2005 in 13 northern states 
where ASR has not yet been confirmed. The researchers conducting these 
trials focused on questions such as whether fungicides improved soybean 
yields in the absence of ASR. These trials produced inconsistent data, 
in part because different protocols--for example, plot management and 
fungicide application techniques--were followed; and the researchers 
concluded that uniform protocols should be established for future 
trials to ensure consistent data collection and interpretation. 

Rust-Resistant Soybeans Will Not Be Available to Growers for Several 
Years: 

Breeding commercial soybeans with resistance to or tolerance of ASR is 
generally regarded as the best long-term solution for managing the 
disease; and USDA, several universities, and private companies are 
currently working to develop such soybeans. Breeding new varieties of 
soybeans and making them commercially available takes time--up to 9 
years--according to USDA officials. The Agricultural Research Service 
has approximately 16,000 soybean lines in its soybean germplasm 
collection.[Footnote 30] As of June 2005, researchers had finished an 
initial screening of these lines. Approximately 800 lines were 
identified as having some form of resistance or tolerance to ASR and 
are currently being evaluated using more advanced screening tests. 
Subsets of these 800 lines are also being evaluated in field trials in 
collaboration with researchers in Africa, Asia, and South America. An 
intermediate screening of these 800 lines was completed and the results 
published in a scientific journal in January 2006.[Footnote 31] Some of 
these lines are only resistant to a few of the known strains of ASR. 
USDA researchers hope to eventually find lines that are resistant to 
all known strains.[Footnote 32] The United Soybean Board and the Iowa 
Soybean Association and Promotion Board have provided financial support 
for this work. 

In addition to the sheer volume of germplasm that researchers need to 
examine, other factors have also contributed to the time taken to 
identify soybean varieties that are resistant or tolerant to ASR. 
Before USDA removed ASR from the select agents and toxins list under 
the Agricultural Bioterrorism Protection Act of 2002 in March 
2005,[Footnote 33] USDA's research in the United States was limited to 
a few containment facilities. Researchers could not conduct yield loss 
studies because the available containment facilities did not have 
enough room to allow soybean plants to reach maturity. The limited 
space in containment facilities has also slowed USDA's ability to 
germinate and study foreign strains of ASR (see fig. 5). ASR's arrival 
in the United States should facilitate USDA's efforts to study the 
disease because researchers in affected states can now work with ASR 
and soybean plants under field conditions. 

Figure 5: An Agricultural Research Containment Facility: 

[See PDF for image] 

[End of figure] 

The Agricultural Research Service expects to have soybean germplasm 
with some level of resistance to ASR within 5 years. It intends to work 
with industry through cooperative research and development agreements 
and other mechanisms to provide access to this germplasm so that 
private companies can develop commercial soybeans with resistance or 
tolerance to ASR. Commercialization may take an additional 2 to 4 
years. According to agency researchers, it is difficult to develop 
germplasm that is completely resistant to all strains of ASR; and 
therefore, the most effective approach for developing resistance will 
be to develop tolerant soybeans to provide growers more time each 
season to prepare for and manage ASR. 

The Agricultural Research Service is also conducting research to 
examine the genetic variability among the various strains of ASR. The 
expected outcomes of this project are to identify genes required for 
the infection process and disease cycle, as well as the discovery of 
potential targets for new fungicides. Both the Agricultural Research 
Service and the United Soybean Board have supported this research, and 
the agency has also worked with the Department of Energy's Joint Genome 
Institute. 

In April 2005, the Agricultural Research Service issued a National 
Strategic Plan for the Coordination and Integration of Soybean Rust 
Research. It began to develop this strategic plan at a meeting held in 
December 2004, 3 weeks after the disease was confirmed in the 
continental United States. USDA, together with the United Soybean Board 
and the North Central Soybean Research Program, held a national 
workshop with more than 90 soybean experts to set priorities, identify 
strategic goals for ASR research, and develop a national research plan. 
This plan is linked to the agency's overall strategic plan and 
coordinated with other USDA agencies. The research plan also promises 
project review and program assessment by independent peers via annual 
research progress reports. 

Of the research plan's six strategic goals, three aim directly at 
developing ASR resistance or tolerance: 

* develop new, high-yielding germplasm with resistance to soybean rust; 

* determine the genetic basis for ASR's virulence and determine the 
genetic basis for soybeans' resistance to ASR; and: 

* improve understanding of ASR's biology and epidemiology.[Footnote 34] 

The Agricultural Research Service has since developed a draft of an 
action plan intended to measure the progress of the research plan 
initiative. 

Conclusion: 

Effective, timely communication and coordination at the federal, state, 
and local levels, coupled with favorable weather conditions, were keys 
to limiting the impact of ASR on U.S. soybean production in 2005. 
Indeed, in many areas of the country, soybean production exceeded 
expectations, in part because producers were more attentive to their 
crop. While the experience in 2005 was favorable, it is unlikely that 
the fungus will be eliminated. Accordingly, it will still be important 
for all agricultural stakeholders to remain vigilant and to 
consistently monitor, test, and report on ASR and to develop models for 
predicting the spread of the disease. Going forward, however, 
differences in how researchers monitor, test, and report on the disease 
could detract from the value of future prediction models. 

The 2005 ASR experience also highlights the importance of preparing 
for, coordinating, and monitoring a new agricultural disease. The 
lessons learned from managing ASR could be valuable in minimizing the 
effects of other agricultural pests that threaten crops and can cause 
significant economic losses. In this regard, a clear plan of action and 
strong leadership in coordinating the actions of all stakeholders was 
important in 2005 and will continue to be critical to the success of 
efforts to monitor, report, and manage the spread of ASR in 2006. 

Recommendations for Executive Action: 

We are making two recommendations to the Secretary of Agriculture to 
ensure continued strong leadership and improved efforts to predict and 
limit the spread of ASR. 

* To ensure reliable, quality reporting on the spread of the disease, 
USDA should provide additional guidance to state ASR program managers 
and monitors on the timing and frequency of reporting on the incidence 
of ASR, the designation of sentinel plots, and when to use advanced 
diagnostic testing. 

* To ensure that ASR continues to receive national priority and the 
same level of effective coordination and cooperation evidenced in 2005, 
USDA should develop a detailed action plan, prior to the beginning of 
the growing season, describing how it will manage ASR in 2006. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to USDA and EPA for their review and 
comment. In oral comments, EPA told us that the factual information in 
our draft report is correct and provided technical comments, which we 
incorporated as appropriate. In written comments, USDA said that the 
report fairly describes USDA's preparations related to ASR. In 
addition, it stated that both of the report's recommendations reflect 
its ongoing cooperative efforts with states to combat the disease (see 
app. VI). USDA also provided a number of technical comments, which we 
incorporated as appropriate. 

As agreed with your office, unless you publicly announce the contents 
of this report earlier, we plan no further distribution until 30 days 
from the report date. At that time, we will send copies of this report 
to the appropriate committees; the Secretary of Agriculture; the 
Administrator of EPA; and other interested parties. In addition, the 
report will be available at no charge on the GAO Web site at 
[Hyperlink, http://www.gao.gov]. 

If you have any questions about this report, please contact me at (202) 
512-3841 or [Hyperlink, bertonid@gao.gov]. Contact points for our 
Offices of Congressional Relations and Public Affairs may be found on 
the last page of this report. GAO staff who made major contributions to 
this report are listed in appendix VII. 

Sincerely yours, 

Signed by: 

Daniel Bertoni: 
Acting Director, Natural Resources and Environment: 

Appendixes: 

Appendix I: Objectives, Scope, and Methodology: 

To determine the U.S. Department of Agriculture's (USDA) strategy for 
minimizing the effects of Asian Soybean Rust (ASR) now that the disease 
has arrived in the continental United States and the lessons learned 
that could be used to improve future efforts, we interviewed officials 
from USDA's Animal and Plant Health Inspection Service (APHIS), the 
Cooperative State Research, Education, and Extension Service (CSREES), 
the Agricultural Research Service, the Farm Service Agency (FSA), and 
the Risk Management Agency (RMA) to identify efforts that have been 
implemented since November 2004. We also surveyed state officials in 
the 31 soybean-producing states that were included in USDA's sentinel 
plot program to obtain information on their efforts to minimize the 
effects of ASR through education, training, surveillance, and testing 
and to obtain information about the lessons learned during the 2005 
crop year. The survey included questions about the states' university 
extension programs; sentinel plots, monitoring, and scouting; 
diagnostic screening and testing; fungicide use; and perceptions of 
USDA's efforts. Prior to implementing our survey, we pretested the 
questionnaire with several state officials (university extension 
faculty) in Florida and Alabama. During these pretests, we interviewed 
the respondents to ensure that (1) the questions were clear and 
unambiguous, (2) the terms we used were precise, and (3) the survey did 
not place an undue burden on the staff completing it. The questionnaire 
was also reviewed by a GAO survey expert. We made changes to the 
questionnaire based on these pretests. We received responses from all 
31 states surveyed. The state information presented in this report is 
based on information obtained from this survey and interviews with 
state officials. Appendix II contains the state questionnaire and 
aggregated responses. We conducted site visits to Alabama, Georgia, and 
Florida, where we inspected ASR-infected soybeans while touring 
sentinel plots, a fungicide efficacy trial, diagnostic facilities, and 
a commercial soybean field with state extension officials. We 
interviewed university extension faculty and laboratory diagnosticians 
in these states, as well as in Indiana and Iowa, to gain more in-depth 
information about their efforts to mitigate the effects of ASR and test 
for the disease. We also toured USDA diagnostic facilities in 
Beltsville, Maryland. In addition, we interviewed industry and trade 
representatives to discuss the adequacy of available fungicides and 
application equipment. Finally, we attended the November 2005 National 
Soybean Rust Symposium in Nashville, Tennessee to determine 
stakeholders' assessment of USDA's efforts. 

To determine the progress that USDA, the Environmental Protection 
Agency (EPA), and others have made in developing, testing, and 
licensing fungicides to treat ASR and in identifying and breeding ASR- 
resistant or -tolerant soybeans, we interviewed officials from EPA and 
state departments of agriculture to obtain information about their 
efforts to license fungicides to treat ASR. In addition, we asked about 
the adequacy of fungicide supplies and equipment when surveying the 31 
soybean-producing states that were included in USDA's sentinel plot 
program. We interviewed Agricultural Research Service personnel as well 
as researchers from academia and industry and reviewed related reports 
and studies regarding efforts to research fungicide efficacy and 
identify and breed ASR-resistant or -tolerant soybeans. We also toured 
USDA research facilities at Ft. Detrick, Maryland. 

We conducted our work between May 2005 and January 2006 in accordance 
with generally accepted government auditing standards. 

[End of section] 

Appendix II: Results of GAO's Survey of Soybean-Producing States: 

[See PDF for image] 

[End of figure] 

[End of section] 

Appendix III: 2005 Sentinel Plots and Soybean Acreage: 

State: Alabama; 
Soybean acres planted: 150,000; 
USDA sentinel plots: 10; 
Other sentinel plots[A]: 25. 

State: Arkansas; 
Soybean acres planted: 3,030,000; 
USDA sentinel plots: 25; 
Other sentinel plots[A]: 37. 

State: Delaware; 
Soybean acres planted: 185,000; 
USDA sentinel plots: 6; 
Other sentinel plots[A]: 44. 

State: Florida; 
Soybean acres planted: 11,000; 
USDA sentinel plots: 15; 
Other sentinel plots[A]: 11. 

State: Georgia; 
Soybean acres planted: 180,000; 
USDA sentinel plots: 10; 
Other sentinel plots[A]: 15. 

State: Illinois; 
Soybean acres planted: 9,500,000; 
USDA sentinel plots: 10; 
Other sentinel plots[A]: 30. 

State: Indiana; 
Soybean acres planted: 5,400,000; 
USDA sentinel plots: 9; 
Other sentinel plots[A]: 8. 

State: Iowa; 
Soybean acres planted: 10,100,000; 
USDA sentinel plots: 10; 
Other sentinel plots[A]: 20. 

State: Kansas; 
Soybean acres planted: 2,900,000; 
USDA sentinel plots: 10; 
Other sentinel plots[A]: 20. 

State: Kentucky; 
Soybean acres planted: 1,260,000; 
USDA sentinel plots: 10; 
Other sentinel plots[A]: 37. 

State: Louisiana; 
Soybean acres planted: 880,000; 
USDA sentinel plots: 15; 
Other sentinel plots[A]: 50. 

State: Maryland; 
Soybean acres planted: 480,000; 
USDA sentinel plots: 5; 
Other sentinel plots[A]: 28. 

State: Michigan; 
Soybean acres planted: 2,000,000; 
USDA sentinel plots: 10; 
Other sentinel plots[A]: 20. 

State: Minnesota; 
Soybean acres planted: 6,900,000; 
USDA sentinel plots: 10; 
Other sentinel plots[A]: 26. 

State: Mississippi; 
Soybean acres planted: 1,600,000; 
USDA sentinel plots: 24; 
Other sentinel plots[A]: 38. 

State: Missouri; 
Soybean acres planted: 5,000,000; 
USDA sentinel plots: 16; 
Other sentinel plots[A]: 23. 

State: Nebraska; 
Soybean acres planted: 4,700,000; 
USDA sentinel plots: 10; 
Other sentinel plots[A]: 38. 

State: New Jersey; 
Soybean acres planted: 95,000; 
USDA sentinel plots: 5; 
Other sentinel plots[A]: 62. 

State: New York; 
Soybean acres planted: 190,000; 
USDA sentinel plots: 10; 
Other sentinel plots[A]: 0. 

State: North Carolina; 
Soybean acres planted: 1,500,000; 
USDA sentinel plots: 10; 
Other sentinel plots[A]: 17. 

State: North Dakota; 
Soybean acres planted: 3,000,000; 
USDA sentinel plots: 10; 
Other sentinel plots[A]: 16. 

State: Ohio; 
Soybean acres planted: 4,500,000; 
USDA sentinel plots: 10; 
Other sentinel plots[A]: 35. 

State: Oklahoma; 
Soybean acres planted: 320,000; 
USDA sentinel plots: 5; 
Other sentinel plots[A]: 0. 

State: Pennsylvania; 
Soybean acres planted: 440,000; 
USDA sentinel plots: 5; 
Other sentinel plots[A]: 10. 

State: South Carolina; 
Soybean acres planted: 430,000; 
USDA sentinel plots: 11; 
Other sentinel plots[A]: 0. 

State: South Dakota; 
Soybean acres planted: 3,900,000; 
USDA sentinel plots: 10; 
Other sentinel plots[A]: 30. 

State: Tennessee; 
Soybean acres planted: 1,130,000; 
USDA sentinel plots: 25; 
Other sentinel plots[A]: 5. 

State: Texas; 
Soybean acres planted: 260,000; 
USDA sentinel plots: 5; 
Other sentinel plots[A]: 5. 

State: Virginia; 
Soybean acres planted: 530,000; 
USDA sentinel plots: 5; 
Other sentinel plots[A]: 51. 

State: West Virginia; 
Soybean acres planted: 19,000; 
USDA sentinel plots: 5; 
Other sentinel plots[A]: 0. 

State: Wisconsin; 
Soybean acres planted: 1,610,000; 
USDA sentinel plots: 10; 
Other sentinel plots[A]: 10. 

State: Total; 
Soybean acres planted: 72,200,000; 
USDA sentinel plots: 331; 
Other sentinel plots[A]: 711. 

Source: GAO survey of soybean-producing states, USDA acreage data. 

[A] Other sentinel plots were funded or sponsored by state government, 
the North Central Soybean Research Program, or other grants. 

[End of table] 

[End of section] 

Appendix IV: Approved Fungicides for Treating Soybeans for ASR: 

Table 2: Fungicides Approved by EPA for Treating ASR on Soybeans, as of 
December 31, 2005: 

Fungicide (Trade name): Quadris; 
Active ingredients: Azoxystrobin; 
Class of chemicals: Strobilurin; 
Major properties: Preventative; 
Type of label: Section 3; 
Date first approved[A]: 4/10/03. 

Fungicide (Trade name): Pristine; 
Active ingredients: Boscalid & Pyraclostrobin; 
Class of chemicals: Carboxamide & Strobilurin; 
Major properties: Preventative; 
Type of label: Section 3; 
Date first approved[A]: 3/16/05. 

Fungicide (Trade name): Bravo Weather Stik; 
Active ingredients: Chlorothalonil; 
Class of chemicals: Chloronitrile; 
Major properties: Preventative; 
Type of label: Section 3; 
Date first approved[A]: 11/8/02. 

Fungicide (Trade name): Echo 720; 
Active ingredients: Chlorothalonil; 
Class of chemicals: Chloronitrile; 
Major properties: Preventative; 
Type of label: Section 3; 
Date first approved[A]: 6/17/03. 

Fungicide (Trade name): Echo 90DF; 
Active ingredients: Chlorothalonil; 
Class of chemicals: Chloronitrile; 
Major properties: Preventative; 
Type of label: Section 3; 
Date first approved[A]: 6/17/03. 

Fungicide (Trade name): EQUUS 720 SST; 
Active ingredients: Chlorothalonil; 
Class of chemicals: Chloronitrile; 
Major properties: Preventative; 
Type of label: Section 3; 
Date first approved[A]: 7/15/04. 

Fungicide (Trade name): EQUUS DF; 
Active ingredients: Chlorothalonil; 
Class of chemicals: Chloronitrile; 
Major properties: Preventative; 
Type of label: Section 3; 
Date first approved[A]: 7/15/04. 

Fungicide (Trade name): Headline; 
Active ingredients: Pyraclostrobin; 
Class of chemicals: Strobilurin; 
Major properties: Preventative; 
Type of label: Section 3; 
Date first approved[A]: 11/30/04. 

Fungicide (Trade name): Tilt; 
Active ingredients: Propiconazole; 
Class of chemicals: Triazole; 
Major properties: Curative; 
Type of label: Section 18; 
Date first approved[A]: 4/23/04; 
Date tolerance level approved: 7/27/05; 
Date expires: 11/10/07. 

Fungicide (Trade name): Propimax; 
Active ingredients: Propiconazole; 
Class of chemicals: Triazole; 
Major properties: Curative; 
Type of label: Section 18; 
Date first approved[A]: 4/23/04; 
Date tolerance level approved: 7/27/05; 
Date expires: 11/10/07. 

Fungicide (Trade name): Bumper; 
Active ingredients: Propiconazole; 
Class of chemicals: Triazole; 
Major properties: Curative; 
Type of label: Section 18; 
Date first approved[A]: 4/23/04; 
Date tolerance level approved: 7/27/05; 
Date expires: 11/10/07. 

Fungicide (Trade name): Folicur 3.6F; 
Active ingredients: Tebuconazole; 
Class of chemicals: Triazole; 
Major properties: Curative; 
Type of label: Section 18; 
Date first approved[A]: 7/20/04; 
Date tolerance level approved: 8/4/05; 
Date expires: 11/10/07. 

Fungicide (Trade name): Orius 3.6F; 
Active ingredients: Tebuconazole; 
Class of chemicals: Triazole; 
Major properties: Curative; 
Type of label: Section 18; 
Date first approved[A]: 4/21/05; 
Date tolerance level approved: 8/4/05; 
Date expires: 11/10/07. 

Fungicide (Trade name): Uppercut; 
Active ingredients: Tebuconazole; 
Class of chemicals: Triazole; 
Major properties: Curative; 
Type of label: Section 18; 
Date first approved[A]: 6/30/05; 
Date tolerance level approved: 8/4/05; 
Date expires: 11/10/07. 

Fungicide (Trade name): Laredo EC; 
Active ingredients: Myclobutanil; 
Class of chemicals: Triazole; 
Major properties: Curative; 
Type of label: Section 18; 
Date first approved[A]: 3/25/04; 
Date tolerance level approved: 8/24/05; 
Date expires: 11/10/07. 

Fungicide (Trade name): Laredo EW; 
Active ingredients: Myclobutanil; 
Class of chemicals: Triazole; 
Major properties: Curative; 
Type of label: Section 18; 
Date first approved[A]: 3/25/04; 
Date tolerance level approved: 8/24/05; 
Date expires: 11/10/07. 

Fungicide (Trade name): Stratego; 
Active ingredients: Propiconazole & Trifloxystrobin; 
Class of chemicals: Triazole & Strobilurin; 
Major properties: Curative and preventative; 
Type of label: Section 18; 
Date first approved[A]: 12/13/04; 
Date tolerance level approved: 6/24/05; 7/27/05; 
Date expires: 11/10/07. 

Fungicide (Trade name): Domark 230 ME; 
Active ingredients: Tetraconazole; 
Class of chemicals: Triazole; 
Major properties: Curative; 
Type of label: Section 18; 
Date first approved[A]: 3/2/05; 
Date tolerance level approved: 6/1/05; 
Date expires: 11/10/07. 

Fungicide (Trade name): Quilt; 
Active ingredients: Propiconazole & Azoxystrobin; 
Class of chemicals: Triazole & Strobilurin; 
Major properties: Curative and preventative; 
Type of label: Section 18; 
Date first approved[A]: 3/28/05; 
Date tolerance level approved: 7/27/05; 
Date expires: 11/10/07. 

Fungicide (Trade name): Headline SBR; 
Active ingredients: Tebuconazole & Pyraclostrobin; 
Class of chemicals: Triazole & Strobilurin; 
Major properties: Curative and preventative; 
Type of label: Section 18; 
Date first approved[A]: 3/28/05; 
Date tolerance level approved: 8/4/05; 
Date expires: 11/10/07. 

Source: EPA. 

[A] For some Section 3 products, this is the date fungicide 
manufacturers notified EPA that Asian soybean rust was added to the 
label as a treatable pest. 

[End of table] 

Table 3: Section 18 Fungicides Approved for ASR and States Where 
Approved, as of December 31, 2005: 

Fungicide: Tilt, Propimax, Bumper; 
States with approved Section 18 requests: AL, AR, CO, DE, FL, GA, IA, 
IL, IN, KS, KY, LA, MD, MI, MN, MO, MS, NC, ND, NE, NJ, NY, OH, OK, PA, 
SC, SD, TN, TX, VA, VT, WV, WI. 

Fungicide: Folicur 3.6F; 
States with approved Section 18 requests: AL, AR, CO, DE, FL, GA, IA, 
IL, IN, KS, KY, LA, MD, MI, MN, MO, MS, NC, ND, NE, NJ, NY, OH, OK, PA, 
SC, SD, TN, TX, VA, VT, WV, WI. 

Fungicide: Orius 3.6F; 
States with approved Section 18 requests: AL, AR, CO, DE, FL, GA, IA, 
IL, IN, KS, KY, LA, MD, MI, MN, MO, MS, NC, ND, NE, NJ, NY, OH, OK, PA, 
SC, SD, TN, TX, VA, VT, WV. 

Fungicide: Uppercut; 
States with approved Section 18 requests: AR, DE, IA, IL, IN, KY, MD, 
MN, MO, MS, NC, NE, OH, SC, TN, VA. 

Fungicide: Laredo EC, Laredo EW; 
States with approved Section 18 requests: AL, AR, CO, DE, FL, GA, IA, 
IL, IN, KS, KY, LA, MD, MI, MN, MO, MS, NC, ND, NE, NJ , NY, OH, OK, 
PA, SC, SD, TN, TX, VA, VT, WV, WI. 

Fungicide: Stratego; 
States with approved Section 18 requests: AL, AR, CO, DE, FL, GA, IA, 
IL, IN, KS, KY, LA, MD, MI, MN, MO, MS, NC, ND, NE, NJ, NY, OH, OK, PA, 
SC, SD, TX, VA, TN, VT, WV, WI. 

Fungicide: Domark 230 ME; 
States with approved Section 18 requests: AL, AR, DE, GA, IA, IL, IN, 
KS, KY, LA, MD, MI, MN, MO, MS, NC, ND, NE, NJ, NY, OH, OK, PA, SC, SD, 
TN, TX, VA, VT, WV, WI. 

Fungicide: Quilt; 
States with approved Section 18 requests: AL, AR, CO, DE, FL, GA, IA, 
IL, IN, KS, KY, LA, MD, MI, MN, MO, MS, NC, ND, NE, NJ, NY, OH, OK, PA, 
SC, SD, TN, TX, VA, VT, WV, WI. 

Fungicide: Headline SBR; 
States with approved Section 18 requests: AL, AR, CO, DE, FL, GA, IA, 
IL, IN, KS, KY, LA, MD, MI, MN, MO, MS, NC, ND, NE, NJ, NY, OH, OK, PA, 
SC, SD, TN, TX, VA, VT, WV, WI. 

Source: EPA. 

[End of table] 

[End of section] 

Appendix V: Progression of ASR during the 2005 Growing Season: 

[See PDF for image] 

[End of figure] 

[End of section] 

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

USDA: 

United States Department of Agriculture: 
Office of the Secretary: 
Washington, D.C. 20250: 

FEB 15 2006: 

Mr. Dan Bertoni: 
Acting Director: 
Natural Resources and Environment: 
United States Government Accountability Office: 
Washington, D.C. 20548: 

Dear Mr. Bertoni: 

The U.S. Department of Agriculture (USDA) has reviewed the Government 
Accountability Office's (GAO) draft report, "Agriculture Production: 
USDA Needs to Build on 2005 Experience to Minimize the Effects of Asian 
Soybean Rust in the Future" (GAO-06-337). We appreciate the opportunity 
to review this document and are developing ways to address its 
recommendations. 

We have found that the report fairly describes USDA's preparations 
related to ASR and that both of the report's recommendations reflect 
our ongoing cooperative efforts with various States to combat this 
disease. We will continue to provide additional guidance to our State 
cooperators to facilitate the collection of the best possible 
monitoring information during 2006. We also agree that our continued 
actions will be best served through the detailed transition plan that 
is currently under development with our State cooperators to further 
ensure strong leadership in predicting and limiting the spread of ASR. 
To these ends, we provide the following comments and observations based 
on our review of the draft document provided to USDA. 

In its report, GAO appropriately recognizes that multiple USDA agencies 
and offices have been working to prepare for the onset of ASR. These 
agencies include the Agricultural Marketing Service; the Agricultural 
Research Service; the Animal and Plant Health Inspection Service; the 
Cooperative State Research, Education, and Extension Service; the 
Foreign Agricultural Service; the Farm Service Agency; the Economic 
Research Service; the Natural Resources Conservation Service; the 
Office of Communications; the Office of Homeland Security; the Office 
of Pest Management Policy; and the Risk Management Agency. 

Research to identify the virulence of P. pachyrhizi as well as 
potential crop resistance has been conducted by the Agricultural 
Research Service since the 1980's. Since 2002, the other agencies 
listed above have also been actively working to initially exclude the 
disease organism, to prepare for its eventual arrival by training field 
personnel around the country to recognize the disease, and to plan for 
a national response once ASR was discovered in the continental United 
States. 

A central theme of the GAO report is a focus on the lack of uniformity 
in the responses provided by each of the approximately 30 States 
cooperating in the ASR response. During 2005, specific guidance was 
provided in the mechanism for collecting and reporting observations 
from the sentinel plot system. Once the initial detection was confirmed 
by USDA, States did exercise latitude in their implementation of 
diagnostic techniques and in their frequency of providing management 
information for entry into the system. 

GAO correctly reports that States varied in their level of response 
(e.g. frequency of reporting), but those States in which the disease 
was found provided information on a timely basis to inform the State 
specialists and the USDA data collection/modeling system. As the 
principal information collected from sentinel plots is the presence or 
absence of ASR at any given point during the season, there is always a 
tradeoff between the frequency of making observations and the cost of 
conducting an individual trial. 

It is the position of USDA that most States did provide information in 
a timely and accurate fashion. For example, States reported their 
observations based on the (a) growth stage and (b) potential 
susceptibility of host plants based on their proximity to known areas 
of ASR infection. Six States (i.e. Colorado, Iowa, Missouri, Ohio, 
Washington, and Wisconsin) reported fewer than seven times during the 
season. States that reported several times weekly were much closer to 
or actually comprised the infected areas (e.g. Alabama, Florida, 
Georgia, Mississippi, and South Carolina). Lessons learned from the 
diversity of these individual responses will be considered carefully 
during the implementation of the 2006 sentinel plot program. 

Training on the visual detection of ASR was provided to more than 
15,000 individuals prior to the 2005 growing season. To a trained 
diagnostician, visual identification of ASR in the field can be quite 
straightforward if the pathogen is sporulating, but USDA also 
implemented standardized procedures to confirm first-find diagnoses in 
2005-including microscopic examination and testing using the validated 
real-time polymerase chain reaction test. 

Additional molecular and biochemical identification techniques were 
available, and State diagnosticians had latitude to determine the 
techniques they believed were appropriate to use in processing samples 
from sentinel plots and producers' fields during 2005. Guidelines for 
diagnostic labs regarding screening procedures are being refined based 
on USDA's experience in 2005 and as new technologies become available 
that may allow earlier detection of infection (e.g. before 
sporulation). We would like to note, however, that the use of different 
diagnostic techniques by various States is not a shortcoming; rather, 
it reflects flexibility in providing a local response subject to 
availability of resources and skilled personnel as well as the volume 
of samples that a diagnostic facility may anticipate. USDA is working 
with the National Plant Diagnostic Network in modifying standard 
operating procedures based on experience gained during the 2005 season. 

With regard to the modeling employed by USDA to predict the movement of 
ASR, these models integrate weather data, disease incidence reports, 
crop growth stage, and plant disease development information in order 
to derive estimates of where the disease may emerge. Much experience 
gained from other plant disease modeling has been incorporated into the 
techniques utilized by USDA to anticipate movement of ASR. The 
availability and use of other models, supported or developed in part by 
funding from USDA, is viewed as an asset in providing predictive 
information to the ASR specialists. 

With guidance from its Risk Management Agency, USDA has placed 
increased emphasis on good farming practices for combating ASR and has 
posted management information on the USDA website. In combating ASR, 
soybean growers are required to carry out good farming practices in 
order to receive crop insurance indemnities that may result from 
soybean rust. The guidance provided through the website by State and 
local Cooperative Extension System personnel was based on local ASR 
observations through the monitoring effort. This interaction between 
State and Federal authorities and local soybean growers reduced 
fungicide inputs, increased the effectiveness of preventative and 
curative fungicide applications, and provided growers with 
documentation necessary to prove their use of good farming practices. 

Since May 2005, efforts have been underway at USDA to provide the 
framework for the ASR response in 2006. The State and Federal 
cooperative framework established in response to ASR will continue, 
with the notable change that funding for the State sentinel plot 
program will be provided through the Southern Regional Integrated Pest 
Management Center at North Carolina State University rather than 
directly from USDA's Animal and Plant Health Inspection Service. A 
written plan outlining the elements of this program has been developed 
and is being finalized in conjunction with the States that are 
cooperating in the 2006 ASR response. As the establishment and 
management of the plots previously has been conducted primarily through 
the land-grant universities in most of the affected States, USDA's 
Cooperative State Research, Education, and Extension Service will 
oversee the ASR response in 2006. This change is not intended to alter 
the USDA commitment to a national ASR response; rather, it more 
accurately reflects the coordinated management and funding mechanisms 
to be employed in 2006. 

Again, I appreciate the opportunity to comment on the draft report. The 
document is informative and thorough, and I hope that our observations 
prove useful in helping others to better understand USDA's role in 
combating ASR. 

Sincerely, 

Signed by: 

Mike Johanns: 
Secretary: 

Appendix VII: GAO Contacts and Staff Acknowledgments: 

GAO Contacts: 

Daniel Bertoni (202) 512-3841 or [Hyperlink, bertonid@gao.gov]: 

Staff Acknowledgments: 

In addition to the contact named above, Ronald E. Maxon, Jr., Assistant 
Director; James L. Dishmon, Jr; Chad M. Gorman; Lynn M. Musser; Deborah 
S. Ortega; Paul J. Pansini; Carol Herrnstadt Shulman; and Amy E. 
Webbink made key contributions to this report. 

[End of section] 

Related GAO Products: 

Agriculture Production: USDA's Preparation for Asian Soybean Rust. 
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-05-668R]. Washington, 
D.C.: May 17, 2005. 

(360535): 

FOOTNOTES 

[1] ASR can infect over 90 host plant species, including legumes, such 
as dry beans, peas, and kudzu. 

[2] GAO, Agriculture Production: USDA's Preparation for Asian Soybean 
Rust, GAO-05-668R (Washington, D.C.: May 17, 2005). 

[3] Pub. L. No. 92-516, § 18 (1972) (codified at 7 U.S.C. § 136 p.) 

[4] In addition to steps taken as part of USDA's coordinated framework, 
unavoidable crop losses due to ASR are covered under the federal crop 
insurance program administered by USDA's Risk Management Agency (RMA). 
As of December 31, 2005, no one had filed a claim for crop loss from 
ASR. 

[5] Six states did not express a view on the effectiveness of the 
sentinel plot program. 

[6] Five of these plots were located in Puerto Rico. 

[7] According to USDA officials, USDA provided more money per plot 
because it funded the "infrastructure" for the sentinel plot network, 
which included transportation expenses and equipment, in addition to 
salaries for personnel to monitor the plots and, in some cases, the 
rental of farmland to maintain them. 

[8] Other plots included those funded by the North Central Soybean 
Research Program, the United Soybean Board, state governments, or other 
grants; plots not monitored by state officials, such as those sponsored 
by private industry, are not included in this total. 

[9] The information from this restricted Web site is used to provide 
information for the public Web site. 

[10] North Central Soybean Research Program and USDA Protocol for 
Soybean Rust Sentinel Plots, updated April 7, 2005, and August 23, 
2005. 

[11] In the PCR test, Deoxyribonucleic acid (DNA) is extracted from 
spores or infected leaf samples, subjected to PCR, and then ground and 
purified before being analyzed for the presence of key diagnostic 
sequences of DNA that distinguish ASR from related species. The ELISA 
test, which is conducted similarly, requires about 2 hours and is the 
first commercial rapid kit available to detect soybean rust in plant 
tissue. Although ELISA is capable of detecting soybean rust at a very 
early stage, unlike the PCR test, USDA officials were uncertain whether 
it can distinguish between ASR and other types of rust. 

[12] Officials in the remaining two states that we surveyed indicated 
that they received no samples suspected of ASR during 2005. 

[13] This technique is still experimental. 

[14] In addition to the monitoring plan laid out in the framework, 
industry distributed various types of "spore traps" to collect spore 
samples in the air. Researchers hoped that these traps would allow them 
to detect the presence of ASR spores before the disease had spread to 
soybean fields. However, because the traps did not collect enough 
spores for testing and because ASR and other rust spores are similar in 
appearance, USDA issued a position statement in August 2005, stating 
that many challenges and questions need to be resolved before spore 
data can be used most effectively. 

[15] http://www.sbrusa.net/. 

[16] Although ASR was confirmed in another four states, it was detected 
late in the growing season, making a recommendation unnecessary. 

[17] USDA's model was developed by Pennsylvania State University, North 
Carolina State University, and ZedX, Inc., an information technology 
company. 

[18] CSREES' mission is to advance knowledge for agriculture, the 
environment, human health and well-being, and communities by supporting 
research, education, and extension programs in the Land-Grant 
University System and other partner organizations. 

[19] CSREES transferred responsibility to SRIPMC because it had 
available staff and office space and was located in the South where ASR 
was present during 2005. 

[20] USDA's RMA will fund this effort in 2006 as part of an initiative 
to develop a broader system. According to RMA, this effort is aimed at 
providing a mechanism to educate farmers about risk-management 
strategies and providing timely information about good farming 
practices specific to current crop pest and disease status--ASR and 
others. 

[21] Thirty-three states, including the 31 soybean-producing states 
participating in USDA's sentinel plot program, have received emergency 
exemptions to use some or all of these fungicides. 

[22] These fungicides are classified as triazoles, which have some 
preventative properties. 

[23] Several of the pesticides for which emergency exemptions have been 
granted are under consideration at EPA for registration for use on 
soybeans. The science and regulatory evaluations on certain of the 
currently authorized section 18 products and other fungicides proposed 
by their manufacturer for control of ASR may be completed prior to the 
expiration date for the emergency exemptions. 

[24] In early 2004, USDA met with state and federal officials to begin 
making plans for exemptions to use fungicides to treat other leguminous 
crops, such as peas and lima beans, but they did not begin working to 
develop them with EPA until December 2004. Although EPA also allowed 
Florida and Tennessee to prepare a joint request for emergency 
exemptions to use fungicides to treat ASR on other leguminous crops, as 
of December 31, 2005, no states had been approved for these exemptions. 

[25] USDA conducts its research efforts primarily through its 
Agricultural Research Service. 

[26] The United Soybean Board is a marketing and research organization 
supported by soybean growers through a levy on their sales. 

[27] Private companies often only study their own products, or they do 
not release comparative data to the public. 

[28] http://www.ipmcenters.org/NewsAlerts/soybeanrust/efficacy.cfm. 

[29] EPA may consider marketing or promotion of an exempted pesticide 
for uses other than those approved in the emergency exemption to be 
illegal. 40 C.F.R. § 168.22. 

[30] Germplasm is the hereditary material in plant cells. 

[31] Miles, M.R; Frederick, R.D; and Hartman, G.L., 2006. Evaluation of 
soybean germplasm for resistance to Phakopsora pachyrhizi. Online. 
Plant Health Progress doi: 10.1094/PHP-2006-0104-01-RS. 

[32] USDA is currently still trying to identify all of the strains of 
ASR. 

[33] 70 Fed. Reg. 13242 (March 2005). 

[34] Epidemiology includes the incidence, distribution, and control of 
a disease. 

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