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Food and Drug Administration: Overseas Offices Have Taken Steps to Help Ensure Import Safety, but More Long-Term Planning Is Needed

GAO-10-960 Published: Sep 30, 2010. Publicly Released: Oct 25, 2010.
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An increasing volume of food and medical products marketed in the United States are produced in foreign countries. This globalization has challenged the Food and Drug Administration (FDA), which is responsible for ensuring the safety of these products. In late 2008 and early 2009, FDA established overseas offices comprised of 42 total staff covering particular countries or regions--China, Europe, India, Latin America, and the Middle East. The offices are to engage with foreign stakeholders to develop information that FDA officials can use to make better decisions about products manufactured in foreign countries, among other activities. GAO examined (1) the steps overseas offices have taken to help ensure the safety of imported products and (2) the extent to which FDA has engaged in long-term strategic and workforce planning for the overseas offices. GAO reviewed documentation of overseas office activities and planning. GAO also visited offices in China, India, and Latin America to interview FDA officials, officials from other U.S. agencies overseas, and foreign regulators and other stakeholders.

FDA's overseas offices have engaged in a variety of activities to help ensure the safety of imported products, but officials report challenges that could limit their effectiveness, due to an increasing workload and other factors. A primary activity for the offices has been establishing relationships with foreign stakeholders (such as foreign regulators and industry) and U.S. agencies overseas. FDA officials and foreign stakeholders said they had limited contact prior to the opening of the offices, and each noted that the overseas offices are beneficial for relationship building, although relationship building can be time consuming. FDA overseas officials have also gathered information about regulated products and shared it with U.S. officials to assist with decision making. Although FDA has used some of this information to take regulatory actions, some FDA overseas officials told us that they lack feedback regarding the utility of much of the information that they submit to the agency. FDA's offices in China and India include investigators who inspect foreign establishments. In these two countries, as of June 2010, the overseas investigators conducted 48 inspections since they were posted overseas. The FDA overseas officials have also started to provide training, responses to queries, and other assistance to foreign stakeholders to help them improve their regulatory systems and better understand FDA regulations. These officials said, however, that an increasing interest in this type of assistance from foreign stakeholders, while important, could lead to an unmanageable workload. Although FDA staff and others have pointed to several immediate benefits of the offices, it is early and their impact on the safety of imported products is not yet clear. FDA is in the process of long-term strategic planning for the overseas offices and has not developed a long-term workforce plan. FDA expects to complete a 5-year strategic plan to manage office activities by October 2010. Officials said that they intend to include performance goals and measures for the offices in the strategic plan, but that it will be difficult to quantify office contributions toward long-term outcomes. Also, coordination of the overseas offices with other parts of FDA has been a challenge, and strategic planning efforts can help ensure this coordination. FDA has not yet developed a long-term workforce plan to help ensure that it is prepared to address potential overseas office staffing challenges. Overseas staff agree to 2-year rotations, and workforce planning has focused on preparing to fill any 2011 vacancies. FDA has experienced challenges staffing some office locations and officials from FDA and other agencies with overseas staff have identified potential recruitment and retention challenges that could affect FDA's mission. They said that recruiting staff with language skills and reintegrating returning staff into domestic operations may be difficult. Certain FDA staff experienced a reduction in their pay when they went overseas. Workforce planning could help FDA prepare for potential staffing challenges. GAO recommends that the Commissioner of FDA take steps to enhance strategic planning to ensure coordination between overseas and domestic activities and develop a workforce plan to help recruit and retain overseas staff. FDA agreed with GAO's recommendations.


Recommendations for Executive Action

Agency Affected Recommendation Status
Food and Drug Administration To help ensure that FDA's overseas offices are able to fully meet their mission of helping to ensure the safety of imported products, the Commissioner of FDA should ensure, as it completes its strategic planning process for the overseas offices, that it develops a set of performance goals and measures that can be used to demonstrate overseas office contributions to long-term outcomes related to the regulation of imported products and that overseas office activities are coordinated with the centers and Office of Regulatory Affairs (ORA).
Open – Partially Addressed
In a June 2022 written response, FDA described multiple strategic planning efforts it was undertaking to demonstrate the contributions of the overseas offices to long-term outcomes of imported products and coordination with ORA. Of these, FDA provided supporting documentation that it has developed performance measures related to long-term outcomes of inspections conducted by overseas office staff, which it implemented as of March 2023. Specifically, these measures included targets and assessed the contribution of the offices toward helping FDA follow up on prior inspections that identified deficiencies. FDA indicated that the Office of Global Policy and Strategy (OGPS, formerly the Office of International Programs) selected these performance measures in collaboration with ORA to ensure they are in accordance with ORA's existing performance measures. In addition, FDA described efforts to track long-term outcomes unrelated to inspection activities, which it noted were inherently difficult to measure. FDA described the development of indicators and measures toward long-term goals, and noted that the effort was a collaboration between OGPS and the centers. In a June 2023 written response, FDA indicated that OGPS's strategic plan expanded to include several "focal areas" of work: drug safety, food safety, good regulatory practices, and medical devices. Within each focal area, the office had identified "desired future states," which are long-term desired goals. In October 2023, FDA provided drafts of these focal areas that included proposed measures, which indicated that they still needed to be discussed with the centers to ensure alignment. The development of these measures is a positive step. In May 2024, FDA indicated in a written response that the final measures are expected to be completed by end of fiscal year 2024. GAO will leave this recommendation open until FDA fully aligns these measures with the centers and finalizes them.
Food and Drug Administration To help ensure that FDA's overseas offices are able to fully meet their mission of helping to ensure the safety of imported products, the Commissioner of FDA should develop a strategic workforce plan for the overseas offices to help ensure that the agency is able to recruit and retain staff with the experience and skills necessary for the overseas offices and to reintegrate returning overseas staff into FDA's domestic operations.
Closed – Implemented
FDA finalized its strategic workforce plan in March 2016. The plan offers a strategic and long-term view of the issues facing the overseas offices and addresses the agency's plan to recruit, hire, retain, and develop employees with the skills and abilities to fulfill the agency's global mission, consistent with our recommendation. Among other things, it contains performance measures and a timeline for addressing its workforce planning challenges. It also includes key activities to be performed such as developing a hiring strategy, establishing a succession plan for anticipated vacancies, and working to maximize a returning foreign office employee's new skill set from his or her deployment. FDA's workforce plan also addresses reintegration challenges and determining how the agency can better leverage the skills staff develop while working abroad.

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Contaminated foodsDecision makingFederal regulationsFood inspectionFood safetyImportingInternational agreementsInternational relationsInternational tradeProduct safetySafety regulationStrategic planningForeign countriesProgram coordinationStakeholder consultations