---

EXTRACT - see below: ".... Importantly, the tools can detect disease before the animal shows clinical signs of infection...... rapid diagnostic tools would not only allow for a rapid diagnosis but would also permit the monitoring of nearby herds before symptoms appeared so that only infected herds would have to be killed......rapid diagnostic tools would be helpful because FMD would be detected in less than an hour, informed control measures could be implemented, and herds in the area would be under regular surveillance."

 

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Report to Congressional Requesters

:

March 2005:

Homeland Security:

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

GAO-05-214:

GAO Highlights:

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

Why GAO Did This Study:

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

What GAO Found:

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

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

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

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

What GAO Recommends:

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

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

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

[End of section]

Contents:

Letter:

Results in Brief:

Background:

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

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

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

Conclusions:

Recommendations for Executive Action:

Agency Comments and Our Response:

Appendixes:

Appendix I: Scope and Methodology:

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

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

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

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

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

GAO Comments:

Appendix VII: Comments from the Department of Homeland Security:

GAO Comments:

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

Appendix IX: GAO Contacts and Staff Acknowledgments:

GAO Contacts:

Acknowledgments:

Related GAO Products:

Tables:

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

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

Figures:

Figure 1: Top Hog-Producing States in 2002:

Figure 2: Top Soybean-Producing States in 2002:

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

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

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

Figure 6: Top Cattle-Producing States in 2002:

Figure 7: Top Chicken-Producing States in 2002:

Figure 8: Top Corn-Producing States in 2002:

Abbreviations:

APHIS: Animal Plant Health Inspection Service:

ARS: Agricultural Research Service:

CBP: Customs and Border Protection:

CDC: Centers for Disease Control and Prevention:

DHS: Department of Homeland Security:

DOD: Department of Defense:

EPA: Environmental Protection Agency:

FDA: Food and Drug Administration:

FEMA: Federal Emergency Management Agency:

FMD: foot and mouth disease:

GAO: Government Accountability Office:

HHS: Health and Human Services:

HSPD: Homeland Security Presidential Directive:

NVSL: National Veterinary Services Laboratories:

OIE: Office Internationale des Epizooties:

PPQ: Plant Protection and Quarantine:

USDA: United States Department of Agriculture:

Letter March 8, 2005:

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

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

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

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

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

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

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

Results in Brief:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Background:

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

Figure 1: Top Hog-Producing States in 2002:

[See PDF for image]

Note: Three states did not disclose their information.

[End of figure]

Figure 2: Top Soybean-Producing States in 2002:

[See PDF for image]

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

[End of figure]

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

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

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

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

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

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

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

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

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

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

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

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

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

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

[See PDF for image]

[End of figure]

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

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

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

Presidential Directives Define Agency Responsibilities for Protecting against Agroterrorism:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

A Number of Agency-Specific Actions Are Under Way:

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

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

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

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

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

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

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

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

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

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

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

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

Many Veterinarians Lack Training in Foreign Animal Diseases:

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

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

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

USDA Does Not Use Rapid Diagnostic Tools on Site:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Federal Agencies Have Not Addressed Several Management Problems:

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

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

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

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

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

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

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

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

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

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

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

Fewer Inspectors Are Available to Help USDA Manage Agricultural Emergencies:

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

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

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

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

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

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

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

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

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

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

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

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

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

Agencies' Diagnostic Laboratory Networks Are Not Yet Integrated:

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

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

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

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

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

Conclusions:

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

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

Recommendations for Executive Action:

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

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

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

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

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

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

* the Secretaries of Homeland Security and Agriculture work together to identify the reasons for declining agricultural inspections and to ide