oversight

Bioterrorism: A Threat to Agriculture and the Food Supply

Published by the Government Accountability Office on 2003-11-19.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                    United States General Accounting Office

GAO                 Testimony
                    Before the Committee on Governmental
                    Affairs, U.S. Senate


For Release on
Wednesday
November 19, 2003   BIOTERRORISM
                    A Threat to Agriculture and
                    the Food Supply
                    Statement for the Record by
                    Lawrence J. Dyckman, Director
                    Natural Resources and Environment




GAO-04-259T
                                                November 2003

                                                BIOTERRORISM

                                                A Threat to Agriculture and the Food
                                                Supply
 Highlights of GAO-04-259T, a Statement for
 the Record for the Committee on
 Governmental Affairs, U.S. Senate




 When the President created the                 Bioterrorism attacks could be directed at many different targets in the farm-
 Department of Homeland Security,               to-table food continuum, including crops, livestock, food products in the
 he included U.S. agriculture and               processing and distribution chain, wholesale and retail facilities, storage
 food industries in the list of critical        facilities, transportation, and food and agriculture research laboratories.
 infrastructures needing protection.            Experts believe that terrorists would attack livestock and crops if their
 The Secretaries of Agriculture and             primary intent was to cause severe economic dislocation. The U.S.
 of Health and Human Services have              agriculture sector accounts for about 13 percent of the gross domestic
 publicly declared that the U.S. food           product and 18 percent of domestic employment. Terrorists may decide to
 supply is susceptible to deliberate            contaminate finished food products if harm to humans was their motive.
 contamination. GAO was asked to
 provide an overview of the potential
 vulnerabilities of the food supply             Four recent GAO reports found gaps in federal controls for protecting
 and agriculture sector to deliberate           agriculture and the food supply. Thus, the United States would be
 contamination and to summarize                 vulnerable to deliberate efforts to undermine its agriculture industries,
 four recent GAO reports that                   deliberate tampering of food during production, and the release of deadly
 identified problems with federal               animal diseases, some of which also affect humans. GAO found, for
 oversight that could leave the                 example, border inspectors were not provided guidance on foot-and-mouth
 nation’s agriculture and food supply           disease prevention activities in response to the 2001 European outbreak,
 vulnerable to deliberate                       inspection resources could not handle the magnitude of international
 contamination.                                 passengers and cargo, and new technology used to scan shipments at a bulk
                                                mail facility was operating only part-time and in only that facility. Such
                                                careful controls over imported foods can help to prevent pathogens from
 The four GAO reports included                  contaminating U.S. cattle with devastating diseases that have struck many
 recommendations to (1) the U.S.                other countries. GAO also found that federal overseers did not have clear
 Department of Agriculture and the              authority to impose requirements on food processors to ensure security at
 Food and Drug Administration                   those facilities. Finally, GAO found security problems at Plum Island—a
 (FDA) to strengthen import checks              large government-operated animal disease research facility. GAO found that
 for detecting mad cow and foot-and-            scientists from other countries, facility workers, and students had access to
 mouth diseases and to address                  areas containing high-risk pathogens without having completed background
 security matters at food processors;           checks and the required escorts.
 (2) FDA to strengthen enforcement
 of the feed ban; and (3) the
 Department of Homeland Security                Following are the four reports discussed in this testimony:
 to correct security deficiencies at
 Plum Island. The agencies generally               •   Foot and Mouth Disease: To Protect U.S. Livestock, USDA Must
 agreed with GAO’s recommendations                     Remain Vigilant and Resolve Outstanding Issues, U.S. General
                                                       Accounting Office, GAO-02-808 (Washington, D.C.: July 26, 2002).
 and have taken, or are in the process
 of taking, actions to address the                 •   Mad Cow Disease: Improvements in the Animal Feed Ban and Other
 problems GAO found.                                   Regulatory Areas Would Strengthen U.S. Prevention Efforts, U.S.
                                                       General Accounting Office, GAO-02-183 (Washington, D.C.: January 25,
                                                       2002).
                                                   •   Food-Processing Security: Voluntary Efforts Are Under Way, but
                                                       Federal Agencies Cannot Fully Assess Their Implementation, U.S.
                                                       General Accounting Office, GAO-03-342 (Washington, D.C.: February 14,
www.gao.gov/cgi-bin/getrpt?GAO-04-259T                 2003).
To view the full statement, click on the link      •   Combating Bioterrorism: Actions Needed to Improve Security at Plum
above. For more information, contact                   Island Animal Disease Center, U.S. General Accounting Office, GAO-
Lawrence J. Dyckman at 202-512-3841or                  03-847 (Washington, D.C.: September 19, 2003).
dyckmanl@gao.gov.
          Madam Chairman and Members of the Committee:

          I appreciate the opportunity to submit this statement for the record on the
          results of our work on potential threats, vulnerabilities, and risks faced by
          the nation’s agriculture sector and its food supply. As you know,
          protecting the nation’s agriculture industries and food supply has taken on
          increased sense of urgency in the wake of the terrorist attacks of
          September 11, 2001. And there is now broad consensus that American
          farms, food, and agriculture systems, which account for about 13 percent
          of the nation’s gross domestic product, are vulnerable to potential attack
          and deliberate contamination.

          In his October 2001 executive order establishing the Office of Homeland
          Security, the President added agriculture and food industries to the list of
          critical infrastructure sectors needing protection—acknowledging that the
          agriculture sector and the food supply are indeed vulnerable to
          bioterrorism. Both the Secretaries of Agriculture and of Health and Human
          Services have also publicly recognized that the U.S. food supply is
          susceptible to deliberate contamination. Within this backdrop, federal and
          state government agencies; industry; and academic institutions have taken
          steps, such as, assessing the potential threats, risks, and vulnerabilities
          and developing plans to rapidly detect and respond to any attack on the
          nation’s agriculture sector and food supply.

          This statement (1) provides a brief overview of the potential vulnerabilities
          of the food supply and agriculture sector to deliberate contamination and
          (2) summarizes four recent GAO reports identifying a range of problems
          with federal oversight that could leave the nation’s agriculture sector and
          food supply vulnerable to intentional contamination. Included in this
          discussion are our 2002 reports on federal efforts to prevent devastating
          animal diseases—foot-and-mouth and bovine spongiform encephalopathy
          (BSE), also known as mad cow—from entering the United States, and our
          2003 reports on security at food-processing facilities and at the Plum
          Island Animal Disease Center. Plum Island studies serious animal diseases,
          including some that can cause illness and death in humans. The four
          reports are discussed in greater detail in appendix I, which also provides
          the link to each report on GAO’s Web page.


          The U.S. agriculture and food sectors have features that make them
Summary   vulnerable to bioterrorism attacks. These attacks could be directed at
          many different targets in the farm-to-table food continuum—including
          crops, livestock, food products in the processing and distribution chain,

          Page 2                               GAO-04-259T Threats to Agriculture and Food
wholesale and retail facilities, storage facilities, transportation, and food
and agriculture research laboratories. Indeed, chemicals and infectious
pathogens could be intentionally introduced at various points in that
continuum. Most experts believe that terrorists would choose to attack
livestock and crops if their primary intent was to cause severe economic
dislocation. Such an attack would cause severe disruption—the U.S.
agriculture sector accounts for about 13 percent of the U.S. gross domestic
product and 18 percent of domestic employment. On the other hand,
terrorists would choose to contaminate finished food products if harm to
humans was their motive.

Four recently issued GAO reports found gaps in federal controls for
protecting agriculture and the food supply. As a result of those gaps, the
United States would be vulnerable to deliberate efforts to undermine its
agriculture industries, intentional tampering of food during production,
and the release of deadly animal diseases, some of which also affect
humans. We found, among other things, that the volume of imported items
entering the United States made it impossible for border inspectors to
physically inspect every incoming cargo container or each and every
international passenger’s luggage—key pathways through which foot-and-
mouth disease could enter the country. We also found that new equipment
used to scan shipments at one large import bulk mail facility was operating
only part-time and in only that bulk mail facility. We also reported that
discrepancies in the accuracy of documents provided by the importer
posed a risk that BSE-contaminated food might not be flagged for further
inspection. Those careful controls over imported foods help prevent
pathogens from contaminating American cattle with devastating diseases
that have struck many other countries. In addition, we found that federal
overseers did not have clear authority to impose requirements on food
processors to ensure security at those facilities. And finally, we found
security problems at Plum Island. For example, several scientists from
other countries, facility workers, and students had access to areas
containing high-risk pathogens, even though their background checks
were incomplete and they did not have the required escorts.




Page 3                               GAO-04-259T Threats to Agriculture and Food
                        Our current agriculture and food sectors have features that make them
Overview of the         vulnerable to terrorist attacks. These include the high concentration of our
Vulnerability of the    livestock industry and the centralized nature of our food-processing
                        industry. As a result, chemicals and infectious pathogens can be
U.S. Agriculture        intentionally added at various points along the farm-to-table food
Sector and Food         continuum. Whether terrorists target food products or animals and crops
                        for deliberate contamination, serious public health and economic
Supply to Intentional   consequences are at stake. The mere threat of such an attack would
Contamination           seriously undermine consumer confidence in the safety of our food supply
                        and destabilize export markets.

                        The U.S. agriculture sector and food supply have been largely secure from
                        deliberate contamination, except for a few such incidents. In 1984, for
                        example, in what federal agencies describe as the first recorded event of
                        bioterrorism in the United States, a cult group poisoned salad bars at
                        several Oregon restaurants with Salmonella bacteria. As a result, 750
                        people became ill. A recent, deliberate food contamination also highlights
                        how easily someone intent on causing harm can do so. In January 2003,
                        the Centers for Disease Control and Prevention reported that 92 persons
                        became ill after purchasing ground beef from a Michigan supermarket that
                        was intentionally contaminated with nicotine. An employee of the
                        supermarket that sold the contaminated meat has been indicted for
                        intentionally poisoning 200 pounds of meat sold in his supermarket.

                        Naturally occurring outbreaks of diseases affecting livestock, as well as
                        accidental contamination of food, further illustrate the potentially horrific
                        effects of a deliberate and carefully choreographed event. For example,
                        the United Kingdom has estimated that its outbreak of foot-and-mouth
                        disease resulted in over $10 billion (U.S.) in losses to tourism and the food
                        and agriculture sectors and the slaughter of over 4 million animals.
                        Estimates of direct costs for a similar outbreak in the United States run as
                        high as $24 billion with the destruction of about 13 million animals.
                        Terrorists seeking ways to harm the United States could deliberately
                        introduce foreign animal diseases into the country. In addition, according
                        to a recent media report, the USDA calculated that a foot-and-mouth
                        disease outbreak could spread to 25 states in as little as 5 days.
                        Furthermore, according to the media report, a simulation exercise by the
                        National Defense University in June 2002 predicted that a foot-and-mouth
                        disease outbreak could spread to more than one-third of the nation’s cattle
                        herds. As that exercise demonstrated, diseases affecting livestock could
                        have significant impacts on the U.S. economy and consumer confidence in
                        the food supply.



                        Page 4                               GAO-04-259T Threats to Agriculture and Food
                        With regard to food, one large-scale U.S. foodborne illness outbreak in
                        1994 sickened 224,000 people nationwide with Salmonella enteritis from
                        eating a national brand of ice cream. That outbreak, though not deliberate
                        in nature, is estimated to have cost about $18.1 million in medical care and
                        time lost from work. Widely publicized illness outbreaks in 2002 resulted
                        in illnesses, deaths, and costly food recalls. One involved ground beef
                        produced by a plant in Colorado that caused at least 46 people in 16 states
                        to become ill from E. coli O157:H7. The plant conducted a recall to
                        remove about 18 million pounds of potentially contaminated beef that had
                        entered commerce. The other outbreak involved fresh and frozen ready-to-
                        eat turkey and chicken products. Those products, manufactured in a
                        Pennsylvania plant, carried Listeria monocytogenes, caused 46 illnesses in
                        eight states, as well as seven deaths and three stillbirths or miscarriages.
                        The plant recalled approximately 27.4 million pounds of potentially
                        contaminated poultry products that had entered commerce. However,
                        most foodborne illnesses are not reported and the vast majority of
                        foodborne outbreaks are never traced to a specific food source.


                        We recognize that the U.S. Department of Agriculture (USDA) and the
Recent GAO Reports      Food and Drug Administration (FDA)—the federal agencies with primary
Identified Weaknesses   responsibility for safeguarding our agriculture and food sectors—have
                        stepped up their prevention and response efforts. In addition, we
in U.S. Systems for     recognize the concerted efforts to better safeguard U.S. borders that have
Protecting Livestock    been taken over by the Department of Homeland Security, which also
                        recently took over the operation of the Plum Island Animal Research
and the Food Supply     Facility from USDA. Nevertheless, serious questions remain about whether
and Preventing the      the agriculture sector and the food supply are sufficiently prepared for
Release of Animal       deliberate acts of terrorism. Over the last 10 years, GAO has issued many
                        reports that, in aggregate, portray a national food safety system that is
Diseases that Present   fragmented and problem-laden. It is that system, however, on which the
Human Health Risks      nation must depend to prevent, prepare against, and respond to
                        bioterrorism events against our food supply.

                        Four recently issued GAO reports, in particular, identified weaknesses in
                        federal systems for protecting U.S. livestock against devastating animal
                        diseases and ensuring security at food-processing facilities and at Plum
                        Island—the nation’s principal diagnostics laboratory for foreign animal
                        diseases, including some that can transfer to humans. The information
                        from these four reports will not provide a comprehensive presentation of
                        potential risks; there are certainly other potential targets in the farm-to-
                        table food continuum, including the food transportation sector, that we
                        have not yet examined for vulnerability to intentional contamination.

                        Page 5                               GAO-04-259T Threats to Agriculture and Food
These reports do, nonetheless, highlight weaknesses in U.S. systems for
protecting critical agriculture and food safety sectors.

Two reports we issued in 2002—on foot-and-mouth disease and on mad
cow disease—examined, among other things, U.S. measures for preventing
those diseases from entering the United States.1 We found that, because of
the sheer magnitude of international passengers and cargo that enter this
country on a daily basis and the inspection resources that are available,
completely preventing the entry of those diseases may be infeasible. Foot-
and-mouth disease can be carried on the shoes of international passengers
and the packages they carry, in international mail, and in garbage from
international carriers. We found that USDA did not provide timely
guidance to border inspectors for screening cargo and international
passengers after foot-and-mouth disease struck Europe in 2001. We also
reported that only one international bulk mail facility used new scanning
equipment to help inspectors more accurately identify products potentially
carrying animal diseases that could contaminate U.S. cattle.

Our 2003 report on food-processing security noted that experts from
government and academia agreed that terrorists could use food products
as a vehicle for introducing harmful chemical or biological agents into the
food supply.2 We found that USDA and FDA had each, independently,
published comprehensive security guidelines for processors to help them
prevent or mitigate the risk of deliberate contamination at their facilities.
Additionally, we reported that USDA and FDA did not have clear authority
to require processors to take safety measures, such as installing fences,
alarms, or outside lighting. These measures could improve security in the
event of deliberate contamination. In addition, the field personnel at the
two agencies did not have adequate training on security matters, which
would hamper their ability to conduct informed discussion with
processing plant personnel.




1
Foot and Mouth Disease: To Protect U.S. Livestock, USDA Must Remain Vigilant and
Resolve Outstanding Issues, U.S. General Accounting Office, GAO-02-808 (Washington,
D.C.: July 26, 2002) and Mad Cow Disease: Improvements in the Animal Feed Ban and
Other Regulatory Areas Would Strengthen U.S. Prevention Efforts, U.S. General
Accounting Office, GAO-02-183 (Washington, D.C.: January 25, 2002).
2
 Food-Processing Security: Voluntary Efforts Are Under Way, but Federal Agencies
Cannot Fully Assess Their Implementation, U.S. General Accounting Office, GAO-03-342
(Washington, D.C.: February 14, 2003).



Page 6                                   GAO-04-259T Threats to Agriculture and Food
In September 2003, we also reported fundamental concerns with security
at the Plum Island Animal Disease Center that leave the facility vulnerable
to security breaches.3 We found that alarms and door sensors for the
biocontainment area were not fully operational; outdoor lighting was not
adequate to support security cameras; and certain assets, including the
foot-and-mouth disease vaccine bank, were not adequately protected.
Controls over access to the pathogens were also inadequate—scientists
from other countries were given access to the biocontainment area
without escorts while their background checks were incomplete; no
background checks were done on students attending classes in the
biocontainment area; and the cleaning crew were among the unauthorized
staff entering the biocontainment area unescorted. Controlling access to
pathogens is critical because a tiny quantity of pathogen could be removed
without being detected and developed into a weapon. Lastly, we found
that the security guards protecting the Island had been operating without
authority to carry firearms or to make arrests; the facility’s written plans
for responding to a terrorist incident exceeded the capability of its
security system and the emergency response plans were not adequately
coordinated with state and local emergency and law enforcement
responders. Our report noted that the Department of Homeland Security
officials agreed with our identification of these problems and stated that
they had initiated actions to address our concerns.

The four reports made recommendations to USDA, FDA, and the
Department of Homeland Security for correcting the problems we found,
and the agencies generally agreed with our recommendations. Appendix I
discusses the four reports, our recommendations, and the agencies’
positions in greater detail.




3
 Combating Bioterrorism: Actions Needed to Improve Security at Plum Island Animal
Disease Center, U.S. General Accounting Office, GAO-03-847 (Washington, D.C.: September
19, 2003).



Page 7                                   GAO-04-259T Threats to Agriculture and Food
                  For future contacts regarding this statement, please contact Lawrence J.
Contacts and      Dyckman at 202-512-3841. Individuals making key contributions to this
Acknowledgments   statement included Maria Cristina Gobin, Erin Lansburgh, Charles Adams,
                  and Clifford Diehl. This statement will also be available on the GAO Web
                  site at http://www.gao.gov.




                  Page 8                             GAO-04-259T Threats to Agriculture and Food
Appendix I: Recent GAO Reports Highlight
Gaps in Federal Efforts to Protect
Agriculture and the Food Supply
                 Four recently issued GAO reports identified weaknesses in federal
                 systems for protecting U.S. livestock against devastating animal diseases
                 and ensuring security at food-processing facilities and at Plum Island—the
                 nation’s principal diagnostics laboratory for animal diseases. The
                 following reports highlight weaknesses in U.S. systems for protecting
                 critical agriculture and food safety sectors:

             •   Foot and Mouth Disease: To Protect U.S. Livestock, USDA Must Remain
                 Vigilant and Resolve Outstanding Issues, U.S. General Accounting Office,
                 GAO-02-808 (Washington, D.C.: July 26, 2002).

                 Because the livestock industry is a key element of the U.S. agricultural
                 sector and economy, protecting U.S. livestock from foot-and-mouth
                 disease is an important federal responsibility. The 2001 outbreak of this
                 disease in the United Kingdom clearly illustrated the destruction that this
                 highly contagious animal disease can cause to a nation’s livestock industry
                 and other sectors of the economy. Foot-and-mouth disease is one of the
                 most devastating viral animal diseases affecting cloven-hoofed animals—
                 such as cattle and swine—and has occurred in most countries of the world
                 at some point over the past century. The last foot-and-mouth disease
                 outbreak in the United States was in 1929.1 According to federal officials,
                 even a single case of the disease would cause our trading partners to
                 prohibit U.S. exports of live animals and animal products and could result
                 in losses of between $6 billion and $10 billion a year while the country
                 eradicated the disease and until it regained disease-free status.

                 As part of our study, we examined whether U.S. measures for preventing
                 foot-and-mouth disease from entering the United States were effective and
                 whether the United States could respond quickly and effectively to an
                 outbreak of the disease if it were to occur.

                 We found that, because of the sheer magnitude of international passengers
                 and cargo that enter this country on a daily basis, completely preventing
                 the entry of foot-and-mouth disease may be infeasible. The volume of
                 incoming items make it impossible for border inspectors to physically
                 inspect every incoming cargo container or each international passenger’s


                 1
                  The foot-and-mouth virus is relatively hardy and can survive in certain environments for
                 considerable periods of time. For example, it can live in salted bacon for up to 183 days or
                 in air-dried animal hides or skins for 6 weeks. Should a person step in manure from an
                 infected animal, the virus can live on the shoes for up to 9 weeks in summer conditions or
                 up to 14 weeks in winter.



                 Page 9                                       GAO-04-259T Threats to Agriculture and Food
    luggage. The U.S. Department of Agriculture (USDA) has identified key
    pathways through which this highly contagious disease might enter the
    United States, such as on imported live animals or animal products; on the
    shoes of, or in packages carried by, international passengers; in
    international mail; and in garbage from international carriers. We also
    reported that, after the foot-and-mouth disease outbreak in the United
    Kingdom in 2001, USDA did not inform Customs of its decision to prohibit
    or restrict certain products or more vigilantly screen passengers arriving at
    U.S. ports of entry from the United Kingdom. USDA did not provide such
    official guidance until the Acting Commissioner of Customs formally
    requested such information more than a month after the outbreak began in
    the United Kingdom. USDA and the Department of Homeland Security
    (DHS) are working to increase defenses against diseases entering through
    those pathways.

    We further reported that, should preventive measures fail, and the United
    States experience an outbreak, the country would face challenges in
    responding quickly and effectively. While considerable planning and
    testing of emergency response plans had occurred, we noted several
    factors that could limit a rapid response to a foot-and-mouth disease
    outbreak, including (1) the need for rapid disease identification and
    reporting; (2) effective communication, coordination, and cooperation
    between federal, state, and local responders; (3) an adequate response
    infrastructure, including equipment, personnel, and laboratory capacity;
    and (4) clear animal identification, indemnification, and disposal policies.

    Our report recommended that USDA develop a formal mechanism to
    notify Customs as outbreaks of foot-and-mouth disease spread in other
    countries and develop uniform, nontechnical procedures that Customs
    inspectors could use to process international passengers and cargo
    arriving from disease-affected countries. USDA agreed with our
    recommendations. It said it would work with DHS to ensure that formal
    protocols are established for the seamless communication of animal
    disease risk information for border inspection.

•   Mad Cow Disease: Improvements in the Animal Feed Ban and Other
    Regulatory Areas Would Strengthen U.S. Prevention Efforts, U.S. General
    Accounting Office, GAO-02-183 (Washington, D.C.: January 25, 2002).

    Mad cow disease—or BSE—is an always fatal, neuro-degenerative disease
    that had been found in cattle in 23 countries around the world at the time
    we issued this report. Cattle contract the disease through feed that
    contains protein derived from the remains of diseased animals. Scientists


    Page 10                              GAO-04-259T Threats to Agriculture and Food
generally believe an equally fatal disease in humans—known as variant
Creutzfeldt-Jacob Disease—is linked to eating beef from cattle infected
with BSE; over 100 people have died from the human variant. During long
incubation periods—2 to 8 years in cattle and possibly up to 30 years in
humans—the disease is undetectable.

As part of our study, we assessed the effectiveness of federal actions to
prevent the emergence and spread of BSE and ensure compliance with the
animal feed ban.

We found, among other things, that federal actions could not sufficiently
ensure that all BSE-infected animals or products would be kept out of the
United States or that if BSE were found, it would be detected promptly
and not spread to other cattle through animal feed or enter the human
food supply. The United States had imported about 125 million pounds of
beef (0.35 percent of total imported) and about 1,000 cattle (0.003 percent
of total imported) from countries that later discovered BSE—during the
period when BSE would have been incubating. We reported that USDA’s
and the Food and Drug Administration’s (FDA) import inspection capacity
had not kept pace with the growth of imports. We also found that the one
international bulk mail facility that used the newest technology in
scanning equipment that would help inspectors more accurately identify
products that could carry BSE was not being used during periods of
operation when inspectors were not on duty. We further reported that
Customs found discrepancies with the accuracy of importer-provided
information and, as a result, BSE-risk imports may go undetected.

We also reported that FDA’s enforcement of the feed ban, which was put
in place to prevent the spread of BSE if it were found in U.S. cattle, was
limited and that FDA inspection data were flawed. FDA had not identified
and inspected all firms subject to the ban and had not acted promptly to
compel firms to keep prohibited proteins out of cattle feed and to label
animal feed that cannot be fed to cattle. FDA’s data on inspections of feed
facilities were so severely flawed that the agency could not know the full
extent of industry compliance.

We noted that, if BSE were found in the United States, the economic
impact on the $56 billion beef industry could be devastating—consumers
might refuse to buy domestic beef; beef exports could decline
dramatically; and sales in related industries, such as hamburger chains and
soup and frozen dinner manufacturers, could be similarly affected.




Page 11                             GAO-04-259T Threats to Agriculture and Food
    We recommended that USDA and FDA, among other things, develop a
    coordinated strategy to identify resources needed to increase inspections
    of imported goods and that FDA strengthen enforcement of the feed ban
    and its management of inspection data. USDA and FDA agreed with these
    recommendations. Additional funds were requested and approved to
    strengthen border inspections. FDA has increased the number of feed-ban
    compliance inspections, and implemented a new feed-ban inspection data
    system.

•   Food-Processing Security: Voluntary Efforts Are Under Way, but Federal
    Agencies Cannot Fully Assess Their Implementation, U.S. General
    Accounting Office, GAO-03-342 (Washington, D.C.: February 14, 2003).

    The food-processing sector is generally described as the middle segment
    of the farm-to-table continuum—it extends from the time livestock and
    crops leave the farm for slaughter and processing until food products
    reach retail establishments and the consumer. Experts from government
    and academia agreed that terrorists could use food products as a vehicle
    for introducing harmful chemical or biological agents into the food supply.
    In June 2002, the National Academies had also reported that terrorists
    could use toxic chemicals or infectious agents to contaminate food
    production facilities and that FDA should act promptly to extend the use
    of its Hazard Analysis and Critical Control Point methods for ensuring
    food safety to deal with the risk of deliberate contamination.2 The Centers
    for Disease Control and Prevention had also reported on the need for
    vigilance in protecting food and water supplies. Within this context, in
    2002 we examined federal efforts to enhance security at food-processing
    facilities.

    We reported that the two agencies with primary responsibility for ensuring
    for food safety—USDA and FDA—had each, independently, published
    comprehensive security guidelines for food processors to help them
    identify measures to prevent or mitigate the risk of deliberate
    contamination at their production facilities. Both agencies encouraged
    processors to review their current operations and to adopt those measures
    that they believed would be best suited for their facilities. FDA’s guidance
    contains over 100 suggested security measures and USDA’s some 68 such
    items. Among other things, the guidelines included recommendations for



    2
     USDA requires meat and poultry plants to use a Hazard Analysis and Critical Control Point
    system and FDA requires that system for juices, fish, and shellfish.



    Page 12                                    GAO-04-259T Threats to Agriculture and Food
improving personnel security by conducting screening and background
checks and controlling entry into the facilities; securing hazardous
materials by controlling access to storage areas; improving outside
security by monitoring all access to the establishment; installing lighting;
ensuring that in-house laboratories have comprehensive and validated
security and disposal procedures in place; and that parking areas are a
safe distance from the facility.

However, we also reported that USDA and FDA had determined that their
existing statutes did not provide them with absolutely clear authority to
impose security requirements at food-processing facilities. For example,
neither agency had authority to require processors to implement measures
to enhance security outside the food-processing environment, such as
installing fences, alarms, or outside lighting. Nor did the agencies believe
they had authority to require food processors to conduct employee
background checks. Because of these uncertainties about their authority,
the security guidelines they gave food processors are voluntary. Since the
guidelines were voluntary, USDA and FDA have not been enforcing,
monitoring, or documenting their implementation. We also found that
most of USDA’s and FDA’s field staff had not received training on security
matters. And, although the field staff were instructed to be vigilant and on
“heightened alert,” they were also told not to document or report their
observations regarding security at the plants because the information
could be obtained under a Freedom of Information Act request.

We also reported on recent congressional efforts to protect the nation’s
drinking water from terrorist acts that may offer a model for FDA and
USDA to help them monitor security measures at food-processing facilities
and to identify any gaps that may exist. Specifically, the Public Health
Security and Bioterrorism Preparedness and Response Act of 2002
requires community water systems to assess their vulnerability to terrorist
attacks and develop emergency plans to prepare and respond to such
events. They are also required to submit copies of their plans to the
Environmental Protection Agency. The act specifically exempts these
assessments from the Freedom of Information Act.

We concluded that FDA and USDA could not assess the industry’s efforts
to prevent or reduce their vulnerability to deliberate contamination.
Lacking such baseline information, they could not be prepared to advise
food processors on any additional actions needed. We also concluded that
the lack of security training for field personnel hampered their ability to
conduct informed discussion with facility personnel.



Page 13                              GAO-04-259T Threats to Agriculture and Food
    We recommended that FDA and USDA study their agencies’ existing
    statutes and identify what additional authorities they may need relating to
    security measures. On the basis of the results of these studies, the
    agencies should seek additional authority from the Congress. While USDA
    agreed with our recommendation, FDA took no position. We also
    recommended that both agencies provide training for all field personnel to
    enhance their awareness and ability to discuss security measures with
    plant personnel. USDA and FDA agreed with the need for additional
    training.

•   Combating Bioterrorism: Actions Needed to Improve Security at Plum
    Island Animal Disease Center, U.S. General Accounting Office, GAO-03-
    847 (Washington, D.C.: September 19, 2003).

    USDA scientists at the Plum Island Animal Disease Center are responsible
    for developing strategies for protecting the nation against animal diseases
    that could be accidentally or deliberately introduced in to the country.
    These scientists—often with the assistance of scientists from other
    countries—identify the pathogens that cause animal diseases in foreign
    countries and then work to develop vaccines against them. Some
    pathogens maintained at USDA’s Plum Island laboratory, such as foot-and-
    mouth disease, are highly contagious to livestock and could cause
    catastrophic economic losses if they were released outside the facility.
    Questions about the security of Plum Island arose after the September
    2001 terrorist attacks and when employees of the contractor hired to
    operate and maintain the Plum Island facilities went on strike in August
    2002. About 10 months later, in June 2003, DHS became responsible for
    Plum Island while the USDA staff are continuing their research programs.

    In September 2003, we reported that our review of security at Plum Island
    identified fundamental concerns that leave the facility vulnerable to
    security breaches. We found that immediately after the September 2001
    terrorist attacks, USDA began a concerted effort to assess security at
    many of its laboratories, including Plum Island. Using a risk management
    approach, USDA identified certain pathogens as the primary asset
    requiring protection, the potential threats to this asset, and the associated
    risk. USDA also began to upgrade security at Plum Island. For example,
    USDA hired armed guards to patrol the island and installed fingerprint
    recognition locks on freezers containing pathogens.

    Despite these improvements, we identified shortcomings in Plum Island’s
    security arrangements. We found that Plum Island’s physical security was
    incomplete and limited. For example, the alarms and door sensors that


    Page 14                              GAO-04-259T Threats to Agriculture and Food
were recommended for the biocontainment area were not fully
operational; outdoor lighting was not adequate to support security
cameras; and physical security was not sufficient for certain assets,
including the foot-and-mouth disease vaccine bank. DHS officials said the
alarms and door sensors will be in place by December 2003 and they were
evaluating other physical security matters.

Furthermore, we found that Plum Island officials had not adequately
controlled access to the pathogens. Eight scientists from other countries
were given access to the biocontainment area without escorts while their
background checks were incomplete; no background checks were done on
students who regularly attended classes within the biocontainment area;
and individuals entering the biocontainment area to perform
nonlaboratory functions, such as cleaning, were not always escorted.
Controlling access to the pathogens is particularly important because no
security device is currently capable of detecting a microgram of
pathogenic material. Therefore, a scientist could remove a tiny quantity of
pathogen without being detected and potentially develop it into a weapon.
Many facilities take measures to minimize this risk. For example, at the
U.S. Army Medical Research Institute of Infectious Diseases, background
checks must be updated regularly to evaluate the continued suitability and
reliability of employees working with pathogens. According to DHS
officials, they are taking action to revise policies for access to the
biocontainment area.

We also found limitations in Plum Island’s incident response capability.
For example, the guard force had been operating without authority to
carry firearms or to make arrests. Plum Island’s incident response plan
does not address what to do if an incident, such as a terrorist attack,
exceeds the capability of the security system, and officials have not tested
the facility’s response capability to ensure its effectiveness. DHS officials
told us they have started to take actions to fully address these incident
response issues and are obtaining assistance from the Federal Protective
Service.

Because of the strike that occurred in August 2002 and the hostility
surrounding it, the risk that someone may try to steal pathogens has
increased. One striker was convicted of tampering with the island’s water
distribution and treatment system as he walked off the job the day the
strike began, and USDA officials suspect that this individual did not act
alone. The intelligence community considers disgruntled employees as
posing a security risk. Although USDA did consider the possibility that it
could have a disgruntled worker, it did not reevaluate the level of risk, the

Page 15                              GAO-04-259T Threats to Agriculture and Food
           assets requiring protection, or its incident response plans for Plum Island
           in light of specific events related to the strike. Furthermore, USDA did not
           discuss the defined threat with the intelligence community and local law
           enforcement officials to ensure that threats particular to Plum Island and
           its vicinity were taken into consideration.

           We concluded that further actions are needed to provide reasonable
           assurance that pathogens cannot be removed from the facility and
           exploited for use in bioterrorism. Particularly, it is important to better
           secure the foot-and-mouth disease vaccine bank to ensure its availability
           for combating an outbreak. The lack of comprehensive policies and
           procedures for limiting access to pathogens unnecessarily elevates the risk
           of pathogen theft. Moreover, because physical security measures alone are
           not adequate to secure pathogens, all laboratories containing these
           materials face the challenge of developing other approaches to mitigate
           the risk of theft. By consulting with other laboratories to discover methods
           they are using to mitigate the risk to pathogens, Plum Island officials can
           learn more about safeguards being employed elsewhere.

           We recommended that DHS (1) correct physical security deficiencies at
           Plum Island; (2) limit access to pathogens and identify ways to mitigate
           the inherent difficulty of securing pathogens; (3) enhance Plum Island’s
           incident response capability; and (4) reconsider the risks and threats to
           Plum Island and revise the security and incident response plans as needed.
           DHS has agreed with the report and has started to implement these
           recommendations.




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