oversight

Agricultural Inspection: Improvements Needed to Minimize Threat of Foreign Pests and Diseases

Published by the Government Accountability Office on 1997-05-05.

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

                  United States General Accounting Office

GAO               Report to Congressional Committees




May 1997
                  AGRICULTURAL
                  INSPECTION
                  Improvements Needed
                  to Minimize Threat of
                  Foreign Pests and
                  Diseases




GAO/RCED-97-102
                   United States
GAO                General Accounting Office
                   Washington, D.C. 20548

                   Resources, Community, and
                   Economic Development Division

                   B-276421

                   May 5, 1997

                   Congressional Committees

                   Foreign pests and diseases entering the United States cost an estimated
                   $41 billion annually in lost production and expenses for prevention and
                   control, according to the U.S. Department of Agriculture (USDA). USDA’s
                   Animal and Plant Health Inspection Service (APHIS) is responsible for
                   minimizing the risks of infestation and disease and protecting the health of
                   U.S. agriculture by, in part, inspecting passengers and cargo entering the
                   country. As global trade and travel expand, the potential for infestations is
                   likely to increase, and so is APHIS’ inspection workload.

                   To assess APHIS’ effectiveness in minimizing the risks to agriculture from
                   pests and diseases entering the United States, we (1) identified recent
                   developments that could challenge the ability of APHIS’ Agricultural
                   Quarantine and Inspection program to carry out its mission, (2) reviewed
                   APHIS’ efforts to cope with these developments, and (3) reviewed the
                   effectiveness of the inspection program in keeping pace with workload
                   changes.

                   This report is based on work we conducted at APHIS’ headquarters in
                   Washington, D.C., as well as at 12 of the 172 ports of entry where APHIS
                   inspectors regularly inspect individuals and goods entering the United
                   States. The ports of entry that we examined represent a high volume of
                   traffic as measured by people or goods entering the United States and
                   include the nation’s three busiest ports of entry. Appendix I provides more
                   details on the scope and methodology of our work.


                   Several developments are challenging APHIS’ ability to effectively manage
Results in Brief   its inspection program. Key among these is the rapid growth in
                   international trade and travel since 1990, which has dramatically increased
                   the amount of cargo and the number of passengers that inspectors are to
                   examine. In addition, policy changes that emphasize facilitating trade and
                   customer service have put pressure on APHIS to carry out its increased
                   inspection responsibilities more quickly in order to speed the flow of
                   passengers and trade.

                   APHIS has taken several steps to cope with these developments. First, it
                   increased funding and staffing for inspections by about 78 percent and
                   44 percent, respectively, from fiscal year 1990 to 1996. Second, the agency




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             has attempted to improve the efficiency and effectiveness of its
             inspections by (1) using other inspection techniques in addition to visual
             inspections, such as x-ray technology and detector dogs, to pinpoint
             prohibited agricultural products, such as untreated fruits, vegetables, and
             meats from countries that present a higher risk for pests and diseases; and
             (2) coordinating with other Federal Inspection Service agencies to
             maximize inspection activities. Third, it began implementing its results
             monitoring program in fiscal year 1997 to better understand which ports of
             entry and commodities pose the highest risks of entry for harmful pests
             and disease.

             Despite these changes, inspectors at the ports we visited are struggling to
             keep pace with increased workload. Heavy workloads have led to
             inspection shortcuts, which raise questions about the efficiency and
             overall effectiveness of these inspections. On a broader scale, APHIS’ efforts
             to address its workload problems are hampered by inadequate information
             for determining how to best deploy its inspectors. In particular, its current
             staffing models—mathematical formulas used to help determine
             inspection staffing needs—are not based on reliable information and do
             not incorporate risk assessment factors similar to those being developed
             in its results monitoring program. Consequently, APHIS has little assurance
             that it is deploying its limited inspection resources at the nation’s ports of
             entry that are most vulnerable to the introduction of pests and diseases.


             APHIS is the lead federal agency for preventing infestations of harmful
Background   foreign pests and diseases, protecting U.S. agriculture, and preserving the
             marketability of agricultural products in the United States and abroad. The
             agency’s Plant Protection and Quarantine unit (PPQ) exercises regulatory
             authority to inspect agricultural imports,1 as well as nonagricultural
             products that may carry pests, largely through its Agricultural Quarantine
             Inspection (AQI) activities. In fiscal year 1996, APHIS allocated an estimated
             $151.9 million for AQI activities and had about 2,600 inspectors located at
             172 land, sea, and air ports of entry. APHIS has other inspection duties, such
             as inspections of imported and exported live animals, that are not the
             subject of this report.

             APHIS is one of the three primary Federal Inspection Service (FIS) agencies
             responsible for monitoring the entry of cargo and passengers into the
             United States. The two other FIS agencies are the U.S. Customs Service in
             the Department of the Treasury and the Immigration and Naturalization

             1
              APHIS’ regulatory authority is cited in 7 U.S.C. 147-150.



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                       Service (INS) in the Department of Justice. The U.S. Customs Service is
                       primarily concerned with collecting duties on imports, enforcing
                       antismuggling laws, and interdicting narcotics and drugs. INS inspects
                       foreign visitors to determine their admissibility into the United States and
                       guards against illegal entry.

                       Recent multilateral trade agreements—the North American Free Trade
                       Agreement (NAFTA) and the results of the General Agreement on Tariffs
                       and Trade’s Uruguay Round of Multilateral Trade Negotiations (Uruguay
                       Round)—have provisions that affect APHIS’ inspection activities.2 Both
                       agreements contain provisions on signatories’ use of sanitary and
                       phytosanitary standards that limit the introduction of foreign pests and
                       diseases. To prevent the standards from impeding agricultural trade, they
                       must be based on scientific principles and risk assessment, provide a level
                       of protection appropriate to the risk faced, and not restrict trade more
                       than necessary.3


                       APHIS’inspection workload has increased dramatically since 1990 because
Several Developments   of growth in imports and exports, increased travel, and increased
Pose Challenges to     smuggling. Furthermore, policy changes have exacerbated workload
Inspection Program     demands by increasing pressure to expedite the processing of passengers
                       and cargo into the United States.

                       The workload has been directly affected by the increase in international
                       trade and travel between fiscal years 1990 and 1995. Overall, the volume of
                       exports and imports rose 45 percent and 52 percent, respectively, while
                       agricultural exports and imports increased 35 percent and 31 percent,
                       respectively. Moreover, the number of international passengers traveling
                       to the United States increased almost 50 percent, reaching 55 million
                       passengers in fiscal year 1995.

                       Furthermore, increases in the number of ports of entry, as well as
                       increased risk at existing ports, have expanded APHIS’ workload. Along the
                       Mexican border alone, six new border stations were approved between
                       1988 and 1993, while several other major facilities are scheduled for
                       expansion. According to APHIS officials, each new port of entry requires at

                       2
                        NAFTA is a trade agreement among the United States, Mexico, and Canada that was implemented in
                       1994, while the Uruguay Round agreements, implemented in 1995, apply to over 100 member countries
                       of the new World Trade Organization.
                       3
                        APHIS is currently developing pest-risk standards to comply with the trade agreements. These
                       standards, based on risk assessments, form the foundation for changing inspection program
                       procedures, including the frequency and intensity of inspections.



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least five inspectors. Along the U.S.-Canadian border, changes in risks
associated with passengers and cargo have created the need for increased
inspections. APHIS staff at the Blaine, Washington, port told us that
increased risks were responsible for an increase from 4 inspectors in 1990
to 18 in 1996.

In addition to conducting inspections, inspectors are responsible for
reviewing and issuing certificates for agricultural exports, working on
temporary assignments away from their normal work location, and
performing other duties, such as preventing smuggling and fumigating
cargo. As exports increase, inspectors have had to issue and review a
growing number of certificates for U.S. exports.4 Temporary duty
assignments range from domestic emergency eradication of pests and
diseases and foreign preclearance activities to meetings and training.
Studies in California and Florida have found that the smuggling of
agricultural products into the United States has grown and presents a
serious pest risk.5 As a result of increased smuggling activity across the
Canadian and Mexican borders, APHIS inspectors are performing
antismuggling activities, such as working on investigations and
surveillance of markets and border areas.

Along with the greater inspection workload, inspectors face increasing
pressure to expedite the flow of goods and people across U.S. borders.
Responding to the growing importance of trade to the national economy
and to recent trade agreements, APHIS has taken an active role in
facilitating trade. Towards this end, APHIS and its FIS partners have adopted
new customer service standards to move the increasing import and
passenger volume through ports of entry within specific periods. For
passengers, these standards call upon the agencies to clear international
airline passengers within 45 minutes of arrival. Similarly, APHIS has adopted
standards to schedule inspections of perishable cargo within 3 hours of
being notified of its arrival. APHIS acknowledges the conflict between
enforcement responsibilities and trade facilitation and is seeking an
appropriate balance as guidance for the inspection program.




4
 APHIS is responsible for issuing certificates for agricultural exports. The certificates, known as
phytosanitary certificates, attest to the fact that the goods meet the health and safety requirements of
the importing country.
5
These studies are (1) “Report of the Governor’s Exotic Pest Eradication Task Force,” submitted to
Governor Pete Wilson, State of California, Mar. 1996; and (2) “Final Report on Cooperative Efforts to
Manage Pest Risk in South Florida (draft),” prepared by the Florida Department of Agriculture and
Consumer Services and the U.S. Department of Agriculture, Aug. 1996.



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                           APHIS made a number of changes to its inspection program to respond to
APHIS Changed Its          the demands of its growing workload. It shifted funds and staff away from
Inspection Program to      other programs to the inspection program, broadened the range of
Address the New            inspection techniques, and stepped up efforts to coordinate with the other
                           FIS agencies. In addition, to help measure the effectiveness of its
Challenges                 inspections and to form a basis for making further improvements, APHIS
                           recently initiated an effort to compare the rate at which restricted items
                           are entering the United States, and the risks associated with those items,
                           with the inspection rates at individual ports of entry. This effort is
                           designed to determine if the current inspection program is adequately
                           addressing the risks of harmful pests and disease entering the country and
                           to identify which of the country’s ports of entry are most vulnerable to
                           such risks.


APHIS Increased            APHIS has been shifting more funds into inspection activities since fiscal
Resources for Inspection   year 1990. Through fiscal year 1996, the budget for AQI activities rose 78
Activities                 percent to $151.9 million, while APHIS’ overall funding rose 20 percent. To
                           provide this increased funding, APHIS reduced its spending for several other
                           programs, such as the brucellosis eradication program, which fell from
                           $59 million in 1990 to $23 million in 1996. The 1990 and 1996 farm bills also
                           authorized the collection of and expanded access to user fees for
                           inspections. User fees have become the principal revenue source for the
                           AQI program, accounting for about $127 million of program revenues in
                           fiscal year 1996. (See app. II for more detail on funding and staffing for
                           fiscal years 1990-96.)

                           Since 1990, APHIS has raised AQI staffing levels about 44 percent—from
                           1,785 to 2,570 positions. The agency shifted positions from other programs
                           to meet the increased workload. In addition, as a result of the 1996 farm
                           bill’s provisions allowing greater access to user fee revenues and removing
                           a staff ceiling, APHIS is in the process of hiring about 200 new inspectors.


APHIS Expanded Use of      APHIShas taken several steps to make better use of its inspection
Alternative Inspection     resources. To supplement the normal practice of performing visual
Practices and Increased    inspections of selected cargo and baggage, APHIS has significantly
                           expanded the use of alternative inspection practices, such as detector
Interagency Coordination   dogs and x-ray equipment. APHIS increased the number of detector dog
                           teams from 12 in 1989 to 48 in 1996. Inspectors are also periodically using
                           inspection blitzes—highly intensive inspections of baggage or cargo—to
                           augment their visual inspection of selected items. To improve its ability to



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select passengers for inspection, APHIS is refining the list of risk
characteristics that inspectors use in selecting passenger bags for
inspection. Roving inspectors currently use these selection characteristics
in airports to make referrals for agricultural inspection. The agency is also
studying opportunities to use roving inspectors at land border ports.
Finally, APHIS is funding research on new x-ray technology that will identify
air passengers’ baggage containing restricted items.

APHIS has also attempted to reduce the workload at entry ports by
(1) inspecting passengers and products in the country of origin or
(2) allowing lower-risk products to enter with less intensive scrutiny.
Under the first effort, APHIS has staff oversee or conduct inspections to
preclear products and passenger baggage in the country of origin so that
inspectors at receiving U.S. ports primarily monitor these products or
baggage. APHIS’ International Services unit now operates cargo
preclearance inspections in 29 countries and limited passenger
preclearance programs in 2 countries. In addition, APHIS initiated a cargo
release program along the Mexican border to reduce inspections of
high-volume, low-risk commodities6 and allow the products to enter with
less intensive scrutiny. For example, according to APHIS, the port of entry
with the highest volume of agricultural imports from Mexico—Nogales,
Arizona—had about 75 percent of its shipments in 1995 in the cargo
release program.

In addition to taking steps aimed at improving the use of its own
resources, APHIS is working with the other FIS agencies—Customs and
INS—to improve coordination. For example, several work units are
working with the FIS agencies, through Port Quality Improvement
Committees, to improve port operations and are cross-training FIS staff to
educate them on APHIS’ inspection needs. In 1996, the FIS agencies and the
Department of State issued a report with recommendations for improving
screening of passengers as they arrive at U.S. borders. In 1996, APHIS began
providing computer equipment to 33 maritime ports and 26 airports to
enable them to link up with information in Custom’s databases on cargo
and prior violations.7 APHIS is trying to improve the linkage with the cargo
manifest database to overcome early problems in obtaining and reviewing

6
 The Border Cargo Release program established different inspection procedures for high-volume,
low-risk commodities entering from Mexico. APHIS defines high-volume commodities as more than
1,000 entries per year and low-risk commodities as those with no more than one harmful pest found in
a 1-year period or no more than three harmful pests found over a 6-year period. Examples of
high-volume, low-risk commodities are tomatoes, cucumbers, squash, and bell peppers.
7
The Automated Commercial System provides cargo manifests for arriving shipments. The Treasury
Enforcement Communications System contains a list of people and vehicles with prior violations.



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                             cargo information. For example, APHIS is developing its Automated
                             Targeting System, which will automatically scan Custom’s cargo manifest
                             database to identify shipments for inspection.


APHIS Implemented            In October 1996, APHIS began implementing the AQI Results Monitoring
Program to Determine Pest    Program, which is intended to measure the effectiveness of its inspections
and Disease Risks at Ports   nationwide and provide information on which ports of entry pose the
                             highest risk of having harmful pests and diseases enter the country. At
                             each port, the program will also identify risks of harmful pest and disease
                             entry associated with various commodities, their country of origin, and
                             their means of entry. APHIS expects the program to be in place at most
                             ports of entry by September 1997.

                             The results monitoring program uses random surveys of cargo and
                             passengers entering the United States to estimate the rates at which
                             restricted items are entering the country and the risks of harmful pests and
                             diseases associated with those items. The program allows APHIS to
                             determine whether the number of inspections performed at a given
                             location for a given commodity adequately address the risk posed. The
                             program replaces the traditional measure of inspection performance, the
                             quantity of material intercepted, with new performance indicators related
                             to risks associated with commodities entering the country. This approach
                             will enable APHIS to modify its inspection program to reduce the threat of
                             harmful pests while not unduly restricting trade.


                             Despite the changes in resources and activities, APHIS’ inspection program
Inspection Program           at most of the ports we visited has not kept pace with the increasing
Has Not Kept Pace            pressure from its growing workload and mission. Heavy workloads have
With Increasing              often led APHIS inspectors to shortcut cargo inspection procedures, thereby
                             jeopardizing the quality of the inspections conducted. Furthermore, APHIS
Demands                      has little assurance that it is deploying its limited inspection resources
                             efficiently and effectively because of weaknesses in the staffing models it
                             uses for making such decisions.


Questionable Inspection      APHIS’ inspectors are to follow certain procedures when examining goods
Practices                    and passengers entering the United States in order to minimize the
                             possibility of pest infestation and disease.8 However, at 11 of the 12 ports
                             that we examined, inspectors were not always implementing these

                             8
                              App. III discusses APHIS’ inspection procedures.



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    procedures for the (1) number of inspections that should be conducted,
    (2) number of samples of a shipment that should be examined, or
    (3) manner in which a sample should be selected. According to regional
    APHIS officials and internal studies, these types of problems may not be
    limited to the sites we visited.

    At 11 ports of entry we visited, including the 3 busiest ports in the United
    States, inspectors said that they are unable to examine enough vehicles or
    cargo containers to consider their inspection to be representative of the
    movement of goods, to control the flow of restricted goods, and to
    minimize risk of pests and disease. Several of these inspectors said that
    they were not confident that the frequency of inspections was adequate to
    manage the risks. For example:

•   At the Mexican border crossing with the heaviest passenger vehicle
    volume in the country, a supervisory inspector said the staff were
    inspecting less than 0.1 percent of the passenger vehicular traffic because
    of the high volume of traffic and the low number of referrals from FIS
    officials who initially screen the vehicles. APHIS officials have set a target of
    inspecting about 2 percent of all passenger vehicles.
•   Because of staffing shortages, one work unit along the U.S.-Mexican
    border can provide inspector coverage of a busy pedestrian crossing for
    only 8 of the 18 hours of port operations.
•   As a result of a low staffing level and the numerous other duties that must
    be carried out at a busy U.S.-Canadian border location, an APHIS manager
    told us that inspectors cannot maintain a regular presence at any of the
    four border crossings at the port. The inspectors are available to inspect
    only when the other FIS agencies make referrals to APHIS.

    Problems in conducting a sufficient number of inspections were not
    limited to the locations we visited. An APHIS headquarters official told us
    the agency does not conduct any inspections at 46 northern and 6
    southern ports of entry. Instead, the agency relies on the other FIS agencies
    to perform agricultural inspections, when needed, at these low-volume
    ports, although the risks are unknown.

    In addition, even for the inspections that they conduct, inspectors do not
    always examine the number of samples suggested by the guidance. For
    example, inspectors at two ports of entry told us that they were unable to
    inspect a large enough sample in a given cargo shipment to meet APHIS’
    inspection guidance. More specifically, during peak season at one
    high-volume port along the southern border, inspectors usually inspected



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one box from each shipment selected for inspection, or less than
0.5 percent of the shipment. This is far less than the 2-percent sample
recommended in APHIS’ guidance. At another port—the second largest in
the country—inspectors curtailed their inspections of cut flowers, which
are considered a high-risk cargo. The APHIS port director said that
inspectors are able to conduct only cursory inspections during
high-volume periods because the flowers are perishable and the cut flower
industry has continually pressured both political representatives and APHIS
to have inspections performed more quickly.

Finally, in contrast to recommended inspection procedures, APHIS
inspectors do not always select samples in a manner that ensures that the
samples are representative of the shipment being inspected. APHIS’
guidance emphasizes the importance of selecting representative samples
and specifically cautions against “tailgate inspections”—inspections of
goods that are stored near openings and that may not be representative.9 A
random survey of refrigerated cargo containers in Miami, conducted by
APHIS and the state of Florida, documented the pitfalls of such inspections.
The survey found that less than 40 percent of the pests discovered in the
survey were located near the container opening.10 Despite the limitations
associated with tailgate inspections, inspectors at five ports said they
routinely use them in inspecting cargo containers. This practice extends
beyond the ports we visited: A 1996 APHIS report on cargo inspection
monitoring noted that many ports have resorted to tailgate inspections
because of heavy trade volume.11

In addition to tailgate inspections, we found one port using another
sampling practice that also reduced assurance that the samples examined
represented the entire shipment. In Miami, the second busiest port in the
country, we observed inspectors allowing import brokers of cut flowers to
select samples for inspection. With this practice, brokers could select
samples that are likely to pass inspection, which reduces the credibility of
the inspection.

9
 Sampling rates vary widely, depending on the commodity, any treatment of the commodity to kill
pests, and the source country. The inspection rates differ, for example, for pears from Chile and from
New Zealand. As a result, the standard for a “representative” inspection sample varies. The inspection
manual for fresh fruits and vegetables advises inspectors to use 2 percent as a standard sampling rate
for determining the amount of an inspection sample in a particular shipment and allows adjustments
on the basis of experience with the shipper and the size of the shipment.
10
 “Final Report on Cooperative Efforts to Manage Pest Risk in South Florida (draft),” prepared by the
Florida Department of Agriculture and Consumer Services and the U.S. Department of Agriculture,
Aug. 1996.
11
 “Agricultural Quarantine Inspection Results Monitoring Project, Cargo Survey Implementation
Package.” Aug. 23, 1996.



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Inspection Program Lacks   The staffing models that APHIS uses to allocate its inspection resources
a Sound Resource           have several weaknesses that undermine the agency’s ability to ensure that
Allocation Method          inspectors are deployed to areas that pose the highest risk of entry of
                           pests or disease. The weaknesses fall in three areas. First, the staffing
                           models rely on inaccurate inspection workload data, which could skew the
                           models’ analyses. Second, the models do not contain risk assessment
                           information similar to that produced by the results monitoring program
                           because APHIS has not determined how to include risk data in the model’s
                           design. This limitation restricts APHIS’ ability to place inspection resources
                           at the ports of entry with the highest risks of pest and disease
                           introduction. Finally, the models are not used to allocate inspection
                           resources on a national basis. Rather, they are used only to allocate
                           resources within APHIS regions.

                           APHIS’staffing models are intended to help determine the number of
                           inspectors that should be stationed at various locations across the
                           country. There are four separate models for calculating staffing needs at
                           airports, land border crossings, maritime ports, and plant inspection
                           stations. Each of the models calculates staffing needs by, in essence,
                           multiplying various measures of workload activity (such as number of
                           inspections, number of vehicle arrivals, and number of pest interceptions)
                           by the time it takes to complete these activities and converting that
                           product into an estimate of the number of inspectors needed.

                           The accuracy of the workload data used in the models is key to ensuring
                           that projected staffing needs are also accurate. However, APHIS has little
                           assurance that the data are accurate. The inspection workload data used
                           in the model generally comes from APHIS’ Workload Accomplishment Data
                           System (WADS). APHIS officials at all levels of the inspection program
                           questioned the accuracy of the data in this system because of
                           inconsistencies in the way the data were compiled at ports and reported
                           through regional offices to APHIS headquarters. APHIS inspectors told us that
                           some data they submitted, such as information on endangered species,
                           was inaccurately reported or did not appear in the national WADS
                           summaries. Officials in one region said some data were omitted because
                           they were not useful at the national level, while inaccurate data may be
                           due to data entry error. Furthermore, workload statistics were often
                           estimates of activity rather than real-time information. Finally, we found
                           that another source of inaccurate data in WADS can be traced to the poor
                           quality of inspections. If, for example, inspectors are reporting the results
                           of tailgate inspections rather than inspections of representative samples of
                           cargo, WADS data on the number of interceptions could be misleading.



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              A second weakness with the current staffing models is that they do not
              take into consideration variations in the risks of harmful pests and disease
              entering the country. These risks can vary by several factors, such as the
              commodity, country of origin, port of entry and means of entry. The
              results monitoring program may be able to provide this type of analyses.
              However, APHIS officials have not yet determined how to incorporate this
              information into the models. Furthermore, there are some concerns about
              the accuracy of the results monitoring program because it too is based, in
              part, upon information from the WADS.

              Finally, the potential benefits of using the staffing models are limited
              because they are not used to allocate inspection resources on a national
              level. APHIS has instructed its regions and ports to use the staffing models
              to help allocate staff at the regional and port levels. However, regional
              officials at two of the four regions told us that they use the staffing models
              primarily for budget development, not for allocating staff among the ports
              within their regions.


              APHIS faces a difficult mission—to ensure that tons of cargo and millions of
Conclusions   passengers entering the United States do not bring in harmful pests or
              diseases. Its mission will only become more difficult as the volume of
              trade increases and the pressure to facilitate trade through expedited
              inspections becomes greater.

              In the ports we visited—which included the country’s three busiest ports
              of entry—APHIS inspectors are struggling to meet these challenging work
              demands. Unfortunately, these demands have sometimes resulted in
              shortcutting inspection procedures, such as performing tailgate
              inspections and allowing brokers to choose the samples for inspection. In
              turn, these shortcuts have diminished the quality of inspections and
              reduced assurance that an APHIS-inspected shipment entering the United
              States contains no harmful pests or diseases.

              In view of APHIS’ increasing workload, it is critical that the agency be able
              to allocate its limited inspection resources to the ports of entry with the
              highest risks of pest and disease introduction. APHIS currently does not
              have the management tools to do so. Specifically, the workload
              information in the WADS is key to staffing allocation decisions. However,
              APHIS officials question the accuracy of the WADS information, noting,
              among other things, that the system does not include all needed workload




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                      information and some of the information that it does include are estimates
                      that may be inaccurate.

                      Beyond problems with the workload information, APHIS’ current staffing
                      models do not factor into consideration variations by commodity, country
                      of origin, and other factors for the risk of pest or disease introduction.
                      APHIS’ results monitoring program will provide important information on
                      risk. However, APHIS officials have not yet determined how this
                      information will be integrated into their staffing models or staffing
                      decisions.

                      Finally, APHIS has not made a commitment to using its staffing models to
                      allocate inspection resources from a national perspective. Rather, it plans
                      to examine resource allocations only within regions. As a result, APHIS may
                      lack the flexibility for effectively shifting its resources to target them to
                      the highest risks.


                      To better ensure that APHIS identifies harmful pests and diseases through
Recommendations       the inspections that it conducts, the Secretary of Agriculture should direct
                      the Administrator of APHIS to issue guidance that emphasizes the need for
                      APHIS inspectors to adhere to minimum inspection standards in terms of
                      the methods used to select samples from shipments chosen for inspection.
                      We recognize that meeting these minimum standards may result in fewer
                      inspections, but we believe that a smaller number of reliable inspections is
                      preferable to a larger number of inspections that do not comply with
                      inspection guidelines.

                      To strengthen APHIS’ ability to allocate its inspection resources more
                      effectively and efficiently, we recommend that the Secretary of Agriculture
                      direct the Administrator of APHIS to develop and implement plans that will

                  •   improve the reliability of data in the WADS;
                  •   integrate a risk assessment factor, developed on the basis of the results
                      monitoring program, into its staffing allocation process; and
                  •   position APHIS to evaluate inspection resources in terms of national rather
                      than regional needs.


                      We provided a draft of this report to APHIS for its review and comment.
Agency Comments       Appendix IV contains APHIS’ written response to our draft report. APHIS
                      agreed that the issues identified in each of our four recommendations



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              needed to be addressed and indicated actions under way to address them.
              For example, to ensure that APHIS inspectors adhere to minimum
              inspection standards, APHIS said that it will provide guidance to reinforce
              the importance of using the best possible procedures for preventing pests
              from becoming established and will ensure that the inspection standards
              are consistent with the risk determinations conducted through the results
              monitoring activity. To improve the data in the WADS, APHIS plans to ensure
              that inspection program policies are consistently applied nationwide and
              that the data used in decisionmaking are accurate and reliable. To
              integrate a risk assessment factor into its staffing process, APHIS is
              developing a prototype model of staffing guidelines to integrate data from
              its results monitoring and risk assessments. To evaluate inspection
              resources in terms of national needs, APHIS is consolidating its four PPQ
              regions into two and believes that this will contribute significantly to
              achieving national consistency in all APHIS programs.


              To assess APHIS’ inspection program, we reviewed various studies of pest
Scope and     exclusion efforts and interviewed officials at APHIS headquarters, two
Methodology   regional offices, and work units at 12 ports of entry around the country. At
              work units, we observed actual inspections; obtained data on workload,
              operating procedures, and mission; and discussed recent developments
              and changes to the inspection program. Ports we visited were on the
              northern and southern borders of the United States and included
              international airports, seaports, rail yards, and mail stations. We
              performed our review from May 1996 through March 1997 in accordance
              with generally accepted government auditing standards. Appendix I
              provides details on our objectives, scope, and methodology.


              This report is being sent to congressional committees responsible for U.S.
              agriculture; the Secretaries of Agriculture and the Treasury; the U.S.
              Attorney General; the Administrator, APHIS; the Commissioners, U.S.
              Customs Service and Immigration and Naturalization Service; and other
              interested parties. We will also make copies available to others on request.




              Page 13                                  GAO/RCED-97-102 Agricultural Inspection
B-276421




Please contact me at (202) 512-5138 if you or your staff have any questions.
Major contributors to this report are listed in appendix V.




Robert A. Robinson
Director, Food and
  Agriculture Issues




Page 14                                  GAO/RCED-97-102 Agricultural Inspection
B-276421




List of Recipients

The Honorable Richard G. Lugar
Chairman
The Honorable Tom Harkin
Ranking Minority Member
Committee on Agriculture, Nutrition,
  and Forestry
United States Senate

The Honorable Ted Stevens
Chairman
The Honorable Robert C. Byrd
Ranking Minority Member
Committee on Appropriations
United States Senate

The Honorable Robert F. (Bob) Smith
Chairman
The Honorable Charles W. Stenholm
Ranking Minority Member
Committee on Agriculture
House of Representatives

The Honorable Bob Livingston
Chairman
The Honorable David R. Obey
Ranking Minority Member
Committee on Appropriations
House of Representatives

The Honorable Thad Cochran
Chairman
The Honorable Dale Bumpers
Ranking Minority Member
Subcommittee on Agriculture, Rural Development,
  FDA, and Related Agencies
Committee on Appropriations
United States Senate




Page 15                                GAO/RCED-97-102 Agricultural Inspection
B-276421




The Honorable Joe Skeen
Chairman
The Honorable Marcy Kaptur
Ranking Minority Member
Subcommittee on Agriculture, Rural Development,
  FDA, and Related Agencies
Committee on Appropriations
House of Representatives




Page 16                              GAO/RCED-97-102 Agricultural Inspection
Page 17   GAO/RCED-97-102 Agricultural Inspection
Contents



Letter                                                                                                1


Appendix I                                                                                           20

Objectives, Scope,
and Methodology
Appendix II                                                                                          23

Inspection Program
Resources
Appendix III                                                                                         25

Components of the
Inspection Program
Appendix IV                                                                                          26

Comments From the
Animal and Plant
Health Inspection
Service
Appendix V                                                                                           29

Major Contributors to
This Report
Table                   Table I.1: Animal and Plant Health Inspection Service Ports of               20
                          Entry Visited

Figures                 Figure II.l: AQI Funding, Fiscal Years 1990-1996                             23
                        Figure II.2: Authorized AQI Staffing Levels, Fiscal Years 1990-96            24




                        Page 18                                  GAO/RCED-97-102 Agricultural Inspection
Contents




Abbreviations

APHIS      Animal and Plant Health Inspection Service
AQI        Agricultural Quarantine Inspection
FIS        Federal Inspection Service
GAO        General Accounting Office
GSA        General Services Administration
INS        Immigration and Naturalization Service
NAFTA      North American Free Trade Agreement
PPQ        Plant Protection and Quarantine
WADS       Workload Accomplishment Data System


Page 19                                GAO/RCED-97-102 Agricultural Inspection
Appendix I

Objectives, Scope, and Methodology


                                     The objective of our review was to assess the effectiveness of the U.S.
                                     Department of Agriculture’s Animal and Plant Health Inspection Service
                                     (APHIS) in minimizing the risks to agriculture from pests and diseases
                                     entering the United States. Specifically, we (1) identified recent
                                     developments that challenge the Agricultural Quarantine and Inspection
                                     (AQI) program’s resources and ability to carry out its mission, (2) reviewed
                                     APHIS’ efforts to cope with these developments, and (3) reviewed the
                                     effectiveness of the inspection program in keeping pace with workload
                                     changes. We conducted our review at APHIS headquarters, two regional
                                     offices, and work units at 12 ports of entry located in the four APHIS regions
                                     responsible for plant inspection programs. APHIS management officials
                                     guided our selection of the ports we visited in order to ensure that these
                                     locations were representative of the challenges and problems faced by
                                     APHIS inspectors at all 172 staffed ports of entry. Ports we visited were on
                                     the northern and southern borders of the United States and included
                                     international airports, seaports, rail yards, and mail stations. Table I.1 lists
                                     the work units that we visited.

Table I.1: Animal and Plant Health
Inspection Service Ports of Entry    APHIS region and port of entry                      Type of entry
Visited                              Western region
                                     Blaine, Washington                                  Air, land, maritime, rail
                                     San Francisco, California                           Air, mail, maritime
                                     Oakland, California                                 Air, mail, maritime
                                     Los Angeles, California                             Air, mail
                                     San Diego, California                               Air, mail
                                     Nogales, Arizona                                    Air, land, rail
                                     Central region
                                     Brownsville, Texas                                  Air, land, maritime, rail
                                     Pharr, Texas                                        Air, land
                                     Laredo, Texas                                       Air, land, rail
                                     Northeastern region
                                     Buffalo, New York                                   Air, land, mail, maritime, rail
                                     New York, New Yorka                                 Air, maritime, mail
                                     Southeastern region
                                     Miami, Florida                                      Air, maritime, mail
                                     a
                                     In New York city, we visited work units at John Fitzgerald Kennedy International Airport (Jamaica,
                                     New York) and Brooklyn, New York.




                                     Page 20                                                GAO/RCED-97-102 Agricultural Inspection
Appendix I
Objectives, Scope, and Methodology




To identify recent developments affecting the inspection program’s
workload and mission, we reviewed statistical reports on agricultural
imports and exports and international air passenger arrivals from 1990
through 1995. We also reviewed reports prepared by APHIS and state
agriculture agencies on trends in workload volume and changes in pest
risk. APHIS provided data on the cost of foreign pest and disease
infestations to U.S. agriculture, but we did not verify the accuracy of the
data or the methodology used. At the ports of entry we visited, we
discussed changes in the volume and complexity of the port’s workload
and analyzed data on the number of phytosanitary export certificates
issued by the inspection staff. We also contacted APHIS’ regulatory
enforcement officials who analyze trends in smuggling agricultural goods
into the United States. We identified increases in ports of entry by
reviewing reports from the General Services Administration (GSA) and
discussing these increases with GSA headquarters officials. To assess
changes in APHIS’ mission, we reviewed APHIS’ mission statements, internal
reports, and organizational initiatives. At all locations, we discussed with
officials the impact of recent trade agreements or other developments on
APHIS’ workload and mission.


To review the changes APHIS has made to cope with recent developments,
we identified changes in resource allocations to the AQI program by
reviewing APHIS’ budget and staffing documents for 1990 through 1996 and
reports on user fees. We discussed with APHIS officials (1) shifts in staffing
and funding, (2) programs used to reduce the inspection workload at U.S.
ports of entry, (3) program priorities, (4) the implementation and use of
the results monitoring program and staffing models, and (5) inspection
coordination with the other Federal Inspection Service (FIS) agencies. We
analyzed data on inspection techniques and technologies and discussed
the use of various techniques with APHIS officials at all the locations we
visited. At several ports of entry, we observed the use of x-ray equipment
and detector dogs in inspections. We discussed border cargo release
programs with APHIS field staff at U.S.-Mexican border ports we visited and
preclearance programs with officials from the APHIS International Services
unit.

To evaluate the overall effectiveness of the inspection program, we
reviewed inspection manuals and discussed policies, procedures, and
requirements with APHIS headquarters officials. At the ports of entry we
visited, we discussed with port directors, supervisors, and inspectors how
inspections are conducted and how they could be improved. We also
reviewed studies and documents on various APHIS and FIS initiatives aimed



Page 21                                   GAO/RCED-97-102 Agricultural Inspection
Appendix I
Objectives, Scope, and Methodology




at improving inspections and discussed these initiatives with officials at
the locations we visited. Additionally, we observed inspections for various
modes of entry into the United States—airport cargo and arriving
international air passengers; pedestrians, vehicle and bus passengers, and
truck cargo at land border crossings; maritime cargo and ships at seaports;
rail cars and rail passengers; and international mail stations.

We performed our review from May 1996 through March 1997 in
accordance with generally accepted government auditing standards.




Page 22                                 GAO/RCED-97-102 Agricultural Inspection
Appendix II

Inspection Program Resources


                                         APHIS significantly increased its funding and staffing for the AQI program in
                                         the 1990s in an effort to keep pace with growing workload demands. APHIS’
                                         funding for the program rose by 78 percent from fiscal year 1990 through
                                         1996. Figure II.1 lists the funding allocations APHIS made for the inspection
                                         program for fiscal years 1990-96.


Figure II.l: AQI Funding, Fiscal Years
1990-1996                                160   Dollars in millions


                                         140


                                         120


                                         100


                                          80


                                          60


                                          40


                                          20


                                           0

                                           1990             1991     1992       1993            1994         1995         1996

                                           Fiscal year



                                         Source: APHIS.




                                         Inspection staffing levels rose about 44 percent from fiscal year 1990
                                         through 1996. Figure II.2 lists the authorized staffing levels for inspection
                                         activities.




                                         Page 23                                       GAO/RCED-97-102 Agricultural Inspection
                                       Appendix II
                                       Inspection Program Resources




Figure II.2: Authorized AQI Staffing
Levels, Fiscal Years 1990-96           3000   Staffing level



                                       2500



                                       2000



                                       1500



                                       1000



                                        500



                                          0

                                          1990             1991       1992   1993            1994         1995         1996

                                          Fiscal year



                                       Source: APHIS.




                                       Page 24                                      GAO/RCED-97-102 Agricultural Inspection
Appendix III

Components of the Inspection Program


                            The AQI program is APHIS’ first line of defense in protecting U.S. agriculture
                            from harmful pests and diseases. To implement the inspection program,
                            APHIS has prepared manuals to guide inspections of commercial shipments
                            and passengers and developed an array of inspection techniques. These
                            manuals show that a reliable and credible cargo inspection program
                            requires an adequate number of inspections and the selection of individual
                            inspection samples that are representative of whole shipments.


Inspection Procedures for   Procedures for inspecting commercial shipments vary according to such
Commercial Shipments        factors as the type of product, risk levels associated with the product, and
                            country of origin. Detecting the presence of plant pests or contaminants in
                            a commercial shipment is predicated on inspecting a sample of the
                            shipment. The procedures include guidance for ensuring that the sample is
                            representative of the whole shipment.


Inspection Procedures for   Inspection procedures for pedestrians, passengers, and passenger vehicles
Pedestrians, Passengers,    follow a two-stage process, primary and secondary inspection. Primary
and Passenger Vehicles      inspection involves screening passengers, their baggage, and vehicles by
                            questioning the passengers, reviewing their written declaration, and
                            visually observing for referral for further examination. APHIS is refining the
                            characteristics used in the screening process to select passengers and
                            baggage for secondary inspection. Secondary inspection involves a more
                            detailed questioning of the passenger and a visual examination of baggage
                            contents, if necessary. To detect pests and contraband, AQI staff use a
                            range of strategies, such as screening, detector dogs, and x-rays. For
                            airline flights, APHIS has also developed a list of low-, medium-, and
                            high-risk countries of origin to help guide the selection process in the
                            primary inspection area.




                            Page 25                                   GAO/RCED-97-102 Agricultural Inspection
Appendix IV

Comments From the Animal and Plant
Health Inspection Service




              Page 26       GAO/RCED-97-102 Agricultural Inspection
Appendix IV
Comments From the Animal and Plant
Health Inspection Service




Page 27                              GAO/RCED-97-102 Agricultural Inspection
Appendix IV
Comments From the Animal and Plant
Health Inspection Service




Page 28                              GAO/RCED-97-102 Agricultural Inspection
Appendix V

Major Contributors to This Report


               Ron E. Wood, Assistant Director
               Dennis Richards
               Mary K. Colgrove-Stone
               Michael J. Rahl
               Jonathan M. Silverman




(150919)       Page 29                           GAO/RCED-97-102 Agricultural Inspection
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