    Combating Bioterrorism: Actions Needed to Improve Security at
    Plum Island Animal Disease Center (19-SEP-03, GAO-03-847).

    Scientists at the Plum Island Animal Disease Center are
    responsible for protecting the nation against animal diseases
    that could be accidentally or deliberately introduced into the
    country. Questions about the security of Plum Island arose after
    the 2001 terrorist attacks and when employees of the contractor
    hired to operate and maintain the Plum Island facilities went on
    strike in August 2002. GAO reviewed (1) the adequacy of security
    at Plum Island and (2) how well the contractor performed during
    the strike. The Department of Homeland Security (DHS) assumed the
    administration of Plum Island from the Department of Agriculture
    (USDA) on June 1, 2003. While DHS is now responsible for Plum
    Island, USDA is continuing its research and diagnostic programs.
    -------------------------Indexing Terms-------------------------
    REPORTNUM:   GAO-03-847
        ACCNO:   A08514
      TITLE:     Combating Bioterrorism: Actions Needed to Improve
    Security at Plum Island Animal Disease Center
         DATE:   09/19/2003
      SUBJECT:   Animal diseases
    	     Biological warfare
    	     Contractors
    	     Counterterrorism
    	     Facility security
    	     Infectious diseases
    	     National preparedness
    	     Performance measures
    	     Physical security
    	     Terrorism

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    GAO-03-847

    United States General Accounting Office

    GAO

    Ranking Democratic Member, Committee

                  on Agriculture, Nutrition and Forestry, U.S. Senate

    September 2003

    COMBATING BIOTERRORISM

        Actions Needed to Improve Security at Plum Island Animal Disease Center

                                           a

    GAO-03-847

    Highlights of GAO-03-847, a report to the Ranking Democratic Member,
    Committee on Agriculture, Nutrition and Forestry, U.S. Senate

    Scientists at the Plum Island Animal Disease Center are responsible for
    protecting the nation against animal diseases that could be accidentally
    or deliberately introduced into the country. Questions about the security
    of Plum Island arose after the 2001 terrorist attacks and when employees
    of the contractor hired to operate and maintain the Plum Island facilities
    went on strike in August 2002. GAO reviewed (1) the adequacy of security
    at Plum Island and (2) how well the contractor performed during the
    strike. The Department of Homeland Security (DHS) assumed the
    administration of Plum Island from the Department of Agriculture (USDA) on
    June 1, 2003. While DHS is now responsible for Plum Island, USDA is
    continuing its research and diagnostic programs.

    GAO recommends that DHS consult with USDA to correct physical security
    deficiencies; further limit access to pathogens; consult with other
    laboratories to identify ways to mitigate the inherent difficulty of
    securing pathogens; enhance response capabilities; reconsider risks and
    threats; and revise security and incident response plans as needed.

    DHS agreed with the report and has started to implement our
    recommendations. USDA stated that the report was very useful.

    September 2003

    COMBATING BIOTERRORISM

    Actions Needed to Improve Security at Plum Island Animal Disease Center

    Security at the Plum Island Animal Disease Center has improved, but
    fundamental concerns leave the facility vulnerable to security breaches.
    First, Plum Island's physical security arrangements are incomplete and
    limited. Second, Plum Island officials have been assuming unnecessary
    risks by not adequately controlling access to areas where pathogens are
    located. Controlling access is particularly important because pathogens
    are inherently difficult to secure at any facility. Although this risk may
    always exist, DHS could consult with other laboratories working with
    pathogens to learn different approaches to mitigate this risk. Third, Plum
    Island's security response has limitations. For example, the guard force
    has been armed but has not had the authority from USDA to carry firearms
    or make arrests. Moreover, Plum Island's incident response plan does not
    consider the possibility of a terrorist attack. Fourth, the risk that an
    adversary may try to steal pathogens is, in our opinion, higher at the
    Plum Island Animal Disease Center than USDA originally determined because
    of hostilities surrounding the strike. Also, when USDA developed its
    security plan for Plum Island, it did not review their defined threats
    with the intelligence community and local law enforcement officials to
    learn of possible threats-and their associated risks-relevant to the Plum
    Island vicinity. Although these reviews did not occur, USDA subsequently
    arranged to receive current intelligence information.

    Despite a decline in performance from the previous rating period, USDA
    rated the contractor's performance as superior for the rating period
    during which the strike occurred.

    Plum Island Animal Disease Center

    Source: DHS.

    www.gao.gov/cgi-bin/getrpt?GAO-03-847

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

    Contents

      Letter

    Results in Brief
    Background
    USDA Has Taken Strides To Improve Security at Plum Island, but

    Fundamental Concerns Remain

    USDA Concluded Its Contractor's Performance Declined during the Strike but
    Operations Continued and Overall Performance Was Superior

    Conclusions
    Recommendations for Executive Action
    Agency Comments

    1 3 6

    11

    22 22 23 24

    Appendixes

    Appendix I:

    Appendix II:

    Appendix III:

                                            Appendix IV: Appendix V: Appendix VI:

    Scope and Methodology

    Additional Observations on Plum Island's Security System by GAO's Office
    of Special Investigations

    LB&B Associates' Performance, Employee Qualifications, and Costs

    Performance
    Employee Qualifications
    Costs Attributable to the Strike

    Comments from the Department of Homeland Security Comments from the U.S.
    Department of Agriculture GAO Contact and Staff Acknowledgments

    GAO Contact Acknowledgments 28

    30

    31 31 34 35

    39

    43

    46 46 46

        Table   Table 1: Summary of the Award Fee Determination Board's Rating
                            of LB&B Associates' Performance from April 2002 to
                                        January 2003.                          34
    Figures Figure 1: Plum Island, New York Figure 2: USDA Award Fee         7
               Determination Board's Composite
                          Scores for LB&B Associates' Performance from October
                                  1999 through January 2003                    33
                  Figure 3: Monthly Costs Billed to USDA, October 2001 through
                                                                           May
                                            2003                               36

    Contents

    Abbreviations

    APHIS Animal and Plant Health Inspection Service
    ARS Agricultural Research Service
    DHS Department of Homeland Security
    FBI Federal Bureau of Investigation
    GAO General Accounting Office
    USDA U.S. Department of Agriculture

    This is a work of the U.S. government and is not subject to copyright
    protection in the United States. It may be reproduced and distributed in
    its entirety without further permission from GAO. However, because this
    work may contain copyrighted images or other material, permission from the
    copyright holder may be necessary if you wish to reproduce this material
    separately.

    A

    United States General Accounting Office Washington, D.C. 20548

    September 19, 2003

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

    Dear Senator Harkin:

    The Plum Island Animal Disease Center-located in Long Island Sound off
    the coast of New York-researches contagious animal diseases that have
    been identified in other countries. The mission of the facility is to
    develop
    strategies for protecting the nation's animal industries and exports from
    these foreign animal diseases, which could be accidentally or deliberately
    introduced into the United States. Scientists at Plum Island-often with
    the assistance of scientists from other countries-identify the pathogens
    and toxins (hereafter called pathogens) that cause these foreign animal
    diseases and then work to develop vaccines against them. Some of the
    pathogens maintained at the Plum Island Animal Disease Center, such as
    foot-and-mouth disease, are highly contagious to livestock and could cause
    catastrophic economic losses in the agricultural sector if they were
    released outside the facility. A few can also cause illness and death in
    humans. For this reason, research on these pathogens is conducted within
    a sealed biocontainment area that has special safety features designed to
    contain the pathogens.

    Until recently, the Department of Agriculture (USDA) administered Plum
    Island, but in June 2003, it became the responsibility of the Department
    of
    Homeland Security (DHS).1 DHS officials told us that during a transition
    period that will last until September 31, 2003, they will review USDA's
    policies and procedures for Plum Island and determine how best to
    administer the facility. USDA will continue to have access to the facility
    to
    perform its research and diagnostic programs.

    1The Homeland Security Act of 2002 (P.L. 107-296, S: 310) authorized the
    transfer of Plum Island to DHS.

    Concerns about security at the Plum Island Animal Disease Center were
    heightened after the terrorist attacks of September 11, 2001, because of
    fears that someone might try to steal certain pathogens from the facility
    to conduct bioterrorist activities. As a result, USDA contracted with
    Sandia National Laboratories-experts involved in a range of national
    security areas, including ensuring the safety of nuclear weapons-to
    evaluate the effectiveness of, and make recommendations to improve, Plum
    Island's security program. USDA worked with Sandia to develop a risk
    management approach to improve security on the island. Some other agencies
    employ this method for their security planning, including the Department
    of Energy; we have also endorsed a risk management approach for addressing
    security risks.2

    Risk management is a deliberate process for determining risk: that is, how
    likely it is that a threat will harm an asset and how severe the
    consequences would be if the asset were harmed, and then deciding on and
    implementing actions to create a certain level of protection or
    preparedness. Risk management acknowledges that while risk generally
    cannot be eliminated, enhancing protection from known or potential threats
    can reduce it. A facility adopting this approach should document in a
    security plan the assets the facility is protecting as well as the likely
    adversaries and their capabilities (the threat), the probability that an
    adversary will attempt to threaten those assets and the consequences of
    the adversary succeeding (the risk), and the weaknesses that might allow
    an adversary to be successful (the vulnerability). The identified threats,
    risks, and vulnerabilities are used to design the physical security
    system. Because security systems cannot protect against all threats, the
    facility should also develop an incident response plan that clearly lays
    out the actions to be taken if an event occurs that exceeds the capability
    of the security system. The risk management process is ongoing; as new
    information develops or events occur, security is reevaluated and
    corrective actions are taken.

    In August 2002, congressional concerns about the security of pathogens at
    the Plum Island Animal Disease Center arose when 71 employees of the
    contractor USDA had hired to operate and maintain the facility, LB&B
    Associates Inc., went on strike. You asked us to determine (1) the
    adequacy of security at Plum Island and (2) how well LB&B Associates
    performed from August 2002, the month that its workers went on strike,

    2U.S. General Accounting Office, Homeland Security: A Risk Management
    Approach Can Guide Preparedness Efforts, GAO-02-208T (Washington, D.C.:
    Oct. 31, 2001).

    through January 2003. To address the first question, we visited Plum
    Island several times to gain an understanding of the work performed there,
    the operation of the facilities, and to examine the security measures and
    plans. We also spoke with officials from DHS, USDA, Sandia National
    Laboratories, the National Institutes of Health, the U.S. Army Medical
    Research Institute of Infectious Diseases, the Central Intelligence
    Agency, the Defense Intelligence Agency, the Federal Bureau of
    Investigation (FBI), USDA's Office of Inspector General, and government
    officials of localities near Plum Island. To address the second question
    we, among other things, reviewed LB&B Associates' contract; interviewed
    pertinent officials; and reviewed USDA's ratings of LB&B Associates'
    performance, the qualifications of its employees to perform certain tasks,
    and costs that LB&B Associates incurred, but we did not independently rate
    the contractor's performance. Before the administration of Plum Island
    transferred to DHS, we briefed USDA and DHS officials on our preliminary
    findings and made suggestions for improvement so that they could take
    immediate corrective measures. Additional details about our scope and
    methodology are contained in appendix I.

    Results in Brief	Security at the Plum Island Animal Disease Center has
    improved, but fundamental concerns remain. Before the September 2001
    terrorist attacks, officials at the Plum Island Animal Disease Center were
    less conscious of security and focused primarily on the safety of research
    activities and operations. Immediately after the attacks, USDA began a
    concerted effort to assess security at many of its laboratories, including
    Plum Island. Using a risk management approach that Sandia had suggested,
    USDA identified certain pathogens as the primary asset requiring
    protection, the potential threats to this asset, and the associated risk.
    USDA also began steps to upgrade security, some of which DHS has
    continued. For example, USDA hired armed guards to patrol the island and
    installed fingerprint recognition locks on freezers containing pathogens.
    Despite such improvements, we identified shortcomings in Plum Island's
    security arrangements.

    First, Plum Island's physical security is incomplete and limited. For
    example, the alarms and door sensors that Sandia recommended for the
    biocontainment area are not fully operational. Our Office of Special
    Investigations also identified shortcomings such as inadequate lighting to
    support the security cameras outside the research complex. Moreover, USDA
    did not provide sufficient physical security for certain assets, including
    the foot-and-mouth disease vaccine bank, and assets critical to

    the continued operation of the facility. DHS officials agree that alarms
    and door sensors for the biocontainment area are important and anticipate
    that they will be in place by December 2003. DHS officials also told us
    they are in the process of evaluating other physical security decisions
    made by USDA. We are recommending actions to correct Plum Island's
    physical security deficiencies.

    Second, Plum Island officials have not adequately controlled access to the
    pathogens. For example, in an effort to continue its mission, USDA
    permitted eight scientists from other countries access to the
    biocontainment area without being escorted, despite incomplete background
    checks. In addition, background checks are not conducted on students who
    regularly attend classes within the biocontainment area. According to the
    FBI, allowing anyone involved with pathogen-related activities-and, in
    particular, scientists from other countries-access to the biocontainment
    area without a completed background investigation represents a significant
    security risk. Furthermore, not all individuals entering the
    biocontainment area for the purpose of performing nonlaboratory functions,
    such as cleaning, have been escorted as required by regulations. DHS
    officials expressed concerns about this issue and said they are reviewing
    USDA policies and practices. Finally, 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 at
    Plum Island, or any other laboratory, could remove a tiny quantity of
    pathogen without being detected and potentially develop it into a weapon.
    This condition is common to all facilities performing biological research.
    Although this risk may always exist, DHS could consult with other
    laboratories working with pathogens to learn about their different
    approaches for mitigating this risk. For example, at the U.S. Army Medical
    Research Institute of Infectious Diseases, background checks are required
    to be updated regularly to evaluate the continued suitability and
    reliability of employees working with pathogens. DHS officials agree that
    additional measures could help safeguard the pathogens at Plum Island and
    stated that they have taken responsibility for performing background
    checks on all scientists prior to being admitted to the biocontainment
    area and added escorts. We are recommending actions to further limit
    access to pathogens and to identify ways to mitigate the inherent
    difficulty of securing pathogens.

    Third, Plum Island's incident response capability has limitations. For
    example, the guard force on Plum Island has been operating without
    authority from USDA to carry firearms or to make arrests. Until this

    authority is provided, local law enforcement officials said they are
    reluctant to help address criminal situations on the island. In addition,
    Plum Island officials have never specified how long they believe it should
    take for local law enforcement to respond to incidents. Moreover, Plum
    Island's incident response plan does not address what to do in the event
    of an incident that exceeds the capability of the security system, such as
    a terrorist attack. Finally, Plum Island officials have not tested the
    facility's response capability to ensure its effectiveness. DHS officials
    said they have started to take actions to fully address these incident
    response issues and are obtaining assistance from the Federal Protective
    Service. We are recommending that DHS officials enhance Plum Island's
    incident response capability.

    Fourth, the risk that an adversary might try to steal pathogens is, in our
    opinion, higher than USDA believed it to be in 2001, when it defined the
    same risks for all of its laboratories, including Plum Island. USDA
    considered the risk that an adversary would try to steal pathogens from
    any of its laboratories to be relatively low compared to materials found
    at other laboratories, such as nuclear material or pathogens of a higher
    consequence to the human population. Since that time, however, the level
    of risk at Plum Island has increased because of the strike that occurred
    in August 2002 and the hostility surrounding it. For example, one striker
    has been convicted of tampering with the island's water distribution and
    treatment system as he walked off the job the day the strike began. USDA
    officials suspect that this individual did not act alone. The intelligence
    community considers disgruntled employees to be threats who pose a
    security risk. Although USDA did consider the possibility of a disgruntled
    worker when planning security for all of its laboratories, it did not
    reevaluate the level of risk, the assets requiring protection, or its
    incident response plans for Plum Island in light of specific events
    related to the strike. Furthermore, Sandia had originally recommended that
    USDA review the defined threats with the intelligence community and local
    law enforcement officials to ensure that threats particular to Plum Island
    and its vicinity were taken into consideration, but this was never done.
    FBI and Suffolk County officials told us that they consider this step to
    be very important because if there are such threats, federal and local
    officials may know of their existence and the risks they pose to the Plum
    Island Animal Disease Center. DHS officials told us they recognize the
    importance of working with local law enforcement and the intelligence
    community in order to better identify the threats relevant for planning
    security for Plum Island. We are recommending that DHS reconsider the
    risks and threats to Plum Island and revise the security and incident
    response plans as needed.

    Regarding the contractor's performance, despite a decline from the
    previous rating period, USDA rated LB&B Associates' performance as
    superior for the rating period during which the strike occurred. Also, as
    a result of the strike, LB&B Associates exceeded its estimated budget by
    about $511,000, or approximately 5 percent, for fiscal year 2002 and the
    first quarter of fiscal year 2003. USDA was aware of and approved the cost
    increases.

    We provided DHS and USDA with a draft of this report for their review and
    comment. Both agencies provided written and clarifying oral comments. The
    agencies also provided technical comments, which we incorporated into the
    report as appropriate. DHS agreed with the report and stated that it has
    started to implement our recommendations. USDA stated that the report was
    very useful, but raised several concerns. For example, USDA stated that it
    appropriately used armed guards on Plum Island. Our concern is that USDA
    employed armed guards without ensuring that they had appropriate authority
    from USDA to carry firearms or make arrests. Furthermore, USDA had not
    developed a policy for instructing its guards on Plum Island about when
    and how they could use force, including the firearms they were carrying.
    DHS stated that it is working to resolve these issues.

    Background	Plum Island is a federally owned 840-acre island off the
    northeastern tip of Long Island, New York. It is about 1.5 miles from
    Orient Point, New York (see fig. 1), and about 12 miles from New London,
    Connecticut. Access to Plum Island is by a ferry service operated by a
    contractor that transports employees from Orient Point and Old Saybrook,
    Connecticut.

    Figure 1: Plum Island, New York

    The U.S. Army used Plum Island during World War II as a coastal defense
    artillery installation until it was declared surplus property in 1948. In
    1952, the U.S. Army Chemical Corps constructed a biological research
    laboratory, but it was never used. Then, in response to a foot-and-mouth
    disease outbreak in Canada, the Congress transferred all of Plum Island to
    USDA in 1954 for the purpose of researching and diagnosing animal diseases
    from other countries, including foot-and-mouth disease, which has not been
    seen in the United States since 1929.

    Foot-and-mouth disease is the most feared foreign animal disease because
    it is highly contagious and can have serious effects on the economy.
    Slaughtering susceptible animals and quarantining both animals and humans
    in affected areas helps limit the spread of the disease, but it can,
    nevertheless, have devastating economic consequences, as demonstrated
    during the 2001 outbreak in the United Kingdom. By the time the disease
    was eradicated, about 8 months later, the United Kingdom had slaughtered
    over 4 million animals and sustained losses of over $5 billion in the food
    and agricultural industries, as well as comparable losses in tourism.3

    Many other types of animal diseases are also studied at the Plum Island
    Animal Disease Center, such as classical swine fever; rinderpest; and a
    variety of pox viruses, including goat, camel, and deer pox. Some of the
    diseases are caused by pathogens that are zoonotic-that is, they can
    infect, and possibly cause death, in both animals and humans. Zoonotic
    pathogens maintained at Plum Island Animal Disease Center include West
    Nile virus, Venezuelan equine encephalitis, Rift Valley fever, and
    vesicular stomatitis. Because of the importance of the livestock industry
    to the U.S. agricultural sector and economy, protecting livestock from
    these diseases is an important responsibility.

    To prevent pathogens from escaping the Plum Island Animal Disease Center
    and infecting livestock, wildlife, or humans, all research is conducted
    within a specially designed and sealed biocontainment area within the
    research facility that adheres to specific safety measures.4 For example,
    the biocontainment area has air seals on its doors and operates with
    negative air pressure so that air passes through a special filter system

    3An outbreak directly impacts the trade sector because countries constrain
    trade with those markets whose products may be tainted with foot-and-mouth
    disease. Other sectors, such as tourism are affected because tourist
    activities are restricted, especially in quarantined areas. Production
    from infected or quarantined herds is zero because production is stopped
    when animals are slaughtered and products from infected animals are not
    permitted into the food chain.

    4Laboratories adhere to specific biosafety guidelines according to their
    designated biosafety level, which can range from 1 to 4. Biosafety level 1
    is acceptable for low-risk organisms that may be found, for example, in
    high school laboratories. Biosafety level 4 is reserved for a number of
    exotic and highly lethal pathogens, such as ebola. There are only five
    facilities in the United States with biosafety level 4 laboratories,
    including the Department of the Defense's U.S. Army Medical Research
    Institute of Infectious Diseases and the Department of Health and Human
    Services' National Institutes of Health. Plum Island operates a biosafety
    level 3 agriculture laboratory with some additional special agricultural
    safety features to prevent the release of animal disease pathogens into
    the environment.

    before leaving the facility. In addition, employees and visitors must
    change into protective clothing before entering the biocontainment area
    and shower when going between rooms containing different animal diseases
    and before leaving the biocontainment area. USDA's procedures require all
    people and material leaving the biocontainment area to be decontaminated.

    The Plum Island Animal Disease Center's biocontainment area totals
    approximately 190,000 square feet, and it is unusual because it houses a
    laboratory facility with 40 rooms for large animals. The three-level
    laboratory also contains the machinery, such as the air filtration system,
    necessary for the biocontainment area to function, and the pathogen
    repository. Individuals entering the biocontainment area have access to
    all three floors. In contrast, biocontainment areas of other laboratories
    usually consist of a series of smaller rooms, housing smaller laboratory
    animals, making it easier to control access to the pathogens.

    As a result of the September 11, 2001, terrorist attacks, Plum Island
    Animal Disease Center is now required to abide by new laws and regulations
    that were generated to help reduce the possibility of bioterrorism. These
    laws and regulations limit access to pathogens to only approved
    individuals- those whom USDA has identified as having a legitimate need to
    handle agents or toxins and whose names and identifying information have
    been submitted to and approved by the U.S. Attorney General. Specifically,
    the USA Patriot Act of 20015 prohibits restricted people-such as criminals
    or those individuals from countries that the Department of State has
    declared to be state sponsors of terrorism-from shipping, receiving,
    transporting, or possessing certain dangerous pathogens. In addition, the
    Agricultural Bioterrorism Protection Act of 20026 requires that USDA
    develop an inventory of potentially dangerous pathogens. Furthermore,
    individuals who possess or use pathogens must have background checks and
    must be registered with the U.S. Attorney General. Implementing this law
    are regulations that became effective on February 11, 2003,7 which state
    that

    5Pub. L. No. 107-56, S: 817. 6Pub. L. No. 107-188, S:S: 211-213. 77 CFR
    part 331.

    laboratories must be in compliance with the regulations by November 12,
    2003. USDA also requires employees to have favorably adjudicated
    background investigations before working unescorted in the biocontainment
    area.8

    When USDA contracted with Sandia in October 2001, Sandia evaluated the
    effectiveness of security at the Plum Island Animal Disease Center and
    four other USDA laboratories. Using a risk management approach, USDA first
    identified generic lists of assets, risks, and threats for all five
    laboratories. Sandia then used USDA's generic threat definitions to assess
    the security and vulnerabilities at each laboratory. Sandia officials
    found that Plum Island's existing security system was inadequate for
    protecting against the generic threats that USDA had selected and that it
    required significant improvement. Sandia officials also found that the
    biocontainment building was not designed to be a highly secure facility.
    USDA and Sandia agreed, however, that modifying the facility to withstand
    an assault would be cost-prohibitive and that, because pathogens occur
    naturally and are available at other laboratories throughout the world,
    the risk that a terrorist would try to steal them from Plum Island was not
    perceived as significant (and their perception has not changed).
    Consequently, Sandia recommended a limited physical security system
    designed to deter and detect a security breach and, with assistance from
    local law enforcement, respond to incidents exceeding the capability of
    the guard force on the island.

    DHS assumed formal administration of Plum Island from USDA on June 1,
    2003, as provided by the Homeland Security Act of 2002. During a
    transition period that will last until October 1, 2003, DHS will review
    USDA's policies and procedures and determine how best to administer the
    functions of Plum Island. Until the transition is complete, DHS will
    administer the facility under the same policies and regulations
    established by USDA. Ultimately, the two agencies will work together to
    address national biodefense issues and carry out the mission of the Plum
    Island Animal Disease Center. While DHS is now formally responsible for
    security, scientists and support staff of two USDA agencies, the
    Agricultural Research Service (ARS) and the Animal and Plant Health
    Inspection Service (APHIS), will continue to implement the Plum Island
    Animal Disease Center's research and diagnostic mission. ARS scientists at
    Plum Island are responsible for research on foreign livestock diseases,

    8USDA Security Policies and Procedures for Biosafety Level-3 Facilities,
    Agricultural Research Service, DM 9610-1.

    while APHIS scientists are responsible for diagnosing livestock diseases.
    APHIS conducts diagnostic training sessions several times a year to give
    veterinary health professionals the opportunity to study the clinical
    signs of animal diseases found in other countries, such as foot-and-mouth
    disease. According to USDA, scientists from other countries are an
    integral part of the Plum Island Animal Disease Center's workforce because
    they are well qualified and well situated to study the diseases researched
    there, many of which are endemic to their own countries. These scientists
    are sponsored by USDA and obtain visas that permit them to work for the
    department.

    DHS currently uses USDA's independent contractor to carry out operations
    and maintenance functions for Plum Island. The services under the contract
    include, among other activities, operating the ferries, providing security
    and emergency fire and medical services, providing buildings and grounds
    services, meeting utility requirements, and performing custodial
    functions. On August 13, 2002, 71 of these employees went on strike. The
    contractor at that time, LB&B Associates, was responsible for handling the
    strike. On January 6, 2003, LB&B Associates' contract expired. USDA had
    initially awarded that contract under a small business program when LB&B
    Associates still qualified as one. Since that initial award, LB&B
    Associates had grown so that it no longer was eligible to compete for
    contracts set aside for small businesses. As a result, USDA awarded the
    new contract to North Fork Services, a joint venture between LB&B
    Associates and Olgoonik Logistics LLC, a small minority company of
    Anchorage, Alaska. Under this arrangement, the more experienced LB&B
    Associates serves as a mentor to North Fork Services, and most of the
    employees who worked for LB&B Associates continue to work for North Fork
    Services. DHS officials told us that they would not renew the contract
    with North Fork Services. DHS stated that the current terms and scope of
    the contract are insufficient to operate the facility in accordance with
    its view of the standards and mission of the Plum Island Animal Disease
    Center.

    USDA Has Taken Strides To Improve Security at Plum Island, but Fundamental
    Concerns Remain

    Before the September 2001 terrorist attacks, the Plum Island Animal
    Disease Center, like many other federal laboratories, was less conscious
    of security and focused primarily on the safety of its programs and
    operations. Since then, USDA intensified its focus on security and has
    taken strides in developing and installing a security system. However,
    Plum Island remains vulnerable to security breaches because its security
    arrangements are incomplete and limited.

    USDA Has Taken Strides To Improve Security at Plum Island

    Security at Plum Island has improved since the fall of 2001. USDA hired a
    physical security specialist to oversee its efforts to improve security,
    including the implementation of Sandia's recommendations, and to provide
    direction for the security measures being taken for Plum Island. 9 As of
    July 2003, completed security upgrades include the following:

    o 	taking measures to prevent unauthorized access to Plum Island by
    allowing only sponsored visitors on the ferry and island; identifying
    those sponsored individuals, and allocating passes, when they board the
    ferry; and staffing Orient Point, New York, with a security guard as well
    as installing an access gate that can be opened only with an
    identification card assigned to Plum Island federal personnel;

    o 	hiring armed guards to patrol the island and observe personnel and
    visitors entering and leaving the facility. When the nation is on high
    terrorist alert (code orange) armed guards are added to monitor access to
    the biocontainment area and to better secure the island's perimeter. This
    also allows armed guards to remain in the building while the other armed
    guards go to the harbor to inspect vehicles unloaded from the ferry and
    ensure that individuals departing the ferry onto Plum Island have
    permission to be there;

    o 	conducting a background check for government staff and contractors
    working on the island and performing more rigorous checks for individuals
    with access to the pathogens;

    o 	installing some video cameras to (1) increase the probability of timely
    detection of an intruder and (2) monitor the activities of those inside
    the biocontainment area when they remove pathogens from the storage
    area-or the repository;

    o 	installing intrusion detection alarms in the administrative building
    and the biocontainment area;

    9Also, USDA had engaged the U.S. Army Corps of Engineers in August 2000 to
    make some physical security improvements at Plum Island, but this work was
    not based on an assessment of threats and risks. Few of the measures
    suggested by the Corps were implemented. In addition, Sandia officials
    told us that they did not agree with the approach taken by the Corps and
    that their physical security recommendations differed significantly. USDA
    has relied on Sandia's security recommendations.

    o 	limiting access to pathogens by installing certain access control
    devices; and

    o 	improving pathogen control and accountability by completing and
    maintaining an inventory of pathogens at the facility, submitting names of
    those with access to pathogens to the U.S. Attorney General, and creating
    security and incident response plans, as required by law.

    Despite Improvements, Security Arrangements at Plum Island Are Incomplete
    and Have Serious Limitations

    Plum Island's Physical Security Is Incomplete and Limited

    Although security at the Plum Island Animal Disease Center has improved
    over the past few years, fundamental concerns remain.

    Plum Island's physical security system is not yet fully operational. For
    example, the facility does not yet have in place all the equipment
    necessary to detect intruders in various places. DHS officials agree that
    these physical security measures are important and anticipate they will be
    in place by December 2003.

    In addition, our Office of Special Investigations identified physical
    security limitations. For example, we found that lighting is inadequate to
    support the cameras outside of the research complex and vehicles are not
    properly screened. (See app. II for other limitations identified by our
    Office of Special Investigations and observations on how they could be
    addressed.)

    Moreover, the physical security measures that USDA chose to implement on
    Plum Island are largely limited to the biocontainment area, where
    pathogens are located. Consequently, other important assets remain
    vulnerable. For example, the continued operation of the Plum Island Animal
    Disease Center is dependent on its infrastructure, which has limited
    protection. Protecting the infrastructure is particularly important
    because the Plum Island Animal Disease Center is the only facility in the
    United States capable of responding to an outbreak and researching
    foot-and-mouth disease. Therefore, if the infrastructure was damaged, no
    other facility could step in and continue this foot-and-mouth disease
    work. 10

    10Foot-and-mouth disease cannot be studied on the mainland of the United
    States unless the Secretary of Agriculture determines that it is necessary
    to do so (see 21 U.S.C. S: 113a).

    Furthermore, Plum Island is the only facility in North America that has a
    foot-and-mouth disease vaccine bank. This bank represents years of
    cooperative research performed by Canada, Mexico, and the United States,
    yet the room containing it has a window opening covered with only plywood.
    USDA officials said they intend to improve the physical security of the
    vaccine bank but have not yet decided on the approach to take. In
    addition, DHS officials agree that the Plum Island Animal Disease Center
    is vital to combating bioterrorism, and they are evaluating the physical
    security on Plum Island.

    Access to Pathogens Is Not Access to pathogens at the Plum Island Animal
    Disease Center is not

    Adequately Controlled	adequately controlled. For example, as of July 2003,
    eight scientists from other countries were working in the biocontainment
    area without completed background investigations.11 According to FBI
    officials, allowing anyone who does not have a completed background
    investigation access to the biocontainment area-in particular, a scientist
    from another country-represents a significant security risk. USDA
    officials told us these scientists were allowed into the biocontainment
    area to enable research to continue. Furthermore, they stated that
    background investigations had been initiated for these individuals, and it
    was assumed that these scientists were being escorted, which USDA policy
    permits for those with pending background investigations. However, Plum
    Island officials told us that due to resource constraints, it has not been
    possible to continually escort and monitor scientists while they are in
    the biocontainment area. When we brought this concern to the attention of
    DHS officials, they told us they are developing a more restrictive policy
    for allowing scientists from other countries to have access to pathogens.

    11USDA officials told us that they considered these scientists to be
    "grandfathered"-that is, USDA did not require background checks to gain
    unescorted access because these scientists were employed before enactment
    of the Bioterrorism Preparedness Act in June 2002. In addition, we found
    that three of these scientists arrived after this date-December 2002 and
    February and May 2003.

    In addition, USDA policy does not require background checks on students
    who attend the foot-and-mouth disease classes that are regularly held in
    the biocontainment area. In 2002, USDA held six classes with an average of
    32 students per class and anticipates continuing these classes in the
    future. According to USDA's policy, individuals may enter the
    biocontainment area without background checks if an approved individual
    escorts them.12 We believe this policy warrants reconsideration for
    several reasons.

    o 	Allowing students who do not have background checks into biocontainment
    for purposes of attending foot-and-mouth disease classes, with or without
    an approved escort, may not be consistent with the regulations13
    implementing the Agricultural Bioterrorism Preparedness Act.

    o 	These same regulations do not provide an exception for unapproved
    students or other visitors who may be handling or have access to
    pathogens.

    o 	USDA officials told us that maintaining constant visual contact with
    even one escorted individual is very difficult because of the size and
    floor plan of the biocontainment area.

    USDA officials told us that they believe escorting students is sufficient
    to meet the intent of the regulations. However, DHS officials said that
    all students should have completed background checks before entering the
    biocontainment area and told us they will develop a policy that will
    ensure that this occurs once the transition period is complete.

    Although USDA's regulations specifically allow unapproved individuals into
    the biocontainment area with an approved escort, we found unescorted
    maintenance workers in the biocontainment area. The regulations provide
    for unapproved individuals to conduct routine cleaning, maintenance,
    repair, and other nonlaboratory functions in the biocontainment area if
    they are escorted and continually monitored by an approved individual.14
    However, early in our investigation we found that as many as five such

    12USDA Security Policies and Procedures for Biosafety Level 3-Facilities,
    Agricultural Research Service, DM 9610-1.

    137 CFR S:S: 331.10 and 331.11.

    147 CFR S: 331.10(a)(2)(iv)(B).

    individuals were working in the biocontainment area without escorts. When
    we brought this to the attention of USDA officials, they provided an
    escort for these individuals. DHS officials added that the operating
    contractor would soon provide security escorts.

    Controlling access to pathogens is important because no security device
    can currently ensure that an insider, such as a scientist, will not steal
    pathogens from the Plum Island Animal Disease Center or other
    laboratories. According to the director of the Plum Island Animal Disease
    Center-while under USDA's administration-and officials from Sandia, the
    National Institutes of Health, and the U.S. Army Medical Research
    Institute of Infectious Diseases, pathogens are more difficult to secure
    than other materials that could be used as weapons, such as nuclear
    material. This is because there is no existing mechanism capable of
    detecting the theft of a microgram of pathogenic material and a tiny
    quantity can be multiplied. Thus, a scientist could covertly generate or
    divert a pathogen during the normal course of work, remove it from the
    laboratory undetected, and potentially develop it into a weapon for
    spreading disease. This inherent problem leaves all facilities with
    pathogens vulnerable to serious security breaches. Also, the existence of
    the foot-and-mouth disease pathogen at the Plum Island Animal Disease
    Center is a particular concern because an undetected theft, followed by
    the spread of the disease, would have serious economic consequences for
    the nation. In addition, the presence of zoonotic diseases at the Plum
    Island Animal Disease Center is worrisome because of the potential for
    adverse health affects on humans, and two such pathogens are of particular
    concern. First, U.S. government research has shown that Venezuelan equine
    encephalitis virus can be developed into a human biowarfare agent. Second,
    USDA believes that because of the genetic similarities of two pox strains,
    it may be possible to manipulate camel pox into an agent as threatening as
    smallpox.15 Although USDA created an inventory list of the pathogens at
    the Plum Island Animal Disease Center, as required by law, such a list
    cannot provide an accurate count of pathogens because quantities of
    pathogens change as they replicate.

    Thus far, Plum Island officials have secured pathogens by restricting
    access to the island itself and to the biocontainment area where the
    pathogens are

    15Out of concern that Iraqi scientists were trying to manipulate camel pox
    for possible warfare use, USDA conducted work for the Department of
    Defense to determine if camel pox could be manipulated into an agent
    similar to smallpox.

    located and by locking the freezers containing the pathogens. But DHS
    officials have not yet had the opportunity to fully consider actions other
    laboratories are taking to mitigate the likelihood that pathogens could be
    stolen. Officials at the U.S. Army Medical Research Institute of
    Infectious Diseases at Fort Detrick, Maryland, told us they are taking
    several steps, in addition to physical security measures and inventory
    control, to better safeguard pathogens against theft. For example, they
    plan to use trained personnel as roving monitors to ensure that
    unauthorized laboratory work is not being performed, and they will
    randomly inspect all personnel exiting laboratories. Moreover, they are
    interviewing scientists periodically and requiring that background checks
    be updated every 5 years in order to evaluate the continued suitability
    and reliability of those employees working with pathogens. Although USDA
    told us background checks were updated every 5 years, according to Plum
    Island records as of July 2003, 12 current Plum Island employees, some of
    whom have access to pathogens, had not had their background checks updated
    in more than 10 years. According to Sandia, other potentially helpful
    safeguards include creating, implementing, and enforcing strict policies,
    including those that prohibit researchers from continuing work in the
    biocontainment area if they do not follow security procedures. DHS
    officials stated that they have started to work with other laboratories
    and that measures such as these, while not necessarily a panacea, could
    help improve the security of pathogens at Plum Island.

    Incident Response Capability Is Plum Island's incident response capability
    is limited in four ways. First, the

    Limited	security guards on each shift carry firearms, although Plum Island
    does not have statutory authority for an armed guard force.16 USDA
    operated the guard force on Plum Island without authority for the guards
    to carry firearms or make arrests. Furthermore, Plum Island officials have
    not approved a policy that addresses the use of weapons, and, as a result,
    the guards do not know specifically how they are expected to deal with
    intruders on the island and when or if they should use their weapons.17

    16USDA's Office of General Counsel was aware of this issue for over 1 year
    but had not resolved it as of June 2003 when DHS became responsible for
    Plum Island.

    17A draft policy on the use of force was written for the guard force on
    Plum Island but never put into use.

    When we informed DHS officials of these problems, they agreed to resolve
    them as soon as possible and raised the possibility that the Federal
    Protective Service18 could be assigned to guard Plum Island. The Federal
    Protective Service, now under DHS, has the authority to carry weapons and
    make arrests.19 Since DHS has taken responsibility for the island, the
    Federal Protective Service has visited Plum Island to assess its security
    requirements.

    Second, according to the observations of our Office of Special
    Investigations, Plum Island has too few guards to ensure safety and
    effectiveness.20 DHS officials agree with this observation and said that
    they have requested funds to hire additional guards.

    Third, arrangements for local law enforcement support are also limited.
    According to Sandia's recommended security plan, in the event an incident
    exceeds the response capability of the Plum Island guards, they would
    first contact Southold town police, the closest and primary responding law
    enforcement agency.21 If still more resources were needed, Southold town
    police would contact Suffolk County police, the secondary responder.
    Because of liability issues, however, arrangements with local law
    enforcement have not been finalized even though there have been continuing
    discussions with local law enforcement. The result is that Plum Island
    officials cannot predict the extent to which the Southold town police will
    provide backup during an incident. On the other hand, officials of Suffolk
    County, which includes both Plum Island and Southold, told us that
    although it takes longer for them to respond than Southold police, they
    could respond with an adequate number of officers, if necessary.22 In
    addition, they have requested a map of the island and a tour of the
    biocontainment area to become more knowledgeable about the facility and

    18The Federal Protective Service's goal is to provide a safe environment
    in which federal agencies can conduct their business by reducing threats
    posed against federal facilities, which range from terrorism to workplace
    violence to larcenies.

    19Under the Homeland Security Act of 2002, DHS has authority for its
    officers to carry firearms and make arrests.

    20Additional observations of our Office of Special Investigations are
    included in appendix II.

    21Southold town police are located on Long Island in Suffolk County,
    approximately 5 miles from Plum Island.

    22In a life-and-death situation, the Suffolk County Police Department
    could respond with a helicopter, significantly reducing response time.

    its surrounding terrain. Suffolk County officials pointed out, however,
    that, for geographical reasons, Southold remains the primary responder. In
    this vein, Plum Island officials have never defined an adequate response
    time, nor have they conducted exercises with local law enforcement
    officials to determine how effectively Plum Island and local officials can
    address an incident on the island. DHS officials agree that the
    arrangements for local law enforcement support are limited, and they are
    trying to overcome this problem as quickly as possible by first resolving
    the issue surrounding the authority to make arrests and carry weapons. In
    addition, these officials concur that it is important to develop a better
    understanding of the response times and capabilities of local law
    enforcement assistance and to conduct exercises to test the adequacy of
    arrangements once they are completed.

    Fourth, according to Sandia officials, the incident response plan for Plum
    Island is not sufficiently comprehensive. Plum Island's incident response
    plan contains certain elements required under law, such as how to respond
    to an inventory violation or a bomb threat. 23 However, because USDA
    selected a risk management approach to security, Plum Island officials
    need an incident response plan that clearly lays out the actions to be
    taken if events occur that exceed the capability of the facility's
    security system. For example, Plum Island officials do not have a road map
    for actions to be taken in the event of a terrorist attack-who gets
    notified, in what order, and the responsibilities of staff for responding.
    This is a critical shortcoming because, according to DHS, the nation faces
    a significant risk of a terrorist attack. Sandia officials also said that
    the incident response plan for Plum Island requires significant additional
    development to properly prepare for the complete range of threats.
    Moreover, the incident response plan does not identify the security steps
    that should be taken in the event of an outbreak of foot-and-mouth disease
    or take into consideration any increased risks to the facility, which
    could severely impede the nation's capability to contain an outbreak.

    23See 7 CFR, S: 331.11 (a) (3).

    Finally, according to the FBI and local law enforcement officials, the
    island's incident response plan may need to be coordinated with the
    incident response plans of such nearby facilities as the Millstone nuclear
    power plant, the Brookhaven National Laboratory, and the laboratories at
    the State University of New York at Stony Brook because a terrorist attack
    on any of these facilities could also involve Plum Island.24 This type of
    coordination has not yet taken place. DHS officials agree that the
    incident response plan needs to be more comprehensive and coordinated with
    national and local law enforcement agencies.

    Plum Island's Security Plan Does The risk that an adversary might try to
    steal pathogens is, in our opinion, Not Address All Risks and higher than
    USDA believed it to be in 2001, when it defined the same risks

    Threats

    for all of its laboratories, including Plum Island. USDA considered the
    risk that an adversary would try to steal pathogens from any of its
    laboratories to be relatively low compared to materials found at other
    laboratories, such as nuclear material or pathogens of a higher
    consequence to the human population. Since its evaluation in 2001,
    however, the level of risk at Plum Island has increased because of the
    strike that occurred in August 2002 and the hostility surrounding it. For
    example, one striker has been convicted of tampering with the island's
    water distribution and treatment system as he walked off the job the day
    the strike began.25 USDA officials suspect that this individual did not
    act alone. In addition to this incident, USDA asked the FBI and USDA's
    Office of Inspector General to investigate the possibility that a boat
    engine had been tampered with. USDA also asked the FBI to investigate why
    backup generators failed to come on when Plum Island lost power for more
    than 3 hours in December 2002.

    24Officials of the FBI's New York office and of the Suffolk County's
    Police Department and Department of Fire, Rescue and Emergency Service
    told us that they would welcome the opportunity to review Plum Island's
    security assessment and response plans and would assist with this
    coordination.

    25Water pressure is a vital component of the process used to decontaminate
    materials in the biocontainment area in order to prevent the spread of
    animal diseases. Convicted of malicious mischief for tampering with the
    water system, the employee was sentenced to 5 years' probation and ordered
    to pay restitution.

    After the backup generators failed to provide power, New York's ABC news
    station broadcast an interview with a disguised worker, at that time
    employed at Plum Island, who discussed his unhappiness with USDA and the
    contractor and blamed replacement workers for the power outage.26 In
    addition, several of the striking workers returned to work for LB&B
    Associates and are still employed on the island under the new contractor,
    North Fork Services. In response to the strike, USDA prevented striking
    workers from accessing Plum Island and it added guards at Orient Point to
    assure the security of employees as they were arriving and departing near
    the union picket line. However, USDA did not reevaluate the level of risk,
    the assets requiring protection, or its incident response plans in light
    of the strike and accompanying sabotage. USDA believed that this was not
    necessary because its security plan anticipated a disgruntled worker at
    any of its laboratories. We disagree because there is a difference between
    addressing security problems caused by one employee and addressing the
    hostilities resulting from the strike, which could include several
    employees working together. We believe that the implications of a
    disgruntled work force should be taken into account when reevaluating the
    extent of risks, threats, and assets requiring increased security.

    Furthermore, Sandia had originally recommended that USDA review the
    defined threats with the intelligence community and local law enforcement
    officials to ensure that threats particular to Plum Island and its
    vicinity were taken into consideration, but this was never done.27 FBI and
    Suffolk County officials told us that they consider this step to be very
    important because if there were such threats, federal and local officials
    may be aware of them and the risks they pose to the Plum Island Animal
    Disease Center. In addition, if local law enforcement entities were
    involved in planning Plum Island's security, they would be in a better
    position to respond to incidents on the island.

    DHS officials agree that rehiring workers who walked off the job could be
    problematic but told us they are under pressure from the local chapter of
    the union and the community to rehire those who lost their jobs as a
    result of the strike. DHS officials also said they recognize the
    importance of

    26USDA officials said that although it was never proven that replacement
    workers were to blame for the outage, this illustrates the discontent on
    the island. Information on the qualifications of replacement workers can
    be found in appendix III.

    27While intelligence officials did not contribute to the assessment of
    threats to Plum Island, USDA has established links that provide current
    information about terrorist threats.

    working with local law enforcement and the intelligence community to
    better define the threats and associated risks for Plum Island.

    USDA Concluded Its Contractor's Performance Declined during the Strike but
    Operations Continued and Overall Performance Was Superior

    Regarding the contractor's performance, despite a decline from the
    previous rating period, USDA rated LB&B Associates' performance as
    superior for the rating period during which the strike occurred. When the
    strike occurred, LB&B Associates, with the assistance of USDA employees,
    maintained operations at Plum Island. For example, LB&B Associates
    implemented a strike contingency plan, brought in qualified individuals
    from its other work sites, and hired subcontractors with the required
    licenses and certifications to operate certain Plum Island facilities and
    its boats. Also, as a result of the strike, LB&B Associates exceeded its
    estimated budget by about $511,000, or approximately 5 percent, for fiscal
    year 2002 and the first quarter of fiscal year 2003. USDA was aware of and
    approved the cost increases. Further information about LB&B Associates'
    performance, employee qualifications, and costs is contained in appendix

    III.

    Conclusions	Despite improvements, security arrangements at Plum Island are
    not yet sufficient. Further actions are needed to provide reasonable
    assurance that pathogens cannot be removed from the facility and exploited
    for use in bioterrorism. Until DHS fully implements the physical security
    measures and addresses those vulnerabilities identified by our Office of
    Special Investigations, Plum Island's security system will not provide
    physical security commensurate with the importance of the facility.
    Additionally, the Plum Island Animal Disease Center will remain more
    vulnerable than it needs to be if the physical infrastructure that
    supports it is not afforded better protection. Similarly, it is important
    to better secure the foot-and-mouth disease vaccine bank to ensure its
    availability for combating an outbreak. Also, 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. Furthermore, Plum Island officials cannot effectively
    respond to security breaches until DHS resolves issues that impede Plum
    Island's response capability, such as the authority

    of the guard force to make arrests, which makes it difficult for the
    guards and local law enforcement agencies to address criminal situations
    on the island. Finally, because we believe the level of risk at Plum
    Island is higher than USDA originally determined, and because USDA did not
    validate threats with intelligence agencies or local law enforcement
    officials, DHS cannot be assured that Plum Island's security, including
    its physical security system and response plans, is sufficient to address
    the full range of events that could occur on the island.

    Recommendations for Executive Action

    To complete and enhance Plum Island's security arrangements, we recommend
    that the Secretary of Homeland Security, in consultation with the
    Secretary of Agriculture, do the following:

    o 	Correct physical security deficiencies by (1) fully implementing the
    physical security measures, (2) addressing the specific security
    shortcomings identified by our Office of Special Investigations, (3)
    better securing certain features of the physical infrastructure that
    supports the continued operation of the Plum Island Animal Disease Center,
    and (4) better securing the foot-and-mouth disease vaccine bank.

    o 	Limit access to pathogens by further developing and enforcing specific
    procedures, including internal control checks, to ensure (1) that all
    individuals involved in laboratory activities in the biocontainment
    area-including students and regardless of citizenship-have been approved,
    in accordance with the law; (2) that background checks of these
    individuals are updated regularly; and (3) that cleaning, maintenance, and
    repair staff entering the biocontainment area are escorted at all times by
    individuals with completed background checks.

    o 	Consult with other laboratories to identify ways to mitigate the
    inherent difficulty of securing pathogens.

    o 	Enhance incident response capability by (1) resolving the issue of the
    guards' authority to carry firearms and make arrests; (2) developing and
    implementing a policy on how guards should deal with intruders and use
    weapons; (3) increasing the size of the guard force; (4) completing an
    agreement with local law enforcement agencies to ensure backup assistance
    when needed; (5) defining an adequate response time for law enforcement to
    respond to incidents; (6) developing an incident response plan that
    includes precise detail about what to do in the event

    an incident occurs that exceeds the capability of the security system,
    such as a terrorist attack; and (7) conducting exercises with local law
    enforcement to test the efficiency and effectiveness of Plum Island's
    response capability.

    o 	Reconsider the security risks at Plum Island, taking into account
    recent acts of disgruntled employees.

    o 	Consult with appropriate state and local law enforcement and
    intelligence agencies to revisit the threats specific to the Plum Island
    Animal Disease Center.

    o 	Revise, as necessary, security and incident response plans to reflect
    any redefined, risks, threats, and assets.

    Agency Comments	We provided DHS and USDA with a draft of this report for
    their review and comment. Both agencies provided written and clarifying
    oral comments. The agencies also provided technical comments, which we
    incorporated into the report as appropriate. Overall, DHS agreed with the
    report and stated that it has started to implement our recommendations,
    and USDA stated that the report was very useful but also raised several
    concerns.

    In its written comments (see app. IV), DHS agreed that fundamental
    concerns leave the facility vulnerable to security breaches and stated
    that the report is factually accurate. DHS also commented that it accepts
    and supports our recommendations. In addition, DHS stated that since it
    assumed administrative responsibility for Plum Island on June 1, 2003, it
    has taken the following actions, among others, to address the
    recommendations in this report:

    o 	DHS is working with USDA to develop corrective actions to address the
    physical security deficiencies identified in our report.

    o 	DHS is working with USDA to develop an access control policy for all
    personnel who are required to enter the biocontainment area.

    o 	DHS is working with other federal agencies to develop security policies
    and procedures to limit access to pathogens.

    o 	DHS is working with the Federal Protective Service to enhance security
    at the facility and bring arrest and detention authority to the island. In

    addition, DHS stated that funds have been requested to increase the guard
    force.

    o 	DHS is working with local law enforcement agencies to coordinate
    incident response plans, mutual aid agreement requirements, and joint
    exercises to test security response capabilities.

    o 	DHS is reviewing the island's entire security plan and will revise the
    threat assessment as necessary. DHS stated that it expects to complete
    this assessment in early 2004.

    In its written comments (see app. V), USDA addressed several aspects of
    our report. These specific comments and our responses follow.

    o 	USDA suggested that the report should make judgments about the need for
    enhanced security against a risk assessment-based approach that considers
    both the probability and the consequences of specific types of attacks.
    However, as we report, DHS is now responsible for performing such an
    assessment, and DHS stated that it has undertaken a review of USDA's
    threat statement, which it will complete early in 2004. Our objective was
    to evaluate the status of security on Plum Island. That evaluation
    included, among other steps, a review of USDA's risk-based security plan
    for Plum Island and its implementation. Our report details substantive
    flaws in both the planning and the execution of that plan.

    o 	USDA also commented that the report did not recognize that USDA had a
    contract to improve security at Plum Island prior to September 11, 2001.
    We added to the report that USDA contracted with the U.S. Army Corps of
    Engineers in 2000 to improve security at Plum Island, but noted that few
    of the Corps' recommendations had been implemented. Also, USDA officials
    told us that in light of September 11, 2001, and the subsequent
    dissemination of anthrax through the postal system, they made a concerted
    effort to improve security at USDA's laboratories. The officials added
    that Sandia was hired to provide USDA with a consistent approach to
    evaluating security at the department's major laboratories. Sandia
    officials told us that they did not agree with the approach taken by the
    Corps, and they concluded that Plum Island's existing security system was
    substantially inadequate for protecting against the threats that USDA
    defined as relevant.

    o 	USDA indicated that it took various actions to safeguard pathogens in
    response to the strike. USDA stated that it increased and armed the

    guards on Plum Island; added guards at Orient Point, Long Island, where
    the strikers were picketing; and excluded the strikers from Plum Island
    facilities. We agree that USDA responded with immediate measures and have
    revised the report to reflect these steps. However, we believe that USDA's
    responses to the strike were insufficient. Although USDA increased the
    number of guards at Orient Point, this was a temporary measure primarily
    put in place to ensure the safety of the employees as they passed the
    union picket line. Also, Plum Island officials told us that the number of
    guards on Plum Island itself did not change as a result of the strike and
    that these guards had been armed since 2001. More importantly, USDA's
    comments do not recognize that there is a difference between addressing
    security problems caused by one employee and addressing the security
    problems resulting from the strike, which could include several employees
    collaborating to cause problems. We believe that the implications of
    having a disgruntled work force should be taken into account when
    reevaluating the extent of risks, threats and assets requiring increased
    security.

    o 	USDA stated that it appropriately used armed guards on Plum Island and
    were in communication with local law enforcement. While we agree that
    armed guards are necessary for security on Plum Island, our concern is
    that the guard force did not have authority from USDA to carry firearms
    and make arrests. Furthermore, USDA never developed a policy instructing
    its guards when and how they could use force, including the firearms they
    were carrying. Plum Island officials said they were unable to resolve
    these important matters with USDA headquarters officials, including the
    Office of General Counsel. Finally, we noted in the report that while Plum
    Island officials have communicated with local law enforcement, no
    agreement was reached to assist Plum Island guards in the event a criminal
    act occurred on the island. DHS stated that it is working to resolve these
    issues.

    o 	USDA stated that it is an accepted practice for a person with an
    appropriate background investigation to escort those who do not yet have a
    clearance. USDA also acknowledged that it had problems implementing its
    escort procedures at Plum Island but now believes its escort procedures
    are reliable. We agree that the practice of escorting is used in other
    laboratories that contain pathogens. However, Plum Island officials and
    scientists repeatedly told us that this procedure is not practical at Plum
    Island because of staffing considerations. For example, they explained
    that the escorts were Plum Island employees who had other duties, which
    compelled them to leave those they were

    escorting for periods of time. Furthermore, we believe that internal
    control checks should be established to ensure implementation of escort
    procedures, and we have added this to our recommendations. DHS commented
    that more will be done to address this issue-it is planning to develop, in
    concert with USDA, a limited use policy to identify access control
    requirements for all personnel who are required to enter the
    biocontainment area.

    o 	USDA said that several of the employees we identified had not had their
    background checks updated in the last 5 years, but that some of those we
    identified had. We reported based on the actual records of background
    checks maintained at the Plum Island Animal Disease Center. We also
    recognize that there may be differences between the records maintained on
    the island and other USDA records, and that the background checks of
    several of these individuals may have been updated since the time of our
    review.

    As we agreed with your office, unless you publicly announce the contents
    of this report earlier, we plan no further distribution of it until 30
    days from the date of this report. We will then send copies of this report
    to the Secretaries of Homeland Security and Agriculture, appropriate
    congressional committees, and other interested parties. We will also make
    copies available at no charge on the GAO Web site at http://www.gao.gov.

    If you have any questions about this report, please call me or Charles M.
    Adams at (202) 512-3841. Key contributors to this report are listed in
    appendix VI.

    Sincerely yours,

    Lawrence J. Dyckman Director, Natural Resources

    and Environment

    Appendix I

    Scope and Methodology

    To determine the extent to which USDA has addressed security for Plum
    Island, we visited the facility several times to examine current physical
    security measures and to review plans for further security actions. In
    addition, two security experts from our Office of Special Investigations
    toured the facility to identify possible vulnerabilities and actions that
    could be taken to reduce them. We also reviewed numerous security
    documents, such as Sandia's assessment of Plum Island security; Plum
    Island's draft security and response plans; draft memorandums of
    understanding with local entities; physical security implementation plans;
    and policies and procedures for guards, employees, visitors, students, and
    others with access to pathogens. In addition, we worked closely with
    Sandia officials to understand how they applied a risk management security
    approach to Plum Island. We also interviewed numerous officials from Plum
    Island, including the physical security specialist, scientists, the center
    director, and others responsible for security changes under both the
    Agricultural Research Service and the Animal Plant and Health Inspection
    Service; officials of USDA's Offices of Homeland Security, Procurement and
    Property Management, and General Counsel; and officials of the Department
    of Homeland Security, which assumed the administration of Plum Island. To
    gain a better understanding of possible threats to Plum Island, we spoke
    with officials from the Federal Bureau of Investigation, Defense
    Intelligence Agency, Central Intelligence Agency, Suffolk County police
    and fire departments, and USDA's Office of Inspector General. To
    understand the cooperation between local governments and Plum Island that
    might be needed if an incident were to occur on the island, we interviewed
    government and law enforcement officials from Suffolk County, the town of
    Southold, and the village of Greenport. Finally, we toured the
    laboratories at and interviewed officials from the National Institutes of
    Health and the U.S. Army Medical Research Institute of Infectious Diseases
    to understand how they are handling security challenges since the
    terrorist attacks of 2001. To determine Plum Island's compliance with new
    laws and regulations, we reviewed the USA Patriot Act1 of 2001, the
    Agricultural Bioterrorism Protection Act of 20022 and its regulations that
    went into effect as a final interim rule on February 11, 2003,3 as well as
    USDA's policies and procedures for security at biosafety level 3
    facilities. We also considered the Office of Management and

    1Pub. L. No. 107-56.
    2Pub. L. No. 107-188 S: S: 211-213.
    37 CFR S: 331.

    Appendix I
    Scope and Methodology

    Budget's Circular A-123, Management Accountability and Control,4 and the
    standards in our Internal Control: Standards for Internal Control in the
    Federal Government.5

    To determine how well LB&B Associates performed from the time the strike
    began on August 13, 2002, to January 5, 2003, we (1) reviewed LB&B
    Associates' contract with USDA and identified LB&B Associates' performance
    requirements; (2) interviewed officials of USDA, LB&B Associates, and the
    International Union of Operating Engineers to get their perspective on
    LB&B Associates' performance; (3) reviewed USDA's ratings of LB&B
    Associates' performance since 1999 and, in particular, the Award Fee
    Determination Board's report on LB&B Associates' performance during the
    period the strike took place; (4) reviewed the qualifications of LB&B
    Associates employees, such as the boat operators and water distribution
    and treatment system operators, all of whom are required to meet certain
    qualifications for performing their duties; (5) analyzed 3 years of
    contract cost data provided by LB&B Associates to learn which items
    increased as a result of the strike; and (6) validated the contract cost
    data by spot-checking it against the bills LB&B Associates submitted to
    USDA. While we took these steps to determine how well LB&B Associates
    performed, we did not independently rate LB&B Associates' performance. In
    addition, we interviewed officials involved in investigating
    strike-related incidents, including officials of the Federal Bureau of
    Investigation and USDA's Office of Inspector General.

    Our work was conducted in accordance with generally accepted government
    auditing standards from January through August 2003.

    4Office of Management and Budget, OMB Circular A-123 Management
    Accountability and Control (Washington, D.C.: 1995). This document
    provides the specific requirements for assessing and reporting on controls
    within the executive branch.

    5U.S. General Accounting Office, Internal Control: Standards for Internal
    Control in the Federal Government, GAO/AIMD-00-21.3.1 (Washington, D.C.:
    November 1999). The Federal Managers' Financial Integrity Act of 1982
    (FMFIA) requires us to issue standards for internal control in government.
    Among other things, the standards provide the overall framework for
    establishing and maintaining internal control.

    Appendix II

    Additional Observations on Plum Island's Security System by GAO's Office
    of Special Investigations

    o 	The security force reports directly to the Administrative Contract
    Officer and not to the Security Director-it is important for the security
    force to report directly to the Security Director of Plum Island to ensure
    that security-related issues are handled promptly.

    o 	There are no name checks or record checks given to contractors and
    visitors going into the biocontainment area. Contractors and visitors
    entering the biocontainment area could be checked for criminal charges
    (through the National Criminal Information Center) before they are granted
    access.

    o 	The area outside of the biocontainment and administrative building is
    surveilled by stationary closed-circuit television cameras, which are
    insufficient. Installing pan, tilt, and zoom closed-circuit television
    cameras in certain areas would enhance surveillance capabilities.

    o 	The island is easily accessible to the general public by boat, and
    there are limited "no trespassing" signs present on the island to advise
    the public that it is a government facility-more "no trespassing" signs in
    those areas of the island that are easily accessible to the public by boat
    would address this condition.

    o 	In the event of a fire, Plum Island is not always able to respond
    appropriately because the fire brigade has limited hours of operation. The
    security force could be cross-trained for fire rescues and therefore
    provide 24-hour coverage.

    o 	The building used for overnight accommodations lacks panic alarms for
    emergency response. Panic alarms could be installed in the building and,
    when visitors are present, security guards could drive by on a regular
    basis.

    o 	Control for keys and master keys of the facility is deficient. The
    security department could be assigned the responsibility for all keys and
    master keys. A key log could be created to better track possession of
    keys.

    Appendix III

    LB&B Associates' Performance, Employee Qualifications, and Costs

    USDA concluded, in an evaluation of LB&B Associates' performance, which
    included the time period involving the strike, that LB&B Associates'
    overall performance was superior, although its performance had declined
    compared to prior rating periods. When the strike occurred, LB&B
    Associates, with the assistance of USDA employees, continued to perform
    and maintained operations at Plum Island. LB&B Associates implemented a
    strike contingency plan, brought in qualified individuals from its other
    work sites, and hired subcontractors with the required licenses and
    certifications to operate certain Plum Island facilities and its boats.
    Also, as a result of the strike, LB&B Associates exceeded its estimated
    budget by about $511,000, or approximately 5 percent, for fiscal year 2002
    and the first quarter of fiscal year 2003. USDA was aware of and approved
    the cost increases.

    Performance	Although LB&B Associates' performance declined during the
    strike relative to previous rating periods, overall, LB&B Associates
    performed at a superior level during the evaluation period that included
    several months when workers were on strike, maintaining-and in some cases
    even improving-operations critical to the functioning of the island,
    according to Plum Island officials. Plum Island's Award Fee Determination
    Board regularly rated LB&B Associates' performance using a system
    described in its contract to calculate a composite performance score.1
    According to the board, LB&B Associates' performance was outstanding-the
    highest level-for more than 2 years, until the rating period in which the
    strike began. The board faulted LB&B Associates in several rating
    categories resulting in a decline in its performance rating. For example,
    according to the board, LB&B Associates' strike contingency plan, which
    describes how essential operations would be continued in the event of a
    strike, was outdated. As a result, implementation of the plan was slowed
    because it took up to 48 hours before all of its temporary workers arrived
    on the island. Moreover, some subcontracts cost more than anticipated.

    According to the board, LB&B Associates overcame initial problems in
    implementing its contingency plan and, overall, performed at the superior

    1The Award Fee Determination Board consisted of six officials who worked
    on Plum Island: center director, assistant center director, administrative
    contract officer, safety officer, APHIS laboratory chief, and ARS
    foot-and-mouth disease unit scientist. The composite score could have
    placed LB&B at one of five levels: 0-34, unacceptable; 35-49,
    unsatisfactory; 50-70, satisfactory; 71-84, superior; and 85-100,
    outstanding.

    Appendix III
    LB&B Associates' Performance, Employee
    Qualifications, and Costs

    level. For example, temporary workers and subcontractors hired by LB&B
    Associates quickly repaired the water system that had been sabotaged on
    the first day of the strike. Furthermore, according to the board, some
    activities improved after the onset of the strike, including the
    maintenance of steam pipes, an important component of the process used to
    decontaminate laboratory waste contaminated with pathogens. Also, boat
    maintenance and cafeteria services-both of which, according to the Board,
    had been problematic before the strike-improved after replacement workers
    were hired. Figure 2 shows the composite scores the board gave LB&B
    Associates from fiscal year 2000 through the first quarter of fiscal year
    2003, which includes the time during which the strike occurred.

    Appendix III
    LB&B Associates' Performance, Employee
    Qualifications, and Costs

    Figure 2: USDA Award Fee Determination Board's Composite Scores for LB&B
    Associates' Performance from October 1999 through January 2003

    Note: GAO presentation of USDA data.

    aUSDA rated LB&B Associates quarterly through fiscal year 2000; USDA
    changed to a 6-month rating schedule beginning with fiscal year 2001.

    bThe strike began in August of this rating period, April 1, 2002, through
    January 5, 2003, which would have ended on September 30, 2002; however,
    because the contract was extended through January 2003, the rating period
    was extended also.

    More details about how the board evaluated LB&B Associates' performance
    are contained in table 1.

                                      Appendix III
                         LB&B Associates' Performance, Employee
                               Qualifications, and Costs

    Table 1: Summary of the Award Fee Determination Board's Rating of LB&B
    Associates' Performance from April 2002 to January 2003.

    Performance Score and level of categories Types of activities performance

                  Utilities  o  Heating, A/C, and ventilation    77
                                     o  Refrigeration         Superior
                               o  Plumbing and pipefitting
                                o  Power plant operations
                                 o  Wastewater operations
                                      o  Electronics

                           Safety, health and            o  Security      70
                                environmental    o  Emergency health Satisfactory
                                                            services
                                   compliance       o  Environmental
                                                          compliance
                                                o  Biological safety
                                               o  Fire alarm support

                  Program and cost    o  Contract and cost       80
                                           management
                     management    o  Special task management Superior
                                    o  Resource utilization
                                       o  Quality control
                                   o  Subcontract management
                                       o  Scheduling and
                                          coordination
                                     o  Communications and
                                           reporting

                 Facilities     o  Painting and carpentry        76
                                 o  Equipment maintenance     Superior
                                 o  Janitorial functions
                             o  General building and grounds
                                       maintenance

                  Administrative   o  Photography services      82
                     support               o Mail             Superior
                                         o  Laundry
                                         o Glassware
                                      o  Food services

    Transportation  o  All marine and vehicle 71 transportation services
    Superior

    o  Boat and vehicle maintenance

    Source: GAO.

                          Note: GAO presentation of USDA data.

    Employee 	To maintain operations at Plum Island after the strike began,
    LB&B Associates brought in temporary replacements from some of its other

    Qualifications	contract sites, hired subcontractors, and subsequently
    hired permanent replacement workers, as described in the strike
    contingency plan. We confirmed that workers in certain positions,
    including boat operators and operators for the wastewater treatment
    system, were licensed as

                                      Appendix III
                         LB&B Associates' Performance, Employee
                               Qualifications, and Costs

    prescribed by LB&B Associates' contract with USDA. In addition, many of
    the replacement workers appear to have significant and relevant work
    experience for the positions for which they were hired.

    Although LB&B Associates and USDA staff worked together to maintain vital
    functions, operations were affected at times by the strike because of the
    reduced workforce and the loss of some workers with specific skills and/or
    qualifications. For example, the ferries that take workers to and from the
    island operated on a reduced schedule until all three boat masters who had
    walked out were replaced by individuals with the necessary Coast Guard
    license. Also, some USDA officials stepped in to fulfill duties that were
    normally performed by qualified contract staff, such as monitoring the air
    filters in the laboratory, until qualified replacements were hired. By
    July 2003, most positions left vacant by the strike were filled, most of
    them by permanent replacement workers and 16 by striking workers who
    returned to work on the island.

    Costs Attributable to the Strike

    With USDA's approval, LB&B Associates exceeded its estimated budget by
    about $511,000, or approximately 5 percent, during the 15-month period
    covering fiscal year 2002 and the first quarter of fiscal year 2003,2 the
    period during which the strike began.3 USDA allowed the additional
    expenditures, which occurred in the last 2 months of fiscal year 2002 and
    the first 3 months of 2003, because it recognized that the strike would
    result in higher expenses and it found LB&B Associates' estimate for
    exceeding the budget to be acceptable, under the circumstances. As
    required by Federal Acquisition Regulations, LB&B Associates notified USDA
    that it expected

    2LB&B Associates exceeded its fiscal year 2002 estimated budget of
    $8,027,011 by approximately $151,000, or about 1.9 percent. In the first
    quarter of fiscal year 2003, which covered October 1, 2002, through
    January 5, 2003, the contractor exceeded the estimated budget of
    $2,250,524 by about $360,000, or about 16 percent.

    3Prior to the strike, LB&B Associates billed to USDA over $107,000 in
    legal fees associated with renewing the collective bargaining agreement
    through May 31, 2002, after which time LB&B Associates itself paid about
    $136,000 in legal fees through April 2003.

    Appendix III
    LB&B Associates' Performance, Employee
    Qualifications, and Costs

    to exceed its budget as a result of the strike.4 Figure 3 shows the total
    costs LB&B Associates charged to USDA from October 1, 2001 through January
    5 2003; the graph also incorporates costs billed to USDA by North Fork
    Services from January 6 through May 31, 2003, illustrating the continued
    fluctuation in contract costs.

    Figure 3: Monthly Costs Billed to USDA, October 2001 through May 2003

                          Note: GAO presentation of USDA data.

    4Under a cost-reimbursable contract, Federal Acquisition Regulations
    require that the contractor notify the agency in writing whenever it has
    reason to believe that its costs will exceed 75 percent of the estimated
    budget, or if the total cost will be greater or significantly less than
    the estimated budget. Also, as part of the notification process, the
    contractor is required to provide the agency with a revised estimate of
    the total cost of performing its contract. In this case, if USDA had not
    accepted the cost increases, USDA officials said that USDA and LB&B
    Associates officials would have had to agree on which services to
    discontinue in order to stay on budget.

    Appendix III
    LB&B Associates' Performance, Employee
    Qualifications, and Costs

    According to LB&B Associates' data,5 there were fluctuations in Plum
    Island's costs, as shown in figure 3. Also, as a result of the strike,
    additional costs were incurred in the following areas from August 1, 2002,
    through January 5, 2003,6 unless otherwise noted: labor (salary and
    benefits), subcontracts, cafeteria, and travel (including lodging and
    transportation).

    Labor: The cost of labor peaked at $428,161 in August 2002, a 16 percent
    increase over the average monthly cost of $370,118 for the previous 10
    months. Monthly labor costs then gradually decreased until November, when
    the cost of labor was about 1.6 percent more than the average monthly
    cost. Labor costs increased because most of the temporary replacements
    were management-level employees from other LB&B Associates contract sites,
    who earned more than the employees they replaced. According to its
    documents, LB&B Associates used management-level employees because union
    members from other localities usually honor a picket line and would not
    temporarily replace union strikers. As new permanent employees were hired,
    the cost of labor gradually decreased.

    Subcontracts: Subcontracts related to the strike, such as for providing
    security guards at the picket line, added about $523,000,7 or 77 percent
    of the total subcontract costs billed to USDA by LB&B Associates.

    Cafeteria: Cafeteria expenses increased by about $12,000, or 51 percent of
    the total cafeteria expenses because the cafeteria provided two meals per
    day for the temporary replacements, who spent more time on the island to
    ensure continued operations than employees had before the strike began.

    5An independent auditor found that LB&B Associates' statements of income,
    changes in equity, and cash flows fairly represent the financial position
    of the company for the fiscal year ending September 30, 2002.

    6Costs rose sharply in December 2002 because costs related to subcontracts
    that were incurred in October and November were not billed to USDA until
    December, due to the billing cycles of LB&B Associates and the
    subcontractors. These subcontract-related costs were for tasks unrelated
    to the strike, such as security guards on the island, and related to the
    strike, such as security guards at the picket line.

    7North Fork Services incurred an additional $36,000 in subcontract costs
    related to the strike from January 6 through May 31, 2003. These
    subcontracts were for delivering supplies and materials to Orient Point
    and for security at the picket line on Orient Point while striking workers
    were picketing.

    Appendix III
    LB&B Associates' Performance, Employee
    Qualifications, and Costs

    Travel: Travel expenses attributed to the strike, such as transporting and
    housing the temporary replacement workers, totaled more than $125,000,
    constituting 98 percent of the total travel costs billed to USDA during
    that time period.

    Appendix IV

    Comments from the Department of Homeland Security

    Appendix IV
    Comments from the Department of Homeland
    Security

    Appendix IV
    Comments from the Department of Homeland
    Security

    Appendix IV
    Comments from the Department of Homeland
    Security

    Appendix V

    Comments from the U.S. Department of Agriculture

    Appendix V
    Comments from the U.S. Department of
    Agriculture

    Appendix V
    Comments from the U.S. Department of
    Agriculture

    Appendix VI

                         GAO Contact and Staff Acknowledgments

    GAO Contact Charles M. Adams, (202) 512-8010

    Acknowledgments	In addition to the individual named above, Aldo Benejam,
    Nancy Crothers, Mary Denigan-Macauley, Jonathan Gill, Thomas Farrell,
    Wyatt R. Hundrup, and Ramon Rodriguez made key contributions to this
    report.

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