Bioterrorism: A Threat to Agriculture and the Food Supply	 
(19-NOV-03, GAO-04-259T).					 
                                                                 
When the President created the Department of Homeland Security,  
he included U.S. agriculture and food industries in the list of  
critical infrastructures needing protection. The Secretaries of  
Agriculture and of Health and Human Services have publicly	 
declared that the U.S. food supply is susceptible to deliberate  
contamination. GAO was asked to provide an overview of the	 
potential vulnerabilities of the food supply and agriculture	 
sector to deliberate contamination and to summarize four recent  
GAO reports that identified problems with federal oversight that 
could leave the nation's agriculture and food supply vulnerable  
to deliberate contamination.					 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-04-259T					        
    ACCNO:   A08958						        
  TITLE:     Bioterrorism: A Threat to Agriculture and the Food Supply
     DATE:   11/19/2003 
  SUBJECT:   Agricultural industry				 
	     Animal diseases					 
	     Biological warfare 				 
	     Biomedical research				 
	     Consumer protection				 
	     Contaminated foods 				 
	     Emergency preparedness				 
	     Facility security					 
	     Food industry					 
	     Food inspection					 
	     Food supply					 
	     Health hazards					 
	     Import regulation					 
	     Import restriction 				 
	     National preparedness				 
	     Terrorism						 

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GAO-04-259T

United States General Accounting Office

GAO Testimony

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

For Release on Wednesday

November 19, 2003 BIOTERRORISM

                  A Threat to Agriculture and the Food Supply

Statement for the Record by Lawrence J. Dyckman, Director Natural Resources and
Environment

GAO-04-259T

Highlights of GAO-04-259T, a Statement for the Record for the Committee on
Governmental Affairs, U.S. Senate

When the President created the Department of Homeland Security, he
included U.S. agriculture and food industries in the list of critical
infrastructures needing protection. The Secretaries of Agriculture and of
Health and Human Services have publicly declared that the U.S. food supply
is susceptible to deliberate contamination. GAO was asked to provide an
overview of the potential vulnerabilities of the food supply and
agriculture sector to deliberate contamination and to summarize four
recent GAO reports that identified problems with federal oversight that
could leave the nation's agriculture and food supply vulnerable to
deliberate contamination.

The four GAO reports included recommendations to (1) the U.S. Department
of Agriculture and the Food and Drug Administration (FDA) to strengthen
import checks for detecting mad cow and foot-andmouth diseases and to
address security matters at food processors; (2) FDA to strengthen
enforcement of the feed ban; and (3) the Department of Homeland Security
to correct security deficiencies at Plum Island. The agencies generally
agreed with GAO's recommendations and have taken, or are in the process of
taking, actions to address the problems GAO found.

www.gao.gov/cgi-bin/getrpt?GAO-04-259T

To view the full statement, click on the link above. For more information,
contact Lawrence J. Dyckman at 202-512-3841or [email protected].

November 2003

BIOTERRORISM

A Threat to Agriculture and the Food Supply

Bioterrorism attacks could be directed at many different targets in the
farmto-table food continuum, including crops, livestock, food products in
the processing and distribution chain, wholesale and retail facilities,
storage facilities, transportation, and food and agriculture research
laboratories. Experts believe that terrorists would attack livestock and
crops if their primary intent was to cause severe economic dislocation.
The U.S. agriculture sector accounts for about 13 percent of the gross
domestic product and 18 percent of domestic employment. Terrorists may
decide to contaminate finished food products if harm to humans was their
motive.

Four recent GAO reports found gaps in federal controls for protecting
agriculture and the food supply. Thus, the United States would be
vulnerable to deliberate efforts to undermine its agriculture industries,
deliberate tampering of food during production, and the release of deadly
animal diseases, some of which also affect humans. GAO found, for example,
border inspectors were not provided guidance on foot-and-mouth disease
prevention activities in response to the 2001 European outbreak,
inspection resources could not handle the magnitude of international
passengers and cargo, and new technology used to scan shipments at a bulk
mail facility was operating only part-time and in only that facility. Such
careful controls over imported foods can help to prevent pathogens from
contaminating U.S. cattle with devastating diseases that have struck many
other countries. GAO also found that federal overseers did not have clear
authority to impose requirements on food processors to ensure security at
those facilities. Finally, GAO found security problems at Plum Island-a
large government-operated animal disease research facility. GAO found that
scientists from other countries, facility workers, and students had access
to areas containing high-risk pathogens without having completed
background checks and the required escorts.

Following are the four reports discussed in this testimony:

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

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

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

o  	Combating Bioterrorism: Actions Needed to Improve Security at Plum
Island Animal Disease Center, U.S. General Accounting Office, GAO03-847
(Washington, D.C.: September 19, 2003).

Madam Chairman and Members of the Committee:

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

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

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

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

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

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

  Overview of the Vulnerability of the U.S. Agriculture Sector and Food Supply
  to Intentional Contamination

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

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

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

  Recent GAO Reports Identified Weaknesses in U.S. Systems for Protecting
  Livestock and the Food Supply and Preventing the Release of Animal Diseases
  that Present Human Health Risks

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

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

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

These reports do, nonetheless, highlight weaknesses in U.S. systems for
protecting critical agriculture and food safety sectors.

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

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

1Foot and Mouth Disease: To Protect U.S. Livestock, USDA Must Remain
Vigilant and Resolve Outstanding Issues, U.S. General Accounting Office,
GAO-02-808 (Washington, D.C.: July 26, 2002) and Mad Cow Disease:
Improvements in the Animal Feed Ban and Other Regulatory Areas Would
Strengthen U.S. Prevention Efforts, U.S. General Accounting Office,
GAO-02-183 (Washington, D.C.: January 25, 2002).

2Food-Processing Security: Voluntary Efforts Are Under Way, but Federal
Agencies Cannot Fully Assess Their Implementation, U.S. General Accounting
Office, GAO-03-342 (Washington, D.C.: February 14, 2003).

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

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

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

Contacts and 	For future contacts regarding this statement, please contact
Lawrence J. Dyckman at 202-512-3841. Individuals making key contributions
to this

Acknowledgments 	statement included Maria Cristina Gobin, Erin Lansburgh,
Charles Adams, and Clifford Diehl. This statement will also be available
on the GAO Web site at http://www.gao.gov.

Appendix I: Recent GAO Reports Highlight Gaps in Federal Efforts to Protect
Agriculture and the Food Supply

Four recently issued GAO reports identified weaknesses in federal systems
for protecting U.S. livestock against devastating animal diseases and
ensuring security at food-processing facilities and at Plum Island-the
nation's principal diagnostics laboratory for animal diseases. The
following reports highlight weaknesses in U.S. systems for protecting
critical agriculture and food safety sectors:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

We recommended that FDA and USDA study their agencies' existing statutes
and identify what additional authorities they may need relating to
security measures. On the basis of the results of these studies, the
agencies should seek additional authority from the Congress. While USDA
agreed with our recommendation, FDA took no position. We also recommended
that both agencies provide training for all field personnel to enhance
their awareness and ability to discuss security measures with plant
personnel. USDA and FDA agreed with the need for additional training.

o  	Combating Bioterrorism: Actions Needed to Improve Security at Plum
Island Animal Disease Center, U.S. General Accounting Office, GAO-03847
(Washington, D.C.: September 19, 2003).

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

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

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

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

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

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

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

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

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

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

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