Anthrax Detection: Agencies Need to Validate Sampling Activities 
in Order to Increase Confidence in Negative Results (31-MAR-05,  
GAO-05-251).							 
                                                                 
In September and October 2001, letters laced with Bacillus	 
anthracis (anthrax) spores were sent through the mail to two U.S.
senators and to members of the media. These letters led to the	 
first U.S. cases of anthrax disease related to bioterrorism. In  
all, 22 individuals, in four states and Washington, D.C.,	 
contracted anthrax disease; 5 died. These cases prompted Congress
to ask GAO to describe and assess federal agencies' activities to
detect anthrax in postal facilities, assess the results of	 
agencies' testing, and assess whether agencies' detection	 
activities were validated.					 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-05-251 					        
    ACCNO:   A20538						        
  TITLE:     Anthrax Detection: Agencies Need to Validate Sampling    
Activities in Order to Increase Confidence in Negative Results	 
     DATE:   03/31/2005 
  SUBJECT:   Chemical and biological agents			 
	     Disease detection or diagnosis			 
	     Diseases						 
	     Health hazards					 
	     Infectious diseases				 
	     Interagency relations				 
	     Laboratories					 
	     National preparedness				 
	     Postal facilities					 
	     Strategic planning 				 
	     Terrorism						 
	     Test facilities					 
	     Testing						 
	     Disease surveillance				 
	     Homeland security					 
	     Anthrax						 

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GAO-05-251

United States Government Accountability Office

    GAO 	Report to the Chairman, Subcommittee on National Security, Emerging
  Threats, and International Relations, House Committee on Government Reform,
                            House of Representatives

March 2005

ANTHRAX DETECTION

Agencies Need to Validate Sampling Activities in Order to Increase Confidence in
                                Negative Results

GAO-05-251

[IMG]

March 2005

ANTHRAX DETECTION

Agencies Need to Validate Sampling Activities in Order to Increase Confidence in
Negative Results

                                 What GAO Found

The U.S. Postal Service, Centers for Disease Control and Prevention (CDC),
and Environmental Protection Agency (EPA) conducted several interdependent
activities, including sample collection and analytic methods, to detect
anthrax in postal facilities in 2001. They developed a sampling strategy
and collected, transported, extracted, and analyzed samples. They
primarily collected samples from specific areas, such as mail processing
areas, using their judgment about where anthrax would most likely be
found-that is, targeted sampling. The agencies did not use probability
sampling in their initial sampling strategy. Probability sampling would
have allowed agencies to determine, with some defined level of confidence,
when all results are negative, whether a building is contaminated.

                                       5

Sample analysis

Source: GAO analysis of CDC, EPA, and USPS data.

The results of the agencies' testing in 286 postal facilities were largely
negative-no anthrax was detected. However, agencies did not use validated
sample collection and analytical methods. According to the agencies,
validated methods were not available in 2001. Thus, there can be little
confidence in negative results. Validation is a formal, empirical process
in which an authority determines and certifies the performance
characteristics of a given method. Consequently, the lack of validation of
agencies' activities, coupled with limitations associated with their
targeted sampling strategy, means that negative results may not be
reliable.

In preparing for future incidents, the agencies have (1) made some changes
based on what has been learned about some of the limitations of their
sampling strategies, (2) made some revisions to their guidelines, (3)
funded some new research, and (4) planned or conducted conferences
addressing some of the issues GAO has identified. In addition, the
Department of Homeland Security (DHS) has taken on the role of
coordinating agencies' activities and has undertaken several new
initiatives related to dealing with anthrax and other biothreat agents.
However, while the actions DHS and other agencies have taken are
important, they do not address the issue of validating all activities
related to sampling. Finally, the agencies have not made appropriate and
prioritized investments to develop and validate all activities related to
other biothreat agents.

                 United States Government Accountability Office

Contents

  Letter

Results in Brief
Background
Agencies Were Challenged by Problems Associated with Sampling

Activities The Five Activities Involved Many Variables That Can Affect

Results The Sampling Results Were Largely Negative Lack of Validation
Raises Questions about the Reliability of

Negative Results Agencies Have Taken Some Steps to Prepare for Future
Incidents Conclusions Recommendations for Executive Action Agency Comments
and Our Evaluation

                                       1

                                      3 9

                                       17

                                     45 46

56 68 79 82 83

Appendix I Objectives, Scope, and Methodology

Appendix II 	Information on Sampling Events in Facilities with Positive
Results

Appendix III 	Comments from the Centers for Disease Control and Prevention

Appendix IV 	Comments from the Department of Homeland Security

         Appendix V Comments from the United States Postal Service 108

  Appendix VI 	Comments from the Association of Public Health Laboratories 110

Appendix VII Comments from the Department of Defense

114

Tables

Table 1: Agencies' Sample Collection Methods for Initial Sampling,

October 2001 through April 2002 Table 2: Total Samples Collected and
Sampling Events Table 3: Delivery Bar Code Sorting Machines Sampled,
Wallingford

Facility, 2001 Table 4: Agency Evaluations, October 2001 through February
2002

                                     27 46

                                     52 65

Figures

Figure 1: Agency Sampling Activities 18 Figure 2: Three Sample Collection
Methods 29 Figure 3: Laboratory Analysis of Samples in Preliminary and

Confirmatory Tests 37 Figure 4: Primary and Wallingford, Connecticut,
Facilities:

Sampling Methods and Results 48 Figure 5: Test Results Were Largely
Negative 50 Figure 6: Lack of Validation Can Affect Individual Activities
and the

Overall Process 61

Abbreviations

APHL Association of Public Health Laboratories
ATSDR Agency for Toxic Substances and Disease Registry
BSL biosafety level
CDC Centers for Disease Control and Prevention
CFU colony forming unit
DBCS delivery bar code sorter
DHS Department of Homeland Security
DNA deoxyribonucleic acid
DOD Department of Defense
EPA Environmental Protection Agency
FBI Federal Bureau of Investigation
HEPA high-efficiency particulate air
HHA hand-held assay
HHS Department of Health and Human Services
HVAC heating, ventilating, and air conditioning
LRN Laboratory Response Network
NBACC National Biodefense Analysis and Countermeasures Centers
NCID National Center for Infectious Diseases
NIOSH National Institute for Occupational Safety and Health
NJDHSS New Jersey Department of Health and Senior Services
OSHA Occupational Safety and Health Administration
OSTP Office of Science and Technology Policy
PCR polymerase chain reaction
P&DC processing and distribution center
RODAC replicate organism detection and counting
TSWG Technical Support Working Group
USAMRIID U.S. Army Medical Research Institute for Infectious Diseases
USPS U.S. Postal Service

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.

United States Government Accountability Office Washington, DC 20548

March 31, 2005

The Honorable Christopher Shays
Chairman, Subcommittee on National Security, Emerging Threats,

and International Relations
Committee on Government Reform
House of Representatives

Dear Mr. Chairman:

In September and October 2001, contaminated letters laced with Bacillus
anthracis, or anthrax spores,1 were sent through the mail to two senators,
Thomas Daschle and Patrick Leahy, and members of the media. The letters
led to the first cases of anthrax disease related to bioterrorism in the
United States. The postal facilities in New Jersey and Washington, D.C.,
that processed the senators' letters became heavily contaminated.2 Other
mail routed through these facilities, as well as additional ones in the
postal
network, also became contaminated. Numerous federal facilities in the
Washington, D.C., area-the U.S. Supreme Court, Walter Reed Army
Institute of Research, Department of Health and Human Services (HHS),
and main State Department buildings-were also later found to be
contaminated.

The mail for these federal facilities was believed either to have come in
direct contact with the contaminated letters or to have passed through
sorting equipment at the postal facility that processed these contaminated
letters. In all, 22 individuals contracted anthrax disease in four states
(Connecticut, Florida, New Jersey, and New York) as well as in
Washington, D.C. Five of these 22 individuals died.

The threat of bioterrorism had been recognized for a considerable time in
the United States, as well as internationally. Long before the anthrax

1"Anthrax" in this report reflects commonly used terminology. Technically,
the term refers only to the disease caused by the microorganism Bacillus
anthracis, not the bacterium itself or its spores.

2Anthrax contamination had been found earlier in several Florida postal
facilities that processed mail for the American Media Incorporated
building there. However, no letter containing anthrax was ever found.

incidents, several hoax letters indicating the presence of anthrax had
been mailed to federal and state agencies, as well as to private sector
organizations. In calendar year 2000, the Federal Bureau of Investigation
(FBI) responded to about 250 cases potentially involving weapons of mass
destruction. Of these, 200 were related to anthrax, although all turned
out to be hoaxes. Nevertheless, these events raised the possibility that
facilities could become contaminated and would therefore have to be
evaluated for environmental contamination. However, federal agencies have
not been fully prepared to deal with environmental contamination, that is,
anthrax released through the mail, including the potential for multiple
dispersals in indoor environments. 3

In this report, we respond to your request that we

o  	describe and assess federal agencies' activities to detect anthrax
contamination in the postal facilities;

o  	assess the results of the federal agencies' testing in the postal
facilities; and

o  	assess whether agencies' activities were validated and, if not,
discuss any issues that arose from the lack of validation and any actions
they took to address these issues.

This report follows our May 19, 2003, testimony on anthrax testing at the
Southern Connecticut processing and distribution center (P&DC), known as
the Wallingford facility, and it completes our work in this area.4

To respond to your request, we interviewed officials from federal agencies
involved in sampling the postal facilities, including the Department of
Defense (DOD) and the Centers for Disease Control and Prevention
(CDC)-specifically, CDC's Agency for Toxic Substances and Disease

3According to the head of the Postal Inspection Service, more than 7,000
hoaxes, threats, and suspicious letters and packages-an average of almost
600 a day-were reported to his agency in the weeks following the first
anthrax incident. As a result, nearly 300 postal facilities had to be
evacuated.

4GAO, U.S. Postal Service: Issues Associated with Anthrax Testing at the
Wallingford Facility, GAO-03-787T (Washington D.C.: May 19, 2003). See
also GAO, U.S. Postal Service: Better Guidance Is Needed to Improve
Communication Should Anthrax Contamination Occur in the Future, GAO-03-316
(Washington D.C.: Apr. 7, 2003), and U.S. Postal Service: Better Guidance
Is Needed to Ensure an Appropriate Response to Anthrax Contamination,
GAO-04-239 (Washington D.C.: Sept. 9, 2004).

Registry (ATSDR), National Center for Infectious Diseases (NCID), and
National Institute for Occupational Safety and Health (NIOSH).5 We also
interviewed officials from the Environmental Protection Agency (EPA), U.S.
Army Corps of Engineers, U.S. Postal Service (USPS), Association of Public
Health Laboratories (APHL), public health and private sector laboratories,
and experts on microbial detection in indoor environments. In view of the
ongoing criminal investigation, we did not review the FBI's sampling
techniques. However, CDC, EPA, and USPS provided us with some data on the
FBI's testing.

We reviewed documentation provided or developed by ATSDR, CDC, DOD, EPA,
the Occupational Safety and Health Administration (OSHA), and USPS, as
well as sample collection strategies, guidance, environmental collection
and analytical methods and protocols, and test results data, that is,
sample collection and analytical data collected by federal agencies, their
contractors, and public health laboratories. We did not independently
verify these data.

We conducted site visits to some postal facilities affected by anthrax and
some public health and private sector laboratories that were involved in
analyzing samples. We also carried out literature searches and reviewed
studies on sampling methods for detecting biological substances, including
anthrax, on surfaces and in the air. (See app. I for additional details on
our scope and methodology.) We conducted our review from May 2003 through
November 2004 in accordance with generally accepted government auditing
standards.

Although we did not assess anthrax testing done after the 2001 anthrax
incidents, we believe that the issue we identified concerning the need for
validated methods and sound sampling strategies would apply to such
testing in future. This is particularly evident given the consequences
arising from the March 2005 incident involving facility closures following
preliminary anthrax testing in the Washington, D.C., area.

Results in Brief 	CDC, EPA, and USPS, the federal agencies involved in
sampling the postal facilities in 2001 to detect anthrax, undertook
several activities: (1)

5For the purposes of our study, we report on CDC, EPA, and USPS sampling.
However, ATSDR staff, working in coordination with CDC's NIOSH staff, were
involved in the anthrax responses in Connecticut, Florida, New York, and
Washington, D.C.

sampling strategy development, followed by (2) sample collection, (3)
transportation, (4) extraction, and (5) analysis of the samples. As we
discuss below, neither these activities nor the overall process have been
validated for anthrax testing. Consequently, the agencies were challenged
due to limited information available for reliably choosing one method over
another and no information on the limits of detection to use when
evaluating negative results. The sampling strategy used by the agencies
could not provide any statistical confidence with regard to the basic
question: Is this building contaminated? Therefore, in the future, in the
absence of a positive result, a different strategy is needed that will
provide statistical confidence, at a defined level, to answer this
question.

The first activity involved agencies' developing a sampling strategy,
which included deciding how many samples to collect, where to collect them
from, and what collection methods to use. The agencies primarily used a
targeted strategy: They collected samples from specific areas considered
more likely to be contaminated, based on agencies' technical judgments.
This strategy was reflected in agencies' site-specific plans and guidance
and included judgments about where anthrax was likely to be found, such as
a mail processing area.6 Such judgments can be effective in some
situations, for example, in determining (1) the source of contamination in
a disease outbreak investigation or (2) whether a facility is contaminated
when information on the source of potential contamination is definitive.
However, in the case of a negative finding, when the source of potential
contamination is not definitive, the basic question-Is this building
contaminated?-will remain unanswered.

The agencies did not use probability sampling in their initial sampling
strategy. 7 Probability sampling would have allowed agencies to determine
whether the building was contaminated with some defined level of
confidence-in case of a negative result. Agency officials gave several
reasons for choosing targeted sampling. For example, for CDC, targeted
sampling was the most expeditious approach for quickly identifying
contamination in facilities to support public health measures such as

6These judgments, according to CDC, "relied primarily on using existing
law enforcement, epidemiology, and event details to identify locations
where anthrax was most likely to be found."

7A probability sample is taken from a population by some random or
stratification method, so that each item in the population has a known,
nonzero probability of being selected. For negative results, a probability
sample allows for conclusions at specific levels of confidence about the
entire population sampled.

decisions on the need to provide antibiotics. For USPS, the number of
samples it could collect was limited due to insufficient laboratory
analytic capacity. In the future, it would be reasonable for the agencies
to develop a sampling strategy that would allow them to make statistical
inferences about the negative results when the source of contamination is
not definitive. This is important, considering that low levels of anthrax
could cause disease and death in susceptible individuals.

The second activity involved the agencies and their contractors using
different methods to collect samples during sampling events.8 While USPS
generally used dry swabs to collect samples (the least effective method),
CDC and EPA used multiple methods-dry swabs, premoistened swabs, wet
wipes, and a high-efficiency particulate air (HEPA) vacuum-in various
combinations or alone.9

The third activity involved the agencies, or their contractors,
transporting the samples to laboratories for analysis according to federal
regulations for transporting "infectious substances." The regulations were
designed to prevent an inadvertent release of anthrax rather than maintain
the samples' biological integrity for testing. While anthrax spores are
robust, compared with other pathogenic microorganisms, the extent to which
various transportation conditions might have affected their
viability-their ability to germinate, divide, and multiply-was not
specifically validated, although the effects of temperature and
ultraviolet light on spore viability have been reported in the literature.

The fourth activity involved laboratory personnel extracting the particles
from the sample material, using extraction fluids and procedures specified
by the laboratory. However, because no sample extraction efficiency data
were available, interpreting anthrax analytic results was problematic.

8We use "sampling event" to refer to initial sample collection by a
specific agency on a specific day and at a specific time in a specific
facility. Multiple agencies collected samples on the same day in some of
the same facilities; therefore, each agency's sample collection is
considered a separate sampling event. As a result, there were more
sampling events than the total number of facilities sampled.

9Earlier, according to USPS officials, they collected other types of
samples, such as wet wipes, to be analyzed by a portable, field-based
analytic method, as well as two "quick tests," or hand-held assays (HHA)
in one facility in Washington, D.C. And in multiple facilities in the New
York area, CDC used only dry swabs, following a requirement by New York
public health laboratories.

The final activity involved analyzing the extracted material with specific
analytic methods for preliminary and confirmatory identification of
anthrax. Some problems were experienced during preliminary analysis
because (1) knowledge of the limits of detection for the field-based tests
was lacking and (2) there were not enough trained personnel to use these
methods.

The results of the CDC, EPA, and USPS testing in 286 postal facilities
were largely negative. But negative test results do not necessarily mean
that a facility is free from contamination, a conclusion that, according
to CDC, was stated at the time of the testing. Results can be negative if
(1) samples were not collected from places where anthrax was present, (2)
the detection limit of the sampling method was greater than the actual
contamination level, (3) not enough samples were collected, (4) not enough
spores were recovered from the sample material, (5) analysis of the sample
extract did not detect anthrax spores, or (6) anthrax was not present in
the facility. Of 286 facilities, 23 tested positive. For 2 of these 23
facilities, test results were negative at first but positive on a
subsequent testing. However, in 1 of these facilities-the Wallingford,
Connecticut, facility-it was not until the fourth testing that positive
results were obtained.

The federal agencies' activities to detect anthrax contamination were not
validated.10 The significance of the lack of validation of the agencies'
various detection activities was highlighted in our discussions with
scientists and researchers who have worked on microbial detection in
indoor environments. Their opinions differed on sampling methods and
sample material appropriate for environmental sampling and the processes
necessary for validating methods. The opinions of public health and agency
officials involved in making decisions on responding to anthrax
contamination also differed. Validation, as it is generally understood, is
a formal, empirical process in which the overall performance
characteristics of a given method are determined and certified by a
validating authority as (1) meeting the requirements for the intended
application and (2) conforming with applicable standards. Because the
agencies did not use an empirical process to validate their testing
methods, the agencies had limited information available for reliably
choosing one method over

10In commenting on our draft report, CDC stated that the Laboratory
Response Network (LRN) confirmatory test assays for detection of anthrax
were validated. However, we were not provided with supportive
documentation of methodologies used for such validation.

another and no information on the detection limit to use when evaluating
negative results.11

Without validation, the sampling activities could have been based on false
assumptions. For example, the lack of validated sample collection methods
means that it is not known how many spores a particular method will
collect from a surface and, thus, which method is appropriate for a given
situation. Using an ineffective method or procedure could result in a
finding of no contamination when in fact there is contamination-a false
negative. Because the sampling methods are not validated, it is not known
to what extent they will underestimate contamination. Thus, in the case of
a negative result, agencies would have no sound basis for taking public
health measures for the occupants of the contaminated facility.

Validating the overall process is important because operational and
healthrelated decisions are made on the basis of testing results generated
by that process. In addition, validation would offer assurance that the
results of using a particular method, which is part of that process, are
robust enough to be reproduced, regardless of which agency, contractor, or
laboratory is involved. Thus, agencies and the public could be reasonably
confident that any test results generated by a process that includes that
method would be reliable and, in particular, that any negative results
would mean that a sample was free from contamination (within the method's
limits of detection).

In preparing for future incidents, the agencies have (1) made some changes
based on what has been learned about some of the limitations of their
sampling strategies, (2) made some revisions to their guidelines to
reflect some of this knowledge and experience or developed new ones, (3)
funded some new research, and (4) planned or conducted conferences
addressing some of the issues we have identified. In addition, the
Department of Homeland Security (DHS) has taken on the role of
coordinating agencies' activities and has undertaken several new
initiatives related to dealing with anthrax and other biothreat agents.

However, while the actions DHS and other agencies have taken are
important, they do not address the issue of validating all activities
related

11In commenting on our draft, CDC stated, "methods were selected based on
factors such as comparable and available knowledge, studies on fungal
spores, and in view of the immediate need for emergency response."

to sampling. Since the fall of 2001, studies have been performed, or are
under way, that may contribute to the validation of the individual
activities. Nonetheless, these studies address only some aspects of an
individual activity rather than the overall process. Finally, the agencies
have not made appropriate and prioritized investments to develop and
validate all activities related to other biothreat agents.

Accordingly, we recommend that to improve the overall process for
detecting anthrax and to increase confidence in negative test results
generated by that process, the Secretary of Homeland Security develop a
coordinated approach. This approach would include working with agencies to
ensure that appropriate validation studies of the overall process of
sampling activities, including the methods, are conducted. Specifically,
the Secretary should (1) take a lead role in promoting and coordinating
the activities of the various agencies with technical expertise related to
environmental testing; (2) ensure that a definition of validation is
developed and agreed on; (3) guarantee that the overall process of
sampling activities, including methods, is validated so that performance
characteristics, including limitations, are clearly understood and results
can be correctly interpreted; (4) see that appropriate investments are
made in empirical studies to develop probability-based sampling strategies
that take into account the complexities of indoor environments; (5) ensure
that appropriate, prioritized investments are made for all biothreat
agents; and (6) make sure that agency policies, procedures, and guidelines
reflect the results of such efforts.

DHS stated that while it has the overall responsibility for coordination,
EPA has the lead role in responding to biological attacks. However, DHS
stated that it will coordinate with EPA to ensure that appropriate
investments are made to explore improved sampling. But concerning our
recommendation about probability-based sampling strategies, DHS said that
it first wanted to develop sampling requirements and then evaluate both
targeted and probability-based sampling against those requirements. We
believe that DHS's evaluation of sampling will result in a conclusion that
probability-based sampling strategies are necessary to (1) answer the
question-Is this building contaminated?-and (2) achieve DHS's goal of
having a "scientifically defensible sampling strategy and plan."

While CDC and USPS, as well as APHL, agreed with the importance of using
validated testing methods, they raised various concerns about our
discussion of validation or targeted versus probability-based sampling.
While we clarified our discussion to address these concerns where
appropriate, we continue to believe that our findings on the need for

Background

validated testing methods and probability-based sampling strategies are
well supported by the evidence, which we have presented in our report.

Although anthrax can infect humans, it is most commonly found in
planteating animals. Human anthrax infections are rare in the United
States, and when infection does occur, it usually results from
occupational exposure to infected animals or contaminated animal products,
such as wool, hides, or hair. Anthrax infection can occur (1) cutaneously,
usually from a cut or abrasion on the skin; (2) gastrointestinally, by
ingesting undercooked, contaminated meat; and (3) through inhalation, by
breathing aerosolized, or airborne, spores into the lungs.

Anthrax is aerobic and facultative anaerobic; it can grow in aerobic (with
oxygen) or anaerobic conditions. It is gram-positive-that is, when stained
with a special solution (Gram's stain), the bacteria retain the color of
the solution. Anthrax forms spores and is not capable of movement. The
vegetative cell is 1 to 8 microns long and 1 to 1.5 microns wide; spore
size is approximately 1 micron.12 Spores germinate, growing readily on
most ordinary nutrient media in the laboratory.

When the spores are germinating and are growing in a vegetative state,
rather than dormant, and viewed through a microscope, they are said to
look like "jointed bamboo rods." However, to the naked eye, anthrax
vegetative cells growing on plates characteristically have the appearance
of a "Medusa head" (with a curled edge) and "ground glass" (with a rough
surface). Anthrax spores germinate and form vegetative cells after the
spores enter a host. Vegetative cells multiply rapidly in an environment
rich in nutrients, such as the blood or tissues of an animal or human
host. Although vegetative cells have poor survival rates outside the host,
anthrax spores are hardy and can survive for decades in the environment.

The Environmental The response to the incident in the American Media
Incorporated building

Sampling Response 	in Florida in September 2001 led to the identification
of mail as the potential source of contamination; eventually, it led to
the sampling of the postal facilities. The agencies began sampling on
October 12, 2001, in Florida and stopped on April 21, 2002, when the
Wallingford, Connecticut,

12A micron is 1 millionth of a meter, or about 1 thousandth of a
millimeter. The period at the end of this sentence is approximately 500
microns in diameter.

facility was sampled for the last time. The following are key events
related to the response in the postal facilities:

On October 5, 2001, the death of an American Media employee from
inhalation anthrax disease triggered an investigation by CDC, DOD, EPA,
and the FBI. Since a contaminated envelope or package was not recovered in
Florida, the agencies could not initially establish how the anthrax was
delivered-whether by U.S. mail or some other means, such as courier.
According to USPS, the combination of the Florida incident and the opening
of the letter to Senator Daschle on October 15 established the link to the
U.S. mail system. As early as October 10, CDC investigators had considered
the possibility that USPS had delivered the letter containing anthrax. On
October 12, USPS learned that it had delivered the contaminated letter,
which was eventually recovered at the National Broadcasting Company.

On or about October 9, 2001, at least two letters containing anthrax
spores-those to Senators Daschle and Leahy-entered the U.S. mail system.
Before the letters were sent to the Brentwood facility in Washington,
D.C.,13 they were processed on high-speed mail sorting machines at a
postal facility in Hamilton, New Jersey, known as the Trenton facility. In
addition, two other recovered letters had been sent to a television news
anchor at the National Broadcasting Company and to the editor of the New
York Post in New York City; according to USPS, these letters were
postmarked September 18, 2001. Discovering the contaminated letters
resulted in a focus on the postal facilities involved in processing these
letters.14 The agencies reacted to events as more information became
available.

On October 18, 2001, the USPS sampling effort began in the Brentwood
facility. Its nationwide, or "precautionary," sampling, which was to rule
out contamination in facilities considered less likely to be contaminated,
began on or about October 28, 2001, according to USPS officials, and

13The Brentwood facility was renamed the Joseph Curseen Jr. and Thomas
Morris Jr. Processing and Distribution Center, in memory of the two
Brentwood employees who died of inhalation anthrax.

14The two recovered letters sent to the National Broadcasting Company and
the New York Post were processed on high-speed mail sorting machines at
the Trenton facility and the Morgan facility, the New York facility that
also processed these letters, while the letters to the two senators were
similarly processed at the Trenton facility in New Jersey and the
Brentwood facility in Washington, D.C.

ended on April 21, 2002, with the final sampling in the Wallingford
facility.15 According to USPS, it followed the "mail trail" and sampled on
the basis of the likelihood of finding additional contamination if it
existed. Mail flow data were used as initial criteria to identify
facilities that received 1 percent or more of their mail from either the
Trenton or Brentwood P&DCs other facilities were included on the basis of
"plausible nonmail pathways," for example, a repair facility and stamp
fulfillment center. The postal command center was responsible for facility
testing and cleanup.

Four contractors conducted USPS sampling. FBI sampling began on October
12, 2001, in the Florida facilities and ended on November 16, 2001.16 CDC
and EPA sampling began on October 15, 2001, and ended in the Florida
facilities on November 3, 2001. In addition to CDC's sampling of the
Florida facilities, CDC began sampling other postal facilities on October
21, 2001, and ended on December 2, 2001. CDC's part in the sampling effort
involved what it termed "outbreak investigation" sampling and included
facilities associated with the primary facilities or with an employee's
illness. According to CDC, the outbreak investigation included facility
testing in part because postal employees at a specific facility had
contracted anthrax (for example, Trenton and Brentwood P&DCs). In
addition, CDC, as part of its epidemiologic investigations, 17 was looking
for clues to the role that cross-contaminated mail might have played in
nonpostal anthrax cases (for example, in the Morgan, Wallingford, and West
Palm Beach facilities). Finally, based on mail flow patterns, CDC
concluded that facilities may have been cross-contaminated, even if no
anthrax cases were known (for example, all 50 post offices downstream from
the Trenton facility).

On October 30, 2001, according to USPS, the diagnosis of illness in a New
York City woman raised the possibility of cross-contamination. According
to CDC, a key finding, suggesting secondary contamination,

15USPS officials told us that "nationwide" testing referred to the
"downstream," or "precautionary," testing it performed. In this report, we
refer to such testing as precautionary.

16Additional testing may have taken place beyond November 16, 2001, due to
the ongoing criminal investigation.

17Epidemiology, a branch of medical science, investigates the incidence,
distribution, and control of disease in a population. When CDC identifies
the first confirmed case of an unusual illness, such as anthrax infection,
it begins an investigation to identify new cases, unreported cases,
contacts, and risk factors.

was the cutaneous anthrax illness of a New Jersey mail carrier who did not
work at the Trenton facility. CDC, EPA, USPS, and the FBI sampled 286
postal facilities. According to USPS, to identify a good representation of
facilities across the network for testing, it selected facilities based
upon USPS knowledge of mail flows across the country. The intent was to
show anthrax had not spread beyond the two sites that had been identified
as being contaminated. Testing sites included facilities such as a mail
recovery center, mail transport equipment center, and the Topeka repair
center, as well as other P&DCs. The belief was that if anthrax
contamination was found in these facilities-which USPS referred to as
trading partners-then additional sampling would be required in downstream
facilities connected to the trading partners.

                                USPS Mail System

The mission of USPS is to provide affordable, universal mail service. As
of May 28, 2004, more than 800,000 workers processed more than 200 billion
pieces of mail a year. The USPS headquarters office is in Washington, D.C.
USPS has nine area offices; approximately 350 P&DCs and about 38,000 post
offices, stations, and branches; the P&DCs vary widely in size and
capacity. The USPS mail system is involved in collecting, distributing,
and delivering letters, flats (that is, catalogs and magazines), and
parcels, as well as other items that vary in size and capacity.

USPS provides for the security of the mail and for enforcing federal
postal laws through its Postal Inspection Service. This service employs
approximately 1,970 fact-finding and investigative postal inspectors and
1,100 uniformed postal police officers.

Mail processing facilities use several types of high-speed machines to
process letters. At the facility that initially receives a letter for
mailing, an advanced facer-canceller system cancels the postage stamp. For
identification and sorting, other machines with optical character readers
apply bar codes and markings (that is, identification tags) to the
envelopes. The tags identify the time and date of processing, the machine
and facility that processed the envelope, and the delivery destination.
During fall 2001, USPS used this information to track the path of
contaminated envelopes through the mail system.

Delivery bar code sorter (DBCS) machines sort the mail. One machine alone
processes about 37,000 letters an hour, using pinch belts that repeatedly
squeeze the letters. During processing, paper dust accumulates,
particularly near pinch rollers that move the mail through the machine.
Since the rollers and optical readers are hard to access with vacuum

nozzles, compressed air was typically used to blow debris out of the
machine. The compressed air was, however, banned in October 2001 because
of concern about the potential for spreading anthrax in mail processing
facilities.

Federal Agencies Involved in Anthrax Detection in Postal Facilities Had
Differing Responsibilities

The federal agencies involved in the response in the postal facilities had
differing responsibilities. CDC and state and local health departments
primarily provided public health advice and assistance to USPS. CDC has
had primary responsibility for national surveillance of specific diseases,
including anthrax; it has also conducted epidemiologic investigations to
determine, among other things, the source of the disease. The FBI has been
responsible for criminal investigations involving interstate commerce and
the mail and crimes committed on federal property.18 EPA has been the
nation's lead agency for responding to a release of hazardous substances
into the environment.

Responding to health emergencies, including bioterrorist attacks, is
generally a local responsibility, but localities could and did request
CDC's assistance in the fall of 2001. CDC performed the tests needed to
confirm cases of anthrax and analyzed the substances in the two
contaminated letters recovered in New York City. ATSDR and NIOSH within
CDC helped USPS conduct environmental tests of some of its facilities and
advised USPS on its facilities' decontamination. The U.S. Army Medical
Research Institute for Infectious Diseases (USAMRIID) has conducted basic
and applied research in the diagnosis, treatment, and prevention of
hazardous infectious diseases for the military. It analyzed some
environmental samples from postal facilities.19 It also performed detailed
analyses, for the FBI, of anthrax spores in the letters addressed to
Senators Daschle and Leahy. OSHA, responsible for employee health and
safety issues, provided technical assistance and guidance to USPS on the
decontamination of postal facilities.

18The U.S. Postal Inspection Service-responsible for, among other things,
protecting the mail system from criminal misuse-assists the FBI in
criminal investigations. Numerous federal, state, and local agencies were
also involved.

19According to USAMRIDD officials, this work was only part of the
comprehensive evaluation the FBI requested for analyzing the spores;
additional laboratories participated, as requested, for specialized
evaluations.

On October 8, 2001, the President created the Office of Homeland Security
to develop and coordinate a comprehensive national strategy for dealing
with domestic terrorist threats or attacks. The office, which had limited
involvement in the 2001 response, was superceded by the Homeland Security
Act of 2002, which transferred many of its functions to DHS; it became
operational in 2003. DHS was created by combining many previously separate
agencies and is assigned a lead role in coordinating the efforts of
federal agencies that respond to acts of terrorism in the United States.

The Laboratory Response Network

According to CDC, plans to mitigate anthrax outbreaks related to
bioterrorism began in 1998, when CDC hosted a workshop on response to
possible bioterrorism acts.20 The following year, HHS and CDC established
the National Pharmaceutical Stockpile, and CDC collaborated with the FBI
and APHL to develop the Laboratory Response Network (LRN) to coordinate
detection and identification capabilities for threat agents associated
with the testing of human specimens and environmental samples that could
be related to bioterrorism.21 LRN was developed in 1999 to coordinate
clinical diagnostic testing for bioterrorism. The primary purpose on the
biological side was to detect the presence of biothreat agents in a number
of specimen and sample types, especially since CDC was working closely
with the FBI relative to its preparedness and response needs for law
enforcement. Originally set up in four levels, A to D, LRN now consists of
three levels of laboratory response: sentinel (level A), reference (levels
B and C), and national laboratory (level D). Sentinel laboratories include
clinical laboratories certified under the Clinical Laboratories
Improvement Act (CLIA) of 1967, with biosafety level (BSL) 2 safety
practices.22 These laboratories function as first responders that can
perform standard initial tests to rule out, but not definitively confirm,
anthrax.

20B. T. Perkins, "Public Health in a Time of Bioterrorism," Emerging
Infectious Diseases 8 (2002): 1015-17. See CDC, "Comprehensive Procedures
for Collecting Environmental Samples for Culturing Bacillus anthracis"
(Atlanta, Ga.: U.S. Department of Health and Human Services, rev. Apr.
2002).
http://www.bt.cdc.gov/agent/anthrax/environmental-sampling-apr2002.asp
(Jan. 10, 2005).

21Effective March 1, 2003, the National Pharmaceutical Stockpile became
the Strategic National Stockpile.

22Biosafety levels consist of different combinations of laboratory
practices and techniques, the use of specific safety equipment, laboratory
facilities suitable for the procedures performed, the hazard posed by the
infectious agents, and the laboratory functions.

Reference laboratories have core capacity for isolating agents and
confirmatory testing. They include most state and local public health
laboratories, with BSL 3 containment facilities that have been given
access to nonpublic testing protocols and reagents. 23 These laboratories
function to "rule in and refer" and thus have advanced capacity for the
rapid identification of anthrax. The LRN national laboratories include
only laboratories at CDC and USAMRIID. These laboratories, with the
highest containment level (BSL 4), have expertise in diagnosing rare and
dangerous biologic agents.

CDC guidance, prepared and revised during the response, stated that
lowrisk (nonpowder) environmental samples should be processed according to
LRN level A protocols for rule-out testing in a CLIA-certified laboratory,
using BSL 2 facilities and BSL 3 safety practices.24 In April 2002, CDC
revised the guidelines, which stated that swab samples collected for
ruleout testing should be analyzed at an LRN level A laboratory, using BSL
2 facilities and BSL 3 safety practices.25 All other samples-including
bulk (for example, a piece of carpeting), wipes, air samples, and vacuum
samples-were to be analyzed for anthrax at an appropriate LRN level B or C
laboratory, using BSL 3 facilities. Qualified laboratories report anthrax
test results either qualitatively (for example, positive or negative) or
quantitatively (for example, as a specific number of colony forming units
[CFU] or living cells per gram or per square inch of material sampled),
since CFUs do not equal one or a specific number of spores and the
contamination may be either heterogeneously or homogeneously distributed.
The results underestimate the total number of spores. It is important to
note, however, that a negative result means only that no anthrax was
detected in the sample analyzed and that it does not unequivocally
determine the status of the facility or health risk to an individual.

23A reagent is any substance used in detecting another substance by
chemical, microscopic, or other means.

24CDC, Procedures for Collecting Surface Environmental Samples for
Culturing Bacillus anthracis (Atlanta, Ga.: U.S. Department of Health and
Human Services, October 28, 2001). The guidelines included instructions
for collecting bulk, premoistened swabs and HEPA vacuum samples as well as
the level A testing protocol for premoistened swab samples. Presumptive
positive swab samples were to be referred to an LRN state public health
laboratory for confirmatory testing by LRN level B protocol for
identification of anthrax.

25CDC, "Comprehensive Procedures for Collecting Environmental Samples for
Culturing Bacillus anthracis" (rev. Apr. 2002).

Terms Associated with Sampling Methods and Procedures

Sampling generally refers to the selection of a representative portion of
a population, universe, or body. In this report, we refer only to the
collection of environmental samples from the postal facilities and
associated activities and procedures. Environmental sampling, in this
context, refers to the collection of material from an environment, such as
a surface or the air, by using a specific sample collection method and
specific procedures or protocols. Environmental sampling is used to
determine the extent and degree of contamination, assess the risk of
exposure, support decisions related to medical treatment or cleanup, and
determine when cleanup is sufficient to allow an area to be reoccupied.

Objectives for sampling vary. For example, sampling to detect whether
anthrax is present, or to rule its presence out, is referred to as initial
sampling. Sampling to determine the extent of contamination-for example,
how far it has spread in a facility-is referred to as characterization
sampling. Sampling to determine whether decontamination of a facility has
been effective is referred to as verification sampling.

Air and surface sample collection methods are of several types. Swabs,
premoistened or dry, have small surface areas (they are similar to
Q-tips(R) cotton swabs) and are typically used to collect samples from
small, nonporous surfaces that do not have a large accumulation of dust.
Wet wipes-sterile gauze pads-are typically used to collect samples from
larger, nonporous surfaces. A HEPA vacuum is a suction device with a
nozzle that has a filter attached to it for collecting dust samples from a
surface or the air. Microvacuuming techniques allow the collection of
samples by air sampling pumps.

Bulk samples can help detect the presence of contamination on building
materials; office equipment; small articles such as letters or packages;
carpeting; and heating, ventilating, and air conditioning (HVAC) filters.
Air sampling that results in culturable samples can be done by a variety
of methods, which include sampling pumps and filters (gelatin,
polytetrafluoroethylene, and the like) placed inside sampling cassettes.
Air sampling may be used to characterize the air concentration of anthrax
spores.

In this report, "sensitivity" refers to the minimum number of anthrax
spores that a collection method can pick up and that an analytic method
requires to generate a positive result. "Specificity" refers to a method's
ability to accurately discriminate between anthrax and other bacterial
species. "Repeatability" refers to a method's ability to produce the same

results several times under the same conditions. "Reproducibility" refers
to a method's ability to produce similar results under similar conditions,
when performed by different persons independently in different locations.
For example, for analytic methods, reproducibility would be a measure of
the variations in test results across similar tests conducted in different
laboratories or in the same laboratory on different occasions.

"Collection efficiency" refers to the percentage of viable anthrax spores
present in a sampled environmental area that are removed from the surface
by various sample collection methods (e.g., a swab or wipe).

"Recovery efficiency" refers to the number of viable spores- for example,
the number of CFU in plate culture-that are detected as growing by various
analytic methods.

"Accuracy" in the context of analytical tests refers to the closeness of
the test results obtained by a particular method to the true value.

"Robustness" refers to a method's ability to yield a high number of
correct responses when performed under a variety of different experimental
conditions.

"Limit of detection" refers to the lowest amount of analyte in a sample
that can be detected, but not necessarily quantified, under stated
experimental conditions. The detection limit is usually expressed as a
concentration (e.g., percentage, or parts per billion) in a sample.

CDC, EPA, and USPS, the federal agencies involved in sampling the postal
facilities in 2001 to detect anthrax, undertook several activities: (1)
sampling strategy development, followed by (2) sample collection, (3)
transportation, (4) extraction, and (5) analysis of the samples (see fig.
1). As we discuss below, neither these activities nor the overall process
was validated for anthrax testing. Consequently, the agencies were
challenged due to limited information available for reliably choosing one
method over another and no information on the detection limit to use when
evaluating negative results. The sampling strategy used by the agencies
could not provide any statistical confidence with regard to the question:
Is this building contaminated? Therefore, in the future, in the absence of
a positive result, a different strategy is needed that will provide
statistical confidence, at a defined level, to the answer to this
question.

Agencies Were Challenged by Problems Associated with Sampling Activities

Figure 1: Agency Sampling Activities

Source: GAO analysis of CDC, EPA, and USPS data.

                                       5

Sample analysis

Of living organisms in preliminary
tests
and
confirmatory
tests

Activity 1: Sampling Strategy Development

One challenge the agencies faced was to rapidly develop an effective
sampling strategy to detect anthrax in facilities of varying sizes that
had complicated machinery and complex surfaces. A sampling strategy
includes such elements as how many samples to collect, where to collect
them from, and what collection method to use. The targeted strategy the
agencies used was reflected in their site-specific sampling activities.
Sample sizes varied by facility and circumstances, increased over time,
and excluded probability sampling.

According to CDC, EPA, and USPS officials, they generally "followed the
mail trail" in collecting samples. They determined which areas were
involved in mail processing, from their knowledge of the potential path of
the contaminated letters-that is, by analyzing the actual path of the mail
from mail flow data-and from discussions with facility managers and from
epidemiological data. We describe their site-specific approaches below.

USPS's strategy was reflected in its Standard Sampling Plan, for use by
USPS contractors in selected precautionary testing in postal facilities
USPS considered less likely to be contaminated.26 According to USPS, the
sampling strategy evolved in October and November 2001 as mail flows in
the anthrax incident were identified and prescreening was assessed. The
first version of the Standard Sampling Plan that USPS used was dated
November 2, 2001; it was followed by numerous revisions.

26According to USPS officials, before USPS developed its Standard Sampling
Plan, it had been conducting testing in response to events at individual
facilities. See USPS, Standard Sampling Plan, draft (Washington, D.C.:
Nov. 9, 2001).

The plan specified the number of samples to be collected, which increased
as the investigation unfolded. In the beginning, in each facility, 23
samples were to be collected from specific areas relating to mail
processing and up to 20 additional "discretionary" samples were to be
collected, depending on the type and size of the facility. Later, USPS
increased the number of samples required to a minimum of 55, with up to 10
additional discretionary samples for larger facilities. Consequently, the
number of samples collected varied by facility, from a low of 4 to a high
of 148.27

CDC's and EPA's site-specific strategies were primarily discretionary.
According to CDC, for example, decisions as to the number and location of
samples to be collected were based on discussions with facility managers
and others, reviews of facility floor plans, and observations to identify
possible contamination pathways and locations, which were then targeted
for sample collection. The numbers of samples CDC collected varied by
facility, ranging from a low of 4 to a high of 202.28

EPA's site-specific strategy for the postal facilities it sampled in
Florida, in coordination with CDC, on October 31, 2001, was to
"characterize" the extent of anthrax spores in a post office suspected of
having handled contaminated mail; it also focused on decontamination
issues. Like USPS, EPA's plan involved a targeted sampling strategy but
did not specify the number of samples to be collected. However, it did
state that "characterizing a PO [post office] where there is no evidence
that suspect contaminated mail has been handled is problematic." It also
stated that from discussions with postal service officials, employees, and
unions, as well as a review of suspected locations, the "sampling
locations will be identified that are most likely to contain residue from
suspect postage." 29

27These numbers represent samples collected for culture analysis: the 4
excluded samples USPS collected for analysis by the portable polymerase
chain reaction (PCR) instrument that USPS used in some facilities or the 2
"quick tests" performed at Brentwood on October 18, 2001.

28According to CDC, the facility in which the 4 were collected did not
include mail-sorting equipment.

29Post Office Sampling Plan-Florida, Revision 1 (Oct. 31, 2001).

The numbers of samples EPA collected ranged from a low of 4 to a high of

71. EPA did not develop a guidance document.30

USPS and CDC developed guidance. USPS, responding to the finding of
contamination in a number of its facilities, developed draft interim
guidance, revised several times, intended solely for USPS facilities.31
The November 5, 2001, guidance addressed issues such as sampling,
decontamination, communication, employee notification, and interim
cleaning procedures.32

Shortly after CDC became involved in sampling activities in postal
facilities, CDC developed "Comprehensive Procedures for Collecting
Environmental Samples for Culturing Bacillus anthracis" for industrial
hygienists and environmental health professionals who might be called on
to collect samples. 33 The document addressed issues to consider when
collecting anthrax samples, such as general locations and collection
methods and procedures. The guidance stated that the number of samples
collected was to be "influenced by the circumstances of the potential
contamination." It also stated "a sufficient number of samples must be
taken to increase the probability that the sampling is representative of
the extent of contamination." However, it did not define "representative"
or specify what methodology to use to determine sample size.

30In September 2002, the National Response Team, chaired by EPA, developed
a draft "reference tool" to reflect agencies' experience responding to the
2001 anthrax contamination; see National Response Team, Technical
Assistance for Anthrax Response, Interim-Final Draft Phase I Update
(Washington, D.C.: Nov. 2003).
http://www.nrt.org/Production/NRT/NRTWeb.nsf/AllAttachmentsByTitle/A-47AnthraxTAD/
$File/Anthrax.pdf?OpenElement (Jan. 9, 2005).

31USPS, Draft Interim Guidelines for Sampling, Analysis, Decontamination,
and Disposal of Anthrax for U.S. Postal Service Facilities (Washington,
D.C.: Nov. 8, 2001, rev. Dec. 4, 2001).

32The guidance evolved. In the beginning, for smaller facilities, it
provided for collecting 23 samples from specific areas involved in mail
processing, with up to 10 additional discretionary samples; for larger
facilities, the guidance eventually provided for collecting 55 samples,
with up to 10 discretionary samples.

33NIOSH said it had posted the guidance on CDC's Web site and that the
guidance was updated in April 2002. See CDC, "Comprehensive Procedures for
Collecting Environmental Samples for Culturing Bacillus anthracis"
(Atlanta, Ga.: U.S. Department of Health and Human Services, rev. Apr.
2002).
http://www.bt.cdc.gov/agent/anthrax/environmental-sampling-apr2002.asp
(Jan. 10, 2005).

Agencies Primarily Used a Targeted Strategy

CDC and USPS officials said that they used targeted sampling-they
collected samples from specific areas considered, based on agencies'
technical judgments, more likely to be contaminated. This strategy was
reflected in agencies' site-specific plans and guidance and included
judgments about where anthrax was likely to be found, such as a mail
processing area.34 Such judgments can be effective in some situations, for
example, in determining the source of contamination in a disease outbreak
investigation, provided results are positive. However, if the results are
negative, the basic question-Is this building contaminated?-cannot be
answered with statistical confidence.

According to CDC, in a situation where there is confidence that the source
and path of contamination are known, a targeted sampling strategy (that
is, a judgmental approach) can result in a successful and efficient use of
resources.35 In addition, CDC stated that it used empirical methods to
gather information from various sources in order to identify plausible
contamination pathways and to classify locations by contamination
potential. CDC used "judgmental" worst-case approaches to collect from the
"most likely contaminated" locations. CDC further stated that these
approaches were derived from "maximum risk employee" approaches,
traditionally used for initial sampling strategies in occupational health
to identify employees believed to have the greatest exposure in a
workplace.36

CDC believes that targeted sampling "allows scientific inferences about
contamination." In commenting on the draft of this report, CDC stated that
in a well-developed targeted sampling strategy, "if you cannot detect the
agent in a high-probability area, it is improbable that a low-probability
area

34These judgments, according to CDC, "relied primarily on using existing
law enforcement, epidemiology, and event details to identify locations
where anthrax was most likely to be found."

35CDC provided the following example of a targeted strategy: The use of
postal code information, from the recovered Senator Daschle letter, to
identify that Brentwood DBCS machine # 17 was the one that processed the
letter. Machine # 17 was then targeted for sampling with specific
attention to those locations closest to the mail path through the machine.
Judgmental approaches not only produced the highest probability of
identifying a positive sample during the 2001 response but they helped to
establish those locations that posed the greatest risk of exposure.

36In 2001, preliminary information was used to identify, for sampling,
those surfaces (e.g., sorting machines and mail sorting bins) considered
"most likely to have been contaminated."

would produce a positive result." This assertion appears to be reasonable
at face value. However, finding a positive result depends on several
factors, such as the accuracy of identifying the source of contamination
and the detection limit of the sample collection and analytical methods.

According to CDC, it conducts outbreak investigations in a manner that in
its judgment optimizes the chance of locating the source of contamination.
CDC's preference for targeted sampling is based on the need to rapidly
identify the source of contamination in order to institute early public
health interventions. CDC, however, agrees: "targeted sampling does not
support statistical inferences."

CDC and USPS officials said that they used a targeted strategy for several
reasons, including limitations on how many samples could be collected and
analyzed. They also said that in 2001 they lacked the data necessary to
develop an initial sampling strategy that incorporated probability
sampling.37 We disagree with this interpretation. Probability sampling is
statistically based and does not depend solely on empirical criteria
regarding the details of possible contamination.

CDC officials said that the numbers of samples that could be collected
were limited by laboratory capacity for analyzing samples. For example,
according to the CDC official in the Morgan facility in New York, CDC
sampling was restricted to "56 dry swab samples because the New York City
health department was `overwhelmed' with samples from so many other
places." CDC also had a number of different location-specific sampling
goals.38

CDC, EPA, and USPS officials provided various comments on factors involved
in developing sampling strategies. According to a CDC official, CDC "does
not use statistical sampling in its initial assessment sampling"; the
official was not aware of any literature demonstrating that "statistical

37According to CDC, the missing data included "size of the hot spot, limit
of detection, surface contamination risk criteria."

38According to CDC, epidemiologic sampling was needed in some locations to
examine potential exposure pathways for nonpostal anthrax cases. Some
local public health authorities requested that locations less likely to be
contaminated (such as public areas at P&DCs) be sampled in order to help
decide the need to provide personal protective equipment to members of the
public.

sampling" is any more effective than CDC's approaches.39 However, we did
not find any empirical support that for initial sampling, targeted
sampling is better than probability sampling.

According to an EPA official, "if there is some knowledge available about
the release, then sampling in targeted locations is the best approach;
otherwise, a grid sampling approach could be used, but a sufficient number
of samples then would need to be collected."40 The official said that
developing a statistically based sample size requires knowing the
substance (for example, anthrax) and the performance efficiency of the
sample collection methods. EPA did not have this knowledge for anthrax.
Finally, the official stated that statistical sampling could be done for
other substances, such as polychlorinated biphenyl, a chemical that can
cause cancer in humans.

USPS officials said that they had learned lessons from the sampling
conducted in the Wallingford facility in 2001. Consequently, in April
2002, for both initial and verification sampling of the Wallingford
facility, according to USPS officials, they used grid-based sampling. This
resulted in their finding three positive samples containing only a few
spores out of the total samples collected in the facility's high-bay area,
that is, elevated areas including pipes, ducts, lights, joists, beams, and
overhead conveyors.

Incorporating Probability According to CDC, a targeted sampling strategy
may be effective in Sampling Would Allow Greater detecting contamination
in a facility when sufficient site-specific Confidence in Negative Results
information exists to narrow down the locations in which the release and

contamination are most likely to have occurred.41 CDC's assumptions for
this strategy are that at the outset, (1) a scenario where all locations
have

39Citing a paper by Carlson and colleagues, CDC stated, "Statistical
sampling approaches for surface contamination most commonly address
verification (clearance sampling) approaches." The paper also includes
other information requirements, such as specifying the (1) maximum
acceptable level (that is, the level above which a surface is not
considered clean enough), (2) largest acceptable hot spot, and (3) desired
probability with which a single hot spot must be discovered. See T. M.
Carlson and others, Sampling Requirements for Chemical and Biological
Agent Decontamination Efficacy Verification (Washington, D.C.: U.S.
Department of Energy, Mar. 29, 2001).

40Grid sampling is a probability sampling method used to systematically
sample twodimensional areas.

41Examples of such information range from law enforcement findings about
the location of an event to engineering information about machines that
might aerosolize spores, to medical epidemiology findings about where
affected individuals worked.

an equal chance of being contaminated is generally the exception rather
than the rule; (2) information collected about the event, combined with
technical judgment about exposure pathways, can be used to identify
locations where contamination is most likely to be found; (3)
contamination levels of highest public health concern can usually be
detected using a variety of available methods, despite their limitations;
and (4) there is important public health value in quickly identifying
contaminated locations. However, these assumptions may not always apply.
For example, there may be limitations in the available information that
restrict the ability to reliably identify target locations. The method of
contamination spread could conceivably be via a mechanism where there is
an equal chance of any area being contaminated. Lastly, all results may be
negative, which will lead to a requirement for additional testing, as was
the case in Wallingford. This, in turn, will result in the loss of the
critical time needed for public health intervention. Therefore, there is a
need for probability sampling at the outset to provide statistical
confidence in the interpretation of negative results.

We consider probability sampling to be a viable approach that would
address not only the immediate public health needs but also the wider
public health protection, infrastructure cleanup, and general
environmental contamination issues. In any particular facility,
probability sampling could operate in the following ways: At the outset of
a response, a statistically based probability sampling plan would be
drawn, based on the facility dimensions, complexities, and other
characteristics. We recognize that in a major incident, the number of
samples that may need to be collected and analyzed may challenge available
laboratory resources. Accordingly, there is a need to develop innovative
approaches to use sampling methods that can achieve wide-area coverage
with a minimal number of individual samples to be analyzed. For example,
HEPA vacuum techniques, in combination with other methods, appear to be
one such approach that could achieve this. In addition, because of limited
laboratory capacity, samples may need to be stored after collection for
subsequent analysis, on a prioritized basis.

Initial outbreak sampling, within the dictates of the probability-sampling
plan, could be targeted to those areas that, based on technical judgments
(if available), would be considered-when the information on the source of
contamination is definitive-most likely to be contaminated. Thus, targeted
sampling, from a public health perspective, is recognized as an important
component of the wider probability sampling plan. If these early
(targeted) samples yield positive results, then appropriate public health
measures could be instituted. Further sampling of the facility could take

place over a longer period in order to address characterization and
cleanup issues. Conversely, if initial targeted samples were negative,
completing the probability sampling plan would then permit an assessment,
with appropriate confidence limits, of the likelihood of contamination,
even if all of the samples collected under the plan were negative.

We recognize that the use of probability sampling could have strained
laboratory capacity in 2001 (for example, limited analytical capacity may
not permit a laboratory to analyze all samples on a given day). However,
there are several potential solutions, including (1) not all samples, once
collected, have to be analyzed on the same day (given the fact that
anthrax spores do not deteriorate while in acceptable storage conditions
in the laboratory) and (2) laboratory capacity can be increased by hiring
more staff for the existing laboratories, transporting the samples for
analyses to more than one laboratory, and establishing additional
laboratories. Probability sampling would offer a defined degree of
statistical confidence in the negative results. A known level of
confidence is needed because evidence suggests that even a few anthrax
spores could cause disease in susceptible individuals.

The situation in 2001 was unique, and the agencies were not fully prepared
to deal with environmental contamination. Therefore, we are describing and
assessing agencies' activities not to fault the agencies but to learn
lessons. In the future, if the agencies decide to use a targeted rather
than a probability sampling strategy, they must recognize that they could
lose a number of days if their targeted sampling produces negative test
results. In this case, additional samples would need to be collected and
analyzed, resulting in critical time, for public health interventions,
being lost. This was so at the Wallingford postal facility in the fall of
2001, when about 3 weeks elapsed between the time the first sampling took
place and the results of the fourth testing, which revealed positive
results. Furthermore, about 5 months elapsed between the time of the first
sampling event and the time anthrax was found in the Wallingford
facility's high-bay area.42

Therefore, in the future, strategies that include probability sampling
need to be developed in order to provide statistical confidence in
negative

42According to CDC, earlier identification of anthrax in the high-bay area
would most likely not have altered public health intervention
recommendations. The decisions about postexposure prophylaxis were based
on the available epidemiology.

results. Further, even if information on all the performance
characteristics of methods is not yet available, a probability sampling
strategy could be developed from assumptions about the efficiency of some
of the methods. And even if precise data are not available, a
conservative, approximate number could be used for developing a sampling
strategy. This would enable agencies and the public to have greater
confidence in negative test results than was associated with the sampling
strategy used in 2001.

Activity 2: Collecting Samples

The agencies used a variety of sample collection methods, alone or in
combination. USPS primarily used the dry swab method. CDC and EPA used
premoistened and dry sterile, synthetic (noncotton) swabs, wet synthetic
wipes, and HEPA vacuums for sampling. To determine whether anthrax was
airborne, CDC performed air sampling in the Brentwood facility 12 days
after the contaminated letters were processed.43 Airborne anthrax spores
pose a health risk because they can cause inhalational anthrax, the most
serious form of the disease. Agency officials stated that laboratory
requirements had influenced the choice of methods. For example, in the New
York area, CDC used only dry swabs, following a requirement by New York
public health laboratories.

The majority of the samples were collected by the dry swab method, which
experts and others we interviewed considered the least effective. As shown
in table 1, 304 sampling events involved single methods-that is, CDC and
USPS collecting dry swab samples (185) and CDC and others collecting
premoistened swabs (119). However, for some sampling events, CDC used wet
wipes, HEPA vacuum, and air samples at Brentwood and swabs, wet wipes, and
HEPA vacuum samples at Wallingford.

43CDC said that it did not do more air sampling because the air samples in
Brentwood were all negative, despite known surface contamination.
Therefore, air sampling was not seen as useful if (1) the samples were
collected days after buildings were closed, (2) the ventilation systems
were turned off, and (3) anthrax spores had settled on surfaces. CDC
stated that air sampling is more appropriate for clearance (verification
sampling) purposes. CDC also did research on air sampling at Trenton in
February 2002, which we discuss later in the report; according to USPS, a
Canadian Defense Ministry unit conducted additional air sampling under
CDC's guidance.

Table 1: Agencies' Sample Collection Methods for Initial Sampling, October 2001
                               through April 2002

     Methods at different   Sampling                Agency            
       sampling events        eventa CDC  CDC and   USPSb  FBI NJDHSS Unknown 
                                            EPA                       
          Dry swabs              185  X               X               
      Dry swabs and HEPA                                              
            vacuum                 2  X                               
          Dry wipes                1                  X               
      Premoistened swabs         119  X      X              X    X    
    Premoistened swabs and                                            
             bulk                  1                        X         
    Premoistened swabs and                                            
             wet                                                      
            wipes                  1         X                        
    Premoistened swabs and                                            
         HEPA vacuum               5  X                     X         
Wet wipes, HEPA vacuum,                                            
       and air sampling            1  X                               
      Wet wipes and HEPA                                              
            vacuum                 1  X                               
            Wipes                  1                  X               
         HEPA vacuum               2                  X               
    Swabs, wet wipes, and                                             
         HEPA vacuum               1  X                               
Other (hand-held assay)         1                  X               
      Method and agency                                               
           sampling                                                   
           unknown                 3                                     X    
            Total                324                                  

Source: CDC, EPA, and USPS.

aSampling event refers to sample collection by one agency on a specific
day, at a specific time, in a specific facility. Multiple agencies could
have collected samples on the same day; we consider these separate
sampling events.

bEarly, in some facilities, USPS also collected samples for analysis by a
portable, polymerase chain reaction (PCR)-based instrument that
contractors operated for analyzing these particular samples.

USPS officials said that the choice of dry swabs for the USPS Standard
Sampling Plan was based on advice from CDC and an APHL working group,
which had coordinated with the head of LRN. According to APHL, the working
group was made up of "members from various state public health
laboratories, APHL, and CDC, as well as other federal agencies." USPS said
that the goal was to develop a consistent approach that all states could
use and that would ensure that all laboratories analyzing the

samples would have the same capabilities.44 USPS also said that use of
this method would avoid overwhelming the laboratories' capacities.45

According to APHL officials, the working group was to select a collection
method. This group consulted with CDC's NCID in November 2001. APHL said
that an NCID official, who was a member of the group, agreed that the dry
synthetic swab method could be used but that premoistened swabs would pick
up more spores. (See fig. 2 for examples of swab methods.) NCID assisted
in developing the analytic procedures for the dry swab samples USPS
collected.

44USPS was referring to the approach that was developed for the USPS's
contractors to use under USPS's November 2001 agreement with APHL for
public health laboratories to analyze the samples collected by the
contractors. In commenting on this statement, APHL officials stated, the
goal of the LRN is to standardize test procedures and reagents nationwide,
and the USPS was mirroring that approach.

45APHL disagreed with USPS, stating that the capacity of the LRN was not a
topic of concern and that more testing of a variety of environmental
samples could have taken place if validated methods for those samples had
been available through the LRN. However, in discussing major issues that
arose during the anthrax attacks of 2001, including all testing, APHL
referred to the fact that many LRN laboratories were "overwhelmed and near
their breaking point" and "laboratories were required to test specimens
that, in most cases, did not pose a threat."

                   Figure 2: Three Sample Collection Methods

During our fieldwork, we tried to determine what specific advice CDC gave
APHL on using dry swabs. In responding to our inquiry, CDC did not
specifically deny APHL's statement that an official from CDC's NCID told
APHL that dry swabs could be used. However, an official from CDC's NIOSH,
which was not a member of the working group, said that CDC has always
recommended using premoistened swabs. Nevertheless, according to APHL,
"the NIOSH recommendation was not known by the NCID working group members,
nor did they advocate on its behalf." We noted that all versions of CDC's
guidelines included instructions for using premoistened swabs.

The choices for sampling methodology are apparent in the USPS interim
guidelines, earlier versions of which included instructions for
premoistened swabs, later versions omitting them; USPS initially developed
the guidelines following the finding of contamination in a number of its
facilities. However, the USPS Standard Sampling Plan always provided for
dry swabs, as part of the November 7, 2001, USPS agreement with APHL. This
agreement designated public health laboratories to analyze samples
collected by USPS contractors.46 In particular, this plan was used by the
contractors and formed the basis for the development of a site-specific
plan for each facility sampled.

When the contractors were sampling the facilities, the interim guidelines
were still in draft form. In commenting on a November 7, 2001, version of
the guidelines, which included instructions for using premoistened swabs,
CDC suggested, on November 9, 2001, that USPS use other methods, such as
bulk and vacuum samples. 47 CDC stated that the reason for the use of
swabs was an accommodation USPS had reached with APHL. CDC also said that
state laboratories might be less familiar with analyzing bulk and vacuum
samples. A USPS official said that there were issues related to which
laboratories could handle the other types of samples and that laboratories
tended to be conservative, preferring to accept only the types of samples
they were used to handling, such as swabs. According to APHL,

46Several versions of the USPS guidelines were developed while the
contractors sampled
the postal facilities, but they followed only the Standard Sampling Plan.
The most recent
guidelines are USPS, "Interim Guidelines for Sampling, Analysis,
Decontamination, and
Disposal of B. anthracis Spores in USPS Facilities," revision 1.0
(Washington, D.C.:
Dec. 2003).

47NIOSH comments were on USPS interim guidelines, not the Standard
Sampling Plan,
which USPS contractors used under USPS's November 7, 2001, agreement with
APHL for
analyzing samples.

the decision to recommend the use of dry swabs was based on a variety of
concerns, including

the use of an untrained and poorly equipped workforce collecting the
environmental samples; maximized isolation of viable Bacillus anthracis
through preservation of spores during transport when temperature and
exposure to light was least controlled; the ability to eliminate other
environmental bacteria and fungi that would inhibit isolation of anthrax;
and the lack of standardized validated methods for laboratory testing of
HEPA socks.

The decision to use dry rather than premoistened swabs stemmed partly from
the concern of some public health officials, including APHL officials we
interviewed, that moistened swabs would allow anthrax spores to germinate,
growing into vegetative cells instead of remaining as spores.48 Other
public health officials we interviewed said it was highly unlikely that
anthrax spores would germinate into vegetative cells in a premoistened
swab. APHL officials said that it was feared that such vegetative cells
would be destroyed during certain analytic procedures. However, none of
the agencies' collection methods were evaluated for anthrax detection in
environmental samples. The published literature provided some information
on the efficiency of a few sample collection methods. In all the methods
studied, swabs were always premoistened before samples were collected.
However, according to one study, the most efficient method caused problems
when used with certain analytic methods.49 In the absence of empirical
research, agencies had no information available for reliably choosing one
method over another and no information on the limits of detection to use
when evaluating negative results.

Activity 3: Transporting Agencies transported samples by land or air to
laboratories for extraction

Samples 	and analysis (activities 4 and 5). The USPS sample collection
plan included shipping instructions that were based on regulations for
shipping infectious substances and designed to prevent their inadvertent
release.50

48According to an NCID official, this belief about anthrax spore
germination was held for only a short time. However, APHL disagreed,
stating that the concern about spore germination is still a significant
concern today.

49Mark P. Buttner, Patricia Cruz-Perez, and Linda D. Stetzenbach,
"Enhanced Detection of Surface-Associated Bacteria in Indoor Environments
by Quantitative PCR," Applied and Environmental Microbiology 67 (June
2001): 2564-70. The study compared the performance of swab kit, sponge
swipe, cotton swab, and bulk sampling methods.

50This is not intended to imply that the environmental samples were to be
mailed through the postal system.

EPA's sample collection plan did not refer to transportation requirements.
According to CDC's guidelines, anthrax samples were to be considered
infectious substances and packaged according to applicable federal
regulations enforced by the Department of Transportation. These
regulations were aimed at "ensuring that the public and the workers in the
transportation chain are protected from exposure to any agent that might
be in the package." 51 Among other potential requirements, infectious
material must be contained in a securely sealed, pressure resistant,
watertight, primary receptacle surrounded by an absorbent and cushioning
material. This material must, in turn, be enclosed in a securely sealed,
watertight, and durable secondary packaging, which has to be enclosed in
an outer packaging constructed of fiberboard or equivalent material, as
well as shock absorbent material if more than 50 milliliters are shipped
in one package.

However, these regulations did not address one of the most important
issues-maintaining the biological integrity of samples while being
transported. Failure to do so could result in false negative test results.
For example, analysis by culture requires that spores can germinate,
divide and multiply, so that tests can determine whether a sample contains
anthrax. Temperature and exposure to certain kinds of light, such as
ultraviolet light, can be deleterious to some microorganisms. Therefore,
it is important that every sample collected retain its original physical
form before and during transportation.52

We recognize that it may not be possible to maintain the original form of
samples collected by various methods. A 2002 study recognized some of the
factors that must be considered when determining conditions for

51Department of Transportation, 49 C.F.R. subchapter C-Hazardous Materials
Regulation. The USPS regulations mirror the Department of Transportation
regulations. However, to be transported as mail, material must be
classified as mailable. By statute, infectious materials, such as anthrax
spores, that are "disease germs or scabs, [or] other natural or artificial
articles, compositions, or material which may kill or injure another"
cannot be mailed. Such materials are termed "nonmailable matter."
Knowingly mailing such material is a criminal offense, and doing so with
the intent to kill or injure is a felony. When an etiologic material is
not "outwardly or of [its] own force dangerous or injurious to life,
health, or property," USPS may allow it to be mailed, subject to
appropriate rules and regulations governing its preparation and packing.
As a result, USPS allows the mailing of small quantities of appropriately
packaged infectious material, but only if it is intended for medical or
veterinary use, research, or laboratory certification related to public
health.

52Environmental Protection Agency, General Field Sampling Guidelines
(Washington, D.C.: Aug. 11, 1994).

transporting biological samples, such as temperature, exposure to light,
and time before processing.53 CDC's guidance stated that samples,
including premoistened swabs, wet wipes, HEPA vacuum, air, and bulk (for
example, a piece of carpet), should be transported to the appropriate
laboratory at ambient temperature.54 The USPS Standard Sampling Plan
required that dry swab samples be transported at ambient temperatures.
However, both CDC and USPS said that laboratories were also consulted for
specific transportation requirements.

Before the 2001 incidents, LRN analytical protocols were designed to
address sample integrity for human clinical specimens, which differ from
environmental samples.55 According to a DOD expert, human samples may or
may not be expected to contain spores. In addition, all human samples,
including nasal swabs, contain substances that could lead to germination.
Vegetative cells require some form of stabilization. According to a public
health official, ideally all samples, whether clinical or environmental,
should be refrigerated while being transported. However, he also stated
that the temperature conditions for some environmental samples could vary.
For example, because HEPA vacuum samples are usually dry, they can be
shipped at ambient temperatures. Premoistened swabs and wet wipes should
be kept cold or shipped with ice packs to prevent fungal growth,
particularly if their transportation will be delayed. Nevertheless, he
said, both clinical and environmental samples should be analyzed within 24
hours.

According to APHL officials, transportation delays could result in swabs'
degradation from overgrowth of molds or fungus. A DOD expert we

53The study stated: "A major concern in transporting biological samples is
ensuring that the microorganisms remain viable and active with
multiplication until the testing procedures have been performed. Samples
should be protected from ultraviolet light, heating or freezing. When
transit times are less than 6 hours, the sample may be maintained at the
original ambient temperature. If 6 hours is insufficient time for transit
of samples, the general consensus is to lower the temperature to less than
10 degrees centigrade to restrict the amount of growth and deleterious
interactions between the intrinsic species present in the sample. These
samples should be processed within 24 hours of retrieval." E. Raber and
others, "Chemical and Biological Agent Incident Response and Decision
Process for Civilian and Public Sector Facilities," Risk Analysis 22 (Apr.
2002): 195-202.

54EPA's plan, which applied only to the Florida postal facilities, did not
address transportation requirements. However, CDC and EPA worked together
to sample the Florida postal facilities.

55LRN protocols state that if the transport time of moistened clinical
swab samples will be greater than 1 hour, they should be transported at 2
to 8 degrees centigrade.

interviewed said that spores would have no trouble surviving at room
temperature for much longer than 6 hours, and background growth at ambient
temperatures is negligible. Nevertheless, according to another public
health official, while laboratories were familiar with transporting
clinical specimens, they were unsure about transporting environmental
samples. Therefore, experiments under controlled situations are needed to
resolve this issue.

We did not attempt to ascertain (1) the specific transit times for
delivering all the samples to laboratories, (2) whether sample
transportation was delayed, and (3) if it was, how long it was delayed. We
also did not attempt to ascertain the environmental conditions the samples
were shipped under or when they were received at the laboratories.
Finally, we did not attempt to ascertain the degree to which spores could
have been exposed to varying environmental conditions from the time of
release to the time of sample collection, which could have affected sample
integrity. Anthrax spores are robust, compared with other pathogenic
microorganisms, but whether transportation affected their viability cannot
be known because the conditions of their transportation were not
validated. Transport conditions, once validated, would have to be
standardized to ensure reproducibility.

Activity 4: Extracting Samples

LRN protocols required that sample material be extracted with specific
extraction procedures and fluids (such as sterile saline or water) and
that the extracted fluid be subjected to specific analytic methods. For
the samples USPS collected under the APHL agreement, the extraction
methods included adding a sample processing solution to the conical tubes
containing the dry swabs before "plating." This process was adapted from
LRN protocols for extracting swabs.56 However, the private laboratory (not
part of LRN) that originally analyzed the samples for USPS did not use an
extraction fluid; it inoculated the noncotton, rayon-tipped dry swab
directly onto a culture plate.

Several factors could have affected extraction efficiency. For example,
according to public health officials and other experts, the degree to
which swabs or wipes can retain spores depends on the material they are
made

56LRN protocols for environmental swabs required placing each swab in a
3-milliliter sample processing solution (0.3 percent Tween 20(TM), a
surfactant) in phosphate-buffered saline before plating.

of. Cotton is more retentive than some artificial fibers like rayon and
may be more difficult for extraction of spores for analysis. In addition,
according to a public health official, cotton swabs are characterized by a
"lipid matrix, which gives poor results for culture." However, a CDC
official also commented that cotton is a natural material and that some
laboratories using polymerase chain reaction (PCR) believed that cotton
swabs would interfere with PCR analysis.57 CDC also found, after
collecting additional samples in Brentwood to determine the extent of
contamination, that cotton wipe material (that is, moistened sterile
cotton gauze) decreased spore recoveries.

Other factors affecting spore extraction are the physical nature of the
collection device and surface properties. For example, swabs are easier to
manipulate and immerse in extract fluid than more bulky wipes are.
Further, extraction fluids, whether water or a saline solution, with or
without detergents, differ in their efficiency for extracting spores from
a swab or wipe. The extraction fluid is also important in that it may
affect subsequent analyses, by affecting spore germination or by
interfering with analytic methods, such as PCR. CDC has acknowledged that
"the recovery efficiency of the analytical methods has not been adequately
evaluated." The possibility of interference by sponges, used as a sample
collection method, with PCR, an analytic method, was a factor in CDC's
decision to use synthetic swabs rather than sponge sampling kits.58

The reproducibility of the results when an extraction fluid is used can
also be an issue. For example, a USAMRIID official we interviewed told us
of an unpublished USAMRIID study conducted to determine the efficiency of
extracting anthrax from swabs; the study showed that even if the same
procedure was followed, the results were not always the same.59 Although
the importance of reproducibility has been recognized, definitive
scientific information regarding extraction efficiency is lacking. In its
absence, it is not clear whether sampling results were affected,
particularly with respect

57PCR is a process in which a deoxyribonucleic acid (DNA) molecule is
extracted from a sample and then analyzed with a specific procedure to
detect the genetic code of known pathogens, such as anthrax.

58Buttner, Cruz-Perez, and Stetzenbach, "Enhanced Detection of
Surface-Assisted Bacteria."

59Using synthetic swabs and a particular type of buffer could lead to 70
to 75 percent extraction. However, repeating the test with the same type
of buffer made by different companies yielded different results. The
official said that this test showed that there were too many variables.
Even when analysts followed the same procedure, the results were not
always reproducible, casting doubt on the reliability of the test results.

to samples that may have contained few spores. Without knowing the
extraction efficiency, a false negative result may potentially be seen as
a true negative.

Activity 5: Analyzing Samples

Analyzing the samples involved a variety of methods and required two
steps-preliminary and confirmatory-to generate a final result. The
laboratory analytic methods that were used for detecting anthrax in
clinical samples already existed, but they had not been used for
environmental samples. As a result, different analytic approaches were
taken at the preliminary step, involving adaptations of such protocols.
Samples deemed positive at the preliminary step were not always confirmed
as positive, as was to be expected. However, this could cause problems for
the agencies. In addition, some agencies considered preliminary analyses
by field-based instruments unreliable, while others maintained that they
were reliable but had been used inappropriately. However, once sample
extracts were subjected to the required confirmatory tests, a positive
result was indeed a positive.

In analyzing the postal samples, laboratories used a variety of methods
for preliminary and confirmatory testing (see fig. 3). Preliminary tests
included colony morphology, Gram's stain, hemolysis, and motility tests.60
Any culture isolates that could not be ruled out in the preliminary step
of testing were considered presumptively positive and referred for
confirmatory testing. Confirmatory tests included culture analyses
(traditional microbiological and biochemical analyses), gamma phage lysis
(a test that identifies the susceptibility of the organism to
anthrax-specific viruses that create a kill zone in anthrax cultures), and
direct fluorescent antibody assay, or antibody analyses employing a
two-component test that detects the cell wall and capsule, or outer
covering, produced by vegetative cells of anthrax.61

60When bacteria stained with Gram's stain retained the color of the
primary stain (crystal violet), they were considered gram-positive, a
characteristic of anthrax. Hemolysis, a procedure involving culturing,
identified whether the colonies gave no evidence of red blood cell lysis,
a characteristic of anthrax. Motility refers to whether the colonies
showed no movement in microscopic observation, another characteristic of
anthrax.

61CDC noted that performance of all the analytical tests did not always
take place in practice. For example, according to some public health
laboratory officials we interviewed, different combinations of tests were
used in some instances or only one component of the direct fluorescent
antibody was used for confirmatory testing; real-time PCR was used in
early and later stages of testing for some sampling events.

Other specialized tests, such as molecular subtyping, were also conducted
to determine what strain of anthrax was involved. The test results were
reported as positive-anthrax was found-or negative-anthrax was not found.
Traditional microbiological analyses require 18 to 24 hours before a
result can be generated, depending on the laboratory protocols and
procedures.62 In a few instances, results were also reported as number of
CFUs per gram of sample material.

Figure 3: Laboratory Analysis of Samples in Preliminary and Confirmatory
Tests

                                  Preliminary

                                  Confirmatory

Do preliminary tests (e.g., Gram's stain and motility) on suspect
organisms. If they resemble anthrax, report the sample as positive
(presumptive) and proceed to confirmatory testing. If they do not resemble
anthrax, report the sample as negative; no further tests are needed.

Do confirmatory tests (e.g., capsule, gamma phage, and direct fluorescent
antibody) on preliminary positive sample extract to confirm that it
contains anthrax. If it does, report the sample as positive (confirmed).
If it does not, report as negative.

           Source: GAO analysis of CDC, DOD, LRN, and USPS documents.

Laboratory Protocols Were Adapted for Analyzing Samples

According to CDC guidelines, LRN laboratories were to analyze samples by
appropriate LRN protocols.63 According to CDC, all LRN laboratories were
qualified to perform the preliminary tests, and most could perform
confirmatory and other specialized tests. While a lower level of LRN
laboratory could analyze swab samples for preliminary testing, all other
samples-such as bulk, wipes, air samples, or vacuum samples-were to be
analyzed at a higher level of LRN laboratory. Samples could also be
analyzed at CDC laboratories. Presumptive positives found at a lower-level

62According to USPS, presumptive positive results may be determined on the
basis of culture-appropriate growth at the first plate reading (18 to 24
hours of growth) by APHL and LRN procedures. In commenting on our draft
report, USPS also said that while LRN and APHL procedures call for first
reading at 18 to 24 hours, during 2001, USPS received calls that indicated
presumptive growth based upon 12-hour plate culture readings.

63Earlier CDC guidance, prepared in October 2001, stated that low-risk
(nonpowder) environmental samples should be processed according to LRN
level A protocols for ruleout testing in a CLIA-certified laboratory,
using biosafety level (BSL) 2 facilities and BSL 3 safety practices. The
guidance was revised in April 2002.

LRN laboratory had to be referred to an appropriately qualified laboratory
for confirmatory testing.64

The LRN analytic protocols already existed for detecting anthrax in
clinical swab samples, but they had not been used for detecting anthrax in
environmental samples. Consequently, several revisions were made to the
LRN protocols. LRN confirmatory protocols provided for processing
environmental swabs but not other types of samples, such as wet wipes or
HEPA vacuum. However, according to public health officials, once the
sample material was extracted, the same procedures used for analyzing
clinical samples would apply. According to agency and public health
laboratory officials, LRN protocols were generally used for the samples
they analyzed, with some exceptions. For example, according to a
laboratory official, not all components of a particular confirmatory test
were always performed because of time constraints. CDC also acknowledged
that, in practice, procedures sometimes differed from approved protocols.

According to data we reviewed, CDC-approved laboratories, such as public
health laboratories, and a private laboratory analyzed the samples. The
dry swab samples, which were the majority, were analyzed by public health
laboratories or the private laboratory but with different preliminary
protocols. Before its agreement with APHL in November 2001, USPS used a
private laboratory to analyze the dry swab samples; this laboratory
developed its own method of analysis, which it described as "direct
plating," after which it performed the standard preliminary tests (LRN
level A protocols).65 CDC officials told us that level A laboratories did
not have access to the specialized test reagents for gamma phage lysis and
the two direct fluorescent antibody tests.

The method involved inoculating a dry swab directly onto a culture plate,
without first extracting the sampling material and immersing it in a
solution. According to laboratory officials, once the sample material was

64Initial tests of unknown clinical and environmental samples under LRN
level A protocols included colony morphology, Gram's stain, and hemolytic
and motility tests designed to efficiently rule out Bacillus anthracis.
Suspect isolates were then subjected to confirmatory testing. LRN level B
protocols have two methods for confirmatory identification of Bacillus
anthracis. The first is a demonstration of a capsule combined with
susceptibility to lysis by gamma phage. The second is a direct fluorescent
antibody assay for cell wall polysaccharide and capsule antigens.

65The laboratory was not a member of LRN.

extracted, the sample extracts were subjected to LRN protocols for
preliminary testing. Any positives were sent to CDC for confirmatory
testing. Unlike the testing under the APHL agreement, the laboratory did
not subject the dry swabs to vortex (that is, rapid rotation of the
fluid), or "heat shock," procedures. According to an official from the
private laboratory, direct plating is a good technique when there are low
levels of spores, and, for the samples, it was more efficient to do
culture plates than PCR.

A public health official we interviewed disagreed with the private
laboratory's approach. His laboratory had a similar method, called "touch
plate," for environmental monitoring, he said, but direct plating using
dry swab samples was not the best approach for growth because of the lack
of efficiency in transferring the spore from the swab to the plate.66
According to CDC, it also used direct plating for some of the premoistened
swabs it collected from some facilities. CDC also stated that regardless
of the method, 100 percent of a contaminant would not be recovered from a
surface.67

In some instances, CDC stated, touch plates, commonly called replicate
organism detection and counting (RODAC) plates, provide better recovery.
Touch plates are commonly used for sampling smooth, hard surfaces.68 CDC's
description of a touch plate method differs from the one used by the
private laboratory. We did not find any comparative studies that assessed
the relative efficiency of the two methods.

Under the APHL agreement, a working group with input from CDC developed a
method that public health laboratories were to use in analyzing the dry
swab samples collected by USPS contractors. The method was adapted from
LRN protocols for analyzing premoistened

66This laboratory was a member of LRN. The laboratory's touch plate method
consisted of taking a contact plate with agar (nutrient medium) and
touching surface areas to detect the presence of anthrax or other
biothreat agents, followed by incubation for growth of colonies.

67In commenting on our draft, USPS said that it contended that the dry
swab method, coupled with the analytical methods used by the private
laboratory, was as effective as any methods initially used to detect the
presence of viable anthrax spores.

68One technique using RODAC plates is to press the agar surface of the
plate onto the sample surface.

environmental swabs.69 According to APHL officials, the adopted method was
not validated. Consequently, it had to be revised during the testing. For
example, the APHL officials found that the heat shock procedure was
unnecessary, and therefore it was discontinued.

In addition to traditional analytic tests, such as culture for preliminary
tests, other laboratory tests were to be used on the postal samples. For
example, for the USPS dry swab samples, some public health laboratories
performed real-time PCR. Similarly, for some samples CDC and EPA
collected, real-time PCR was performed. According to CDC, the confirmatory
tests were generally reliable, provided that multiple tests were performed
to confirm the results. However, in testimony in May 2003, a scientist
from Johns Hopkins University questioned certain aspects of the protocols
for the analytical procedures USPS and CDC used on premoistened and dry
swab samples.70

For example, the scientist stated that (1) USPS procedures did not
incorporate detergent in sample extraction to aid spore release, (2) the
volume of fluid used to extract the swab differed between CDC and USPS
(CDC required 3 milliliters, USPS 1.5 milliliters), (3) the fraction of
the total extract volume inoculated onto the culture plates differed
between CDC and USPS, and (4) the number of culture plates that were
inoculated per sample also differed (CDC 3, USPS 1). Further, according to
the scientist, both methods cultured too little of the total extract
volume for use as a rule-out test.71

69Adaptations of the laboratory protocols included (1) heat shock the
environmental sample for 30 minutes rather than 10 minutes to clean up the
sample and allow for an easier read of the microbiological plates for
growth of Bacillus anthracis spores; (2) the possible use of a sterile,
disposable serological transfer pipette to inoculate sheep's blood agar
plates, the 100 microliters being approximated; and (3) because the 100
microliter inoculum is large for the plates, the use of dry plates for the
inoculum to soak in sufficiently.

70The procedures were included in USPS, Draft Interim Guidelines for
Sampling, Analysis, Decontamination, and Disposal of Anthrax, and in CDC,
"Comprehensive Procedures for Collecting Environmental Samples."

71Robert G. Hamilton, testimony, Subcommittee on National Security,
Emerging Threats, and International Relations, Committee on Government
Reform, House of Representatives, United States Congress, Washington,
D.C., May 19, 2003.

Agencies Encountered Problems with Preliminary Analytic Methods

The problems agencies encountered in preliminary testing included issues
related to training and quality control, as well as problems with using
fieldbased analytic methods with limitations that were not well
understood. In preliminary testing, a suspect organism must first be
selected; at this point, human error or quality control issues can affect
the results. For example, we identified a problem involving culture in the
preliminary tests-that is, a reliance on the naked human eye to identify
and select the growth of anthrax on the petri dish. Many different types
of organisms could be growing that looked like, but were not, anthrax.
This is significant because when negative results were obtained during
preliminary testing, no further testing was to be done.

According to some public health officials, because environmental samples
often contain Bacillus species commonly found in the environment, any
organisms isolated by culture would have to be examined carefully to rule
out the presence of the anthrax organism. Therefore, adequate training was
essential. According to one public health official, a bacterium called B.
cereus "looks very similar to anthrax in Gram's stain." As we showed in
figure 3, Gram's stain is one of the preliminary tests used to rule out
anthrax. A DOD anthrax expert explained, "Both B. cereus and B. anthracis
are members of the genus Bacillus but are different species. Gram's stains
are useful as an initial step in determining whether an unknown
microorganism could be Bacillus anthracis. If it is gramnegative, it is
not." The problem with differentiation of various Bacillus species might
lead to false positive results. Therefore, confirmation is needed.

Other problems can also affect the reliability of laboratory results.
According to a public health official, false negatives can result from not
using positive controls in performing a specific test. For example, a
defective reagent can cause a test to malfunction and not reveal
anthrax.72 According to an expert microbiologist, this was a problem with
laboratories inexperienced in working with anthrax. Although this type of
microbiology is standard in clinical laboratories, he said, staff
experience is key. According to another expert, speaking generally,
determining who is qualified during a crisis is not easy, because standard
operating procedures may have to be adapted to the situation. Likewise,
regulatory

72Laboratories are required to have quality control and quality assurance
procedures and to use controls to ensure that such an event does not
occur. In this case, a positive control would involve analyzing a sample
known to contain a contaminant and performing the required tests, using
the reagent in question, which should produce a positive result.

and certification agencies would not have the capacity to set standards or
proficiency examinations criteria in a crisis.73

In addition, for about 10 days, in some of the postal facilities,
beginning on October 31, 2001, USPS contractors collected swab and wipe
samples for analysis by a portable, PCR-based instrument.74 According to a
USPS official, USPS collected side-by-side samples, a certain percentage
of which were to be analyzed by the portable instrument and a certain
percentage by culture. According to data we received, all the results
obtained by the portable instrument and culture analysis were negative.
However, USPS officials told us that the results from the portable
instrument were inconclusive because of problems associated with false
positive and false negative response rates. According to USPS, it
discontinued using the portable instrument, based on advice from DOD. USPS
officials said there were concerns about the limitations of the instrument
and level of user experience required, among other things.75

Preliminary analyses were also performed with field-based analytic tests
designed to produce more rapid results than laboratory testing. For
example, on October 18, 2001, USPS arranged for a local hazardous
materials response team to perform two "quick tests," using hand-held
assays (HHA) in the Brentwood facility. The results were reported as
negative the same day.76 According to a USPS official, USPS wanted to get

73According to the expert, "on-the-fly" proficiency can be evaluated by
including blind samples. These should include both negative and positive
samples for qualitative analysis. When the analysis returns a quantitative
result, the proficiency examination should include different samples
spanning the range of what the analysis personnel will encounter. Such
proficiency testing would help determine the value of the test results
generated during a crisis. Action decisions based on on-the-fly
proficiency test results could factor in potential analysis problems.

74A portable device that detects various microbes associated with
infectious diseases and biowarfare agents; such devices are used by first
responders, such as hazardous materials teams, to detect hazardous
substances.

75USPS provided the following details about the instrument: (1) the
minimum level of detection is greater than 100 CFUs; (2) inhibitors can
affect PCR methodology; and (3) although USMARIID data show reasonable
performance in a laboratory setting with greater quantities of testing
solution, a high degree of user experience is required to obtain the
lowest possible false positive (20 percent) and false negative (10
percent) rates and, in the field, the false positive rate may approach 100
percent and the false negative, 40 percent.

76HHAs are small biological test strips, similar to that used in a
pregnancy test, with colored bands to detect the presence of a live agent.
The two HHAs were collected from the ventilation air filters above mail
processing machines in Brentwood.

a rapid preliminary result while waiting for the results of dry swab
sampling that USPS contractors performed the same day, which were to be
analyzed by culture methods. The culture results were not available until
about 4 days later, when some were reported as positive.

Concerns about field-based methods created confusion about their
reliability and the circumstances under which they should be used. For
example, HHS did not recommend field-based methods, nor did the Office of
Science and Technology Policy (OSTP), because of concerns about their low
sensitivity and potential for false positive results caused by nonanthrax
bacteria, chemicals, or inadequately trained personnel. However, DOD
stated that the field-based methods were effective when employed
appropriately.

In an October 2001 advisory, CDC stated that the utility and validity of
the HHAs were not known and that it did not have enough scientific data to
recommend their use. CDC stated further that the analytic sensitivity of
these methods was limited by the technology; data that manufacturers
provided indicated that a minimum of 10,000 spores was required to obtain
a positive result. In a July 2002 memorandum to federal mail managers and
first responders, OSTP recommended against using commercially available
detection and identification technologies such as HHAs for detecting
suspect biological samples, noting that no federal agency had certified or
approved them. The memorandum also cited the limited sensitivity and
specificity of HHAs and their risk of false positives and false
negatives.77

Nevertheless, according to DOD, it had used HHAs successfully in military
situations and was continuing to develop the technology. In responding to
OSTP's memorandum, DOD stated that HHAs were effective when employed as
part of a "systematic, layered detection approach supported by additional
levels of confirmation." DOD further stated that HHAs had provided the
first indication that the letter sent to Senator Daschle contained
anthrax. According to a DOD expert we interviewed, the instruments were
reliable. The expert explained that the reference to their unreliability
stemmed from a combination of factors, including the types of assays that
were used in the instruments, interpretation of the results,

77According to OSTP, an HHA is easy to use but should not be used under
conditions such as (1) sampling porous surfaces, which contain grooves
that may contain dirt or other substances that could hinder the device's
effectiveness, or (2) sampling where there is an excessive concentration
of a suspect agent, which may cause clogging and lead to an inconclusive
result.

and how those results were used. He stated that both instruments-that is,
HHAs and PCR-based instruments-were extremely reliable when their
constraints were understood, they were used properly, and the results were
interpreted correctly. He added that the results obtained by HHAs should
never have been used to make health care recommendations- DOD had never
recommended this to the user community. Finally, according to an EPA
official we interviewed, HHAs can be useful when used appropriately by
first responders who understand their limitations.

The agencies were also faced with problems when deciding how to respond to
preliminary positive results that might eventually turn out to be
confirmed otherwise. For example, agencies did not have clear criteria for
when to close facilities. In addition, as we recently reported, although
HHAs were considered preliminary tests, concerns were raised that the
negative results might lead to a false sense of security.78 During the
2001 incidents, USPS kept the Brentwood facility open, following CDC's
advice that closing it was not warranted. According to USPS officials, the
correctness of this advice appeared to be confirmed by the HHA results
obtained on October 18, 2001. When CDC confirmed a case of inhalation
anthrax in a Brentwood employee on October 21, 2001, the facility was
closed that day. According to USPS, it was not until October 22, 2001,
that the laboratory's culture tests of the other samples, collected on
October 18, revealed positive results.

In a more recent instance, on November 6, 2003, USPS shut down 11 postal
facilities in and around Washington, D.C., after a preliminary test-not a
confirmed result-from a routine air sample taken on November 5 indicated
that a naval mail processing facility might be contaminated with
anthrax.79 USPS tracked the flow of mail through its own facilities and
closed 11 postal facilities that delivered mail to the naval facility. The
subsequent confirmatory tests were negative, and the facilities were
reopened about 3 days later.

78See GAO, U.S. Postal Service, GAO-04-239.

79According to USPS, Navy personnel performed the original sampling and
analysis, and the preliminary positive result was found at a non-USPS mail
processing facility. However, USPS also performed testing at the
designated facilities and other associated facilities; thus, the
facilities were reopened following confirmatory results obtained by both
agencies.

The Five Activities Involved Many Variables That Can Affect Results

All the activities discussed above are interdependent, and many variables
for each one can affect the results. Further, problems associated with any
one of these activities could affect the validity of the results generated
by the overall process. Given that there are so many variables, the use of
different sample collection strategies, reflected in site-specific plans,
could yield different results. For example, three potential sample
collection plans could be used in one facility-plan A, using one
collection method (for example, a swab); plan B, using two methods (for
example, a swab and wipe); and plan C, using three methods (for example,
swab, wipe, and HEPA vacuum). How these collection methods are to be
applied-that is, how they are physically used and how much area each
sample covers-is a variable.80 Within each plan, sample transportation
protocols could differ, involving variables such as temperature-plans A
and B might require transporting at ambient temperature, while plan C
might require freezing temperature-the sample collection method's
moistness during transport, and the size and construction of the
packaging.

In addition, within each plan, laboratory extraction and analysis
protocols could differ, involving variables such as (1) different
manufacturers' different formulations of extraction fluids, (2) different
ways to physically release spores from a particular collection method
(such as a swab) into the liquid extract (such as by shaking or
vortexing), and (3) a combination of analytic methods, such as culture or
PCR for DNA amplification to identify anthrax.81 Any problems experienced
with any of these variables across any of these plans could affect the
final result.

80Material variables could include premoistened or dry swabs or wipes, as
well as swabs made of cotton or synthetic fiber, wipes made of
multilayered gauze or cloth, or devices of similar description made by
different manufacturers. Variables of technique could include coverage
area per sample and mechanical details of manual collection, such as
surfacesweep pattern; manner of moistening, holding, and rotating swabs
and of folding wipes; and firmness of applied pressure related to HEPA
vacuum hose-nozzle handling or filled sample "nozzle sock" handling.

81Other variables include different treatments (typically, heat shock) to
achieve both resistant spore enrichment (relative to more susceptible
vegetative bacteria and molds) and spore activation in extracts (to
physiologically induce rapid germination), different techniques for
concentrating or splitting (or aliquoting) extracts to inoculate culture
plates, and a combination of qualitative or quantitative analytical
methods, such as culture for plate count assay or PCR for DNA replicative
amplification in preparation for strainspecific DNA sequencing analyses
for anthrax species.

The Sampling Results

Were Largely Negative

The majority of the samples collected from the postal facilities tested
negative.82 In all, federal agencies collected about 10,000 samples during
initial testing. USPS contractors collected the majority of the samples
(7,040), followed by CDC (2,313), in a total of 301 separate sampling
events. Samples were also collected by EPA, the FBI, and the New Jersey
Department of Health and Senior Services (NJDHSS), a state public health
laboratory, for a total of 23 additional sampling events (see table 2).

              Table 2: Total Samples Collected and Sampling Events

                               Agency    Samples collected    Sampling events 
                                 USPS                7,040 
                                  CDC                2,313 
                CDC and EPA (Florida)                  183 
                                  FBI                  225 
              State health department                   20 
                               Othera                   26 
                                Total                9,807 

Source: GAO analysis of CDC, EPA, and USPS data.

aThe sampling agency was not indicated in the data we received.

82After anthrax was discovered in the Florida postal facilities, CDC and
USPS began sampling the balance of the facilities. CDC began outbreak
testing, which was associated with, for example, cases of illness or links
to the facilities that processed the letters-that is, the primary
facilities. USPS began precautionary testing of facilities.

We recognize that the sampling activities of CDC, USPS, and other agencies
may have been conducted for different reasons and goals.83 Nevertheless,
it is interesting that of the 9,807 samples that the agencies collected,
more than 98 percent, or 9,648, were negative; a little more than 1
percent, or 159, were positive. In all, 286 facilities were tested for
anthrax contamination. Of these, Brentwood, Trenton, and Morgan were
primary facilities; that is, these 3 facilities processed the original
letters containing the anthrax. Although one of the Florida facilities was
suspected of having processed a contaminated letter, none was found. The
remaining facilities (283) were mostly tested as part of the FBI
investigation, USPS precautionary, or CDC outbreak testing between October
2001 and December 2001.84

Testing in the Three Primary Facilities Revealed More Positive Results
Than in the Wallingford Facility

Testing results differed between the primary facilities and Wallingford
(as shown in fig. 4). First, in the three primary facilities, results were
positive each time a facility was tested, with the important exception of
the two quick tests in Brentwood. In Wallingford, considered less likely
to be contaminated, results were positive only on the fourth sampling.
Second, in the primary facilities, sampling with a single method produced
some positive results, regardless of the sample collection method. In
Wallingford, neither dry nor premoistened swabs produced any positive
results. Third, in the primary facilities, both single and multiple
methods produced positive results; in Wallingford, only multiple methods
produced positive results.

83According to CDC, it conducted sampling as part of the outbreak
investigation. Given that these activities were usually conducted in
highly suspect contaminated buildings, response actions had to be
initiated rapidly for the good of public health and all analyses were
coordinated with level B (or higher) LRN laboratories. In contrast, most
of USPS's activities were conducted as precautionary testing. USPS
activities were conducted in selected P&DCs (those USPS facilities that
exchanged mail with Trenton, Brentwood, or Morgan); therefore, because
there existed a potential for cross-contamination, response actions were
conducted in the long term, when compared with CDC activities, and
analyses were conducted with APHL laboratories that may not have been LRN
(or, at the least, not level B).

84Two facilities were also retested in 2002.

Figure 4: Primary and Wallingford, Connecticut, Facilities: Sampling Methods and
                                    Results

Source: GAO analysis of CDC and USPS data.

Note: Numbers in parentheses are total samples collected and total
positive results for a particular sampling effort (e.g., 29/14).

aIn April 2002, USPS also sampled elevated areas of the facility, using
HEPA vacuum.

bUSPS also had a hazardous materials unit collect two HHAs samples in
Brentwood on October 18, 2001, which were negative.

cThe NJDHSS laboratory also collected 20 premoistened swabs, which were
negative, in the Trenton facility on October 18.

When comparing the positive results, obtained with dry swabs, across the
primary facilities, the proportions differed. For example, in one sampling
event in Brentwood, out of 29 samples collected using dry swabs, 14 were
positive (48 percent), whereas in Morgan, out of 56, only 7 were positive
(13 percent). In addition, for the West Palm Beach, Florida, facility,
sampled several times during one sampling event, out of 38 dry swab
samples collected, only 1 was positive (about 3 percent). While we did not
define this facility as primary, it was suspected of processing a
contaminated letter, although none was found. The use of both wet and

dry swabs produced positive results in this facility, however (see app. II
for details).

Such results cannot be used for drawing specific conclusions, because
other variables may have been involved. For example, according to CDC, the
anthrax powder in the letters that these facilities processed differed,
and the Morgan facility did not use compressed air, which may have
contributed to increased aerosolization and the spread of spores
throughout other facilities. The level of contamination in the facilities
differed. Brentwood ambient air was sufficiently contaminated so that USPS
employees acquired inhalation anthrax.

The Majority of the USPS and CDC sampled facilities that processed mail
from the primary

Facilities' Test Results facilities to determine whether any other
facilities had become

Were Negative 	contaminated. USPS tested 177 of the facilities in
precautionary testing; CDC tested 113 facilities as part of its outbreak
investigation testing.85 The majority of test results from these
facilities were negative: Of 286 facilities sampled, 23 tested positive,
including the 3 primary facilities, and 263 tested negative (see fig. 5).

85The sum of facilities sampled by USPS and CDC is greater than the total
number of facilities sampled because USPS and CDC sampled in some, but not
all, of the same facilities.

                  Figure 5: Test Results Were Largely Negative

                          Facilities testing positive

                          Facilities testing negative

The following discusses results for some of the positive facilities,
excluding the primary ones:

o  	Generally, only 1 or 2 of the total samples collected for each
facility were positive, such as several post offices that received mail
from Brentwood, including Dulles (11 samples collected, 1 positive),
Friendship Station (32, 1 positive), Pentagon Station (17, 2 positive),
and Raleigh, North Carolina (42, 1 positive). These facilities were
considered cross-contaminated.

o  	West Palm Beach and Wallingford tested positive only on retesting,
whereas initially they had tested negative. The West Palm Beach facility
tested positive on the second testing. According to CDC, the sampling
strategy used in this facility was found to have limitations and was not
used again.86 However, Wallingford did not test positive until

86Technically, West Palm Beach tested positive on the second sampling
event. According to CDC, the strategy for the first sampling event was to
clean the facility and then collect samples, which may have caused the
negative result. Additional samples were collected in this facility in
subsequent sampling events.

the fourth testing.87 These results underscore the importance of retesting
and cast doubt on the efficiency of the testing process.

Of the 263 facilities that tested negative, only 9 were sampled more than
once.88 A facility in West Trenton tested negative, even though an
employee had contracted cutaneous anthrax. The facility in West Trenton
was tested twice by the FBI and once by CDC, during which a total of 57
samples were collected, with negative results.

Obviously, final, or confirmed, results will be negative if contamination
is not present in a facility. However, a result can be negative for
several other reasons, such as (1) the sampling method was not efficient
enough, (2) samples were not collected from places where contamination was
present, (3) not enough samples were collected, (4) not enough spores were
recovered from the sample material, or (5) analysis of the sample extract
was not sensitive enough to detect anthrax spores that were present (that
is, the result was a false negative).

The sampling at the Wallingford facility is a good illustration of the
complexities of sampling. According to postal officials, they did not
expect Wallingford to be contaminated. USPS sampled it twice-on November
11, in its precautionary sampling, and on November 21, 2001, after a case
of inhalation anthrax in a postal customer was confirmed. All results were
negative. USPS contractors, using dry swabs, collected 53 samples on
November 11 and 64 samples on November 21. However, on November 25, CDC
collected 60 samples, using premoistened swabs. Still, all results were
negative.

Finally, CDC performed what it called extensive and directed sampling on
November 28, with multiple methods-swabs, wet wipes, and HEPA vacuum (see
table 3)-and this time, testing produced positive results. Of 202 samples,
4 wet wipe and 2 HEPA vacuum samples were positive. Some of the samples
from the mail sorting machines were positive, including a

87USPS retested Wallingford in April 2002, before cleaning its high-bay
areas, using a different method. On retesting, positive results were
obtained for 3 of the 64 samples collected.

88The facilities were tested more than once for various reasons. For
example, the Seymour facility in Connecticut was retested because of a
death in the community related to anthrax.

sample collected from a machine that primarily processed letter mail. The
sample was found to contain about 3 million CFUs.

But it took several sampling events to identify the anthrax spores in the
mail processing equipment. While the sample from the machine containing 3
million CFUs was collected on November 28, 2001, another machine (# 6) was
sampled 5 times, and a total of 77 samples were collected, before anthrax
was eventually found in an area that held mail for the postal customer who
had contracted inhalation anthrax. 89 This particular machine would have
sorted mail by the customer's carrier route and address. In addition, not
until April 2002 was anthrax identified in Wallingford's high-bay area.
This further highlights the importance of developing an appropriate
sampling strategy.

Table 3: Delivery Bar Code Sorting Machines Sampled, Wallingford Facility, 2001

           USPS precautionary                      CDC outbreak       
           testing                                investigation       
                                                         Dec. 2, 2001 
                                                    (characterization   Total 
Machine Nov. 11, 2001 Nov. 21,   Nov. 25, Nov. 28, 2001 sampling)a samples 
           2001                     2001                              
                                           1            8             
                                           1            8             

8

11 (1) 48 (1)

2 12

1 2 3 23 48 (1)

2 12

8

18

b

8 (4) 52 (30)

1 8 (1) 52 (3)

8

89Letters addressed to the customer could have been processed on any of
the 13 DBCSs at the facility during the preliminary sort. The final sort,
on a designated machine sorting letters to 9-digit or 11-digit Zip
Codes(TM), involved several runs through the machine. However, this final
sort of the customer's letter would have been processed on DBCS # 6
because this machine had specific bins designated for the carrier route to
the customer's address. According to CDC, samples were collected by
compositing all bins in a column. Of the 48 columns, only the column
containing the bins for the Zip Codes(TM) that included the customer's
town was found positive.

           USPS precautionary                      CDC outbreak       
           testing                                investigation       
                                                         Dec. 2, 2001 
                                                    (characterization   Total 
Machine Nov. 11, 2001 Nov. 21,   Nov. 25, Nov. 28, 2001 sampling)a samples 
           2001                     2001                              
     13                                    1            8                   9 
    Total                       1 6        8         130 (6) 200 (35) 

Source: GAO analysis of CDC data.
Note: Numbers in parentheses indicate positive results.

aThe first time anthrax spores were found in sample collected from
delivery bar code sorter # 6.

bAbout 3 million anthrax spores were found in one sample.

Interpreting the Test Results

Since the minimum infectious dose of anthrax for inhalation exposure is
not known, interpreting environmental sampling data with respect to health
risks is speculative. Added to this, the lack of performance data on
sampling efficiency means that the level of confidence that a negative
result is truly negative is not known (that is, contamination, if present,
is below a certain level when all samples are negative). Consequently,
health risk is not known. Therefore, in our May 2003 testimony, we
recommended that USPS (1) reassess the risk level, based solely on a
negative sampling result, for postal workers at those facilities deemed to
be free of spores and the general public served by those facilities and
(2) reconsider the advisability of retesting those facilities-should the
decision be made to retest any of these facilities-and use the most
effective sampling methods and procedures.

We also recommended that the results of reassessment be communicated to
the postal workers and the general public.90

When communicating testing results to, and interpreting data for, a lay
audience, it is important to include appropriate caveats. If a confirmed
positive result is obtained in facility testing, saying that a facility is
contaminated is clearly not a problem. However, it is not possible to
assess the real degree of contamination, except in a general way, because
of the lack of empirical data that would allow extrapolation of the
results from various parts of a facility to the entire facility.

Problems arise mainly because facilities are not uniform in their complex
geometry, as well as surface types-rough, smooth, porous, oily, and so

90GAO, U.S. Postal Service, GAO-03-787T, p. 24.

on. Even surfaces of identical materials may differ qualitatively,
depending on their geometrical or spatial arrangement-vertical or
horizontal, fully exposed or shielded. Although collecting large numbers
of samples can help in obtaining an accurate assessment, the problem
remains fundamental. In 2001, difficulty in understanding the true degree
of contamination was compounded by a lack of knowledge about the
efficiency of the available sampling and analytical methods.

When all samples from a facility are negative, interpretation is even more
difficult. The facility may not be truly contaminated; the negative result
may stem from the investigators having missed a contaminated area during
sampling; or the sampling and analytical methods may not be sufficiently
sensitive. Properly validating the process, including sampling and
analytical methods, can increase the level of confidence that
contamination, if present, would be detected in the areas sampled.

Nevertheless, empirical studies-involving model facilities that can be
experimentally contaminated to different degrees and then sampled-may
yield practical information about the number of samples needed to detect
contamination. This may, in turn, suggest a degree of confidence in
interpreting negative test results that could be equated with the absence
of contamination.

When investigators consider the lack of knowledge about the efficiency of
sampling and analytic methods, as well as the absence of risk-based data,
it is important to reassess risk in the light of the challenges the
agencies faced. In August 2003, USPS stated that to respond to the
recommendation in our May 2003 testimony, it had formed a working group,
including representatives from CDC, EPA, OSHA, and postal unions, to
conduct the recommended review and analysis.91 According to USPS, a
February 2002 CDC assessment had determined that such retesting was not
required.

On August 27, 2004, USPS stated that the working group had concluded, "No
further testing is warranted for postal facilities that were deemed to be
free of anthrax spores following the attacks of 2001."92 The group also

91USPS stated that in its assessment, the group would study the entire
sampling chronology and the process USPS and others had used, including
the initial sampling strategy while events unfolded and sampling
guidelines were enacted, as well as the engineering controls and work
practices that were implemented.

92USPS, USPS Response to GAO Recommendation on the Anthrax Attack of 2001
(Washington, DC.: Aug. 2004).

concluded that the anthrax risk level, for postal employees in the
facilities tested and the general public they served, was negligible and
additional testing would not increase the safety of postal premises for
employees and customers. According to USPS, factors contributing to this
conclusion were that (1) no facility was deemed free of anthrax solely on
the basis of a single sampling result; (2) illness tracking by USPS and
federal, state, and local health agencies had shown no epidemiological
evidence of inhalational or cutaneous anthrax among postal employees or
customers since November 2001; and (3) USPS continued to use engineering
controls related to anthrax and work practices that reduced the potential
for another incident in which anthrax could become airborne.

With respect to USPS conclusions about risk level, we agree that the risk
is now probably low and that other actions, such as changes to operational
procedures, have probably decreased the risk even further. But because the
least efficient method was used to sample a large proportion of the postal
facilities and since neither the methods nor the process as a whole was
validated, we concluded that a reassessment of risk was necessary. The
working group is confident that risk is negligible and it has so informed
employees and others. We understand that the rationale for not retesting
is primarily based on the fact that (1) no other postal employees or
customers has contracted inhalation anthrax disease since November 2001
and (2) operational changes have lessened the potential for remaining
spores to become airborne. According to CDC, most of the sampling done at
facilities with a higher probability of contamination included methods
other than dry swabs. Therefore, this use of less effective methods where
contamination might have been lower is counterintuitive and supports the
concern that incidents of contamination in some facilities may have been
missed.

Our recommendation was aimed at facilities deemed free of anthrax from a
single negative sampling event. The data we received from CDC, EPA, and
USPS indicated that 254 such facilities were sampled only once. A large
proportion, 164, were sampled with just dry swabs. Only 9 facilities that
tested negative were retested; the others were deemed negative from a
single negative sampling result.93 A large proportion of these facilities
were considered less likely to be contaminated. However, information

93In its August 2004 report, USPS apparently interpreted our use of
"single negative sampling result" to mean only one sample, whereas we used
the term to refer to a single sampling event.

obtained during our review suggests that the use of the least sensitive
method is problematic in such facilities.

It also appears that the number of samples collected in precautionary
sampling may not have been enough in such facilities. For example, after
the extensive sampling at Wallingford, according to CDC, it became
apparent that considerably more samples were needed and that wet wipes and
vacuums, which are used to sample larger areas than are swabs, should be
used in large facilities.94 Therefore, while no more instances of anthrax
disease related to the release of anthrax in 2001 have occurred, our focus
remains on the efficacy of the sampling approaches, with a view to
improvements in the future.

Finally, it appears that in 2001, on the basis of a single sampling event,
spores could have been present in some of the facilities that tested
negative with the least effective method. USPS reported that the risk is
now low in the facilities tested in 2001, but a sampling strategy that
addresses a range of situations that may be encountered, including
facilities with both high and low probabilities for contamination, is
needed. This strategy should include methods and sample sizes appropriate
for sampling objectives. This should increase the chances of finding
contamination in such facilities and confidence that a negative is indeed
a negative, at least with some level of statistical confidence. In our
view, the Wallingford experience-in which (1) several initial sampling
efforts did not identify anthrax in contaminated machinery in November
2001 and (2) a different sampling strategy identified less contamination
in other areas of the facility several months later-further indicates the
importance of a sampling strategy that includes validated methods and
incorporates probability sampling.

The agencies took some public health-related actions to respond to
incidents related to bioterrorism, but they were not fully prepared for
the nature of the 2001 anthrax incidents. No agency activity to detect
anthrax contamination in the postal facilities had been validated prior to
the event. Because validation for select agents is complex and
time-consuming, it was not possible to perform validation studies during
the emergency response itself. Therefore, agencies had limited information
available for

94E. H. Teshale and others, "Environmental Sampling for Spores of Bacillus
anthracis," Emerging Infectious Diseases 8 (Oct. 2002): 1083-87.

Lack of Validation Raises Questions about the Reliability of Negative
Results

reliably choosing one method over another and limits of detection for
interpreting negative results. Our discussions with agency officials and
other scientists who have worked on microbial detection in indoor
environments highlighted the significance of the lack of validation of the
agencies' methods.

In addition, the opinions of the officials from different agencies
differed with respect to which methods were appropriate for environmental
sampling. Public health officials and agency officials involved in making
decisions in response to anthrax contamination also differed in their
opinions. For example, the officials differed on whether a swab should be
moistened or dry before it is used for sample collection. Although
agencies have made some progress, significant limitations and
uncertainties continue with respect to the testing process. In particular,
serious concerns have been raised about the reliability of negative test
results.

No Activity or Process Was Validated

None of the agencies' activities to detect anthrax contamination in the
postal facilities were validated.95 Validation is a formal and
independently administered empirical process. For validation, the overall
performance characteristics of a given method must be certified as meeting
the specified requirements for intended use and as conforming with
applicable standards. Because the agencies did not use an empirical
process to validate their methods of sampling and analysis, the agencies
had limited information available for reliably choosing one method over
another and no information on the limits of detection to use when
evaluating negative results. Consequently, the methods were selected based
on factors such as available knowledge and sampling associated with fungal
spores and asbestos particles, as well as the context of an emergency
response.

As we noted above, CDC had made some preparation to respond to incidents
related to bioterrorism in 1998, leading to LRN's establishment in 1999.
CDC stated that LRN focused first on developing procedures for clinical
samples. However, since CDC was working with the FBI, environmental
testing was also a priority for LRN. According to CDC, for example,
standard laboratory manuals were developed for LRN, with written protocols
for identifying anthrax and other category A biologic agents. Procedures
for identifying anthrax were validated and, in some

95In commenting on the draft report, CDC stated that LRN confirmatory test
assays for detection of anthrax were validated. However, we were not
provided with supportive documentation of methodologies used for such
validation.

instances, developed or redeveloped from older methods.96 CDC also
standardized, produced, and distributed to participating laboratories
reagents for testing.97 According to CDC, in the fall and winter of 2000,
scientists at state public health laboratories were trained to use these
analytic methods for identifying anthrax and other biologic agents.

In October 2001, however, environmental samples far outnumbered clinical
samples, so that environmental sampling had a much larger role than CDC's
preparedness efforts had anticipated.98 In October 2001, CDC stated,

Currently, no occupational or environmental exposure standards exist for
B. anthracis

spores. In addition, there are presently no validated sampling and
analytical methods

specifically for B. anthracis in environmental samples. Data are lacking
on collection

efficiency of the sample collection media (swabs, wipes, filters, etc.)
for typical porous and

non-porous surfaces encountered in indoor environments (e.g., furniture,
carpet, letters,

clothing, ventilation system filters). The effect of varying
concentrations of B. anthracis-

containing particles and dust loading on sampling efficiency has not been
studied. Further,

the recovery efficiency of the analytical methods (efficiency of removal
of B. anthracis

spores from the sample collection media) has not been adequately evaluated
and limits of detection have not been established.99

Lacking validation, therefore, it was not known what (1) the overall
performance characteristics of the various sample collection methods that
the agencies used were and (2) the recovery efficiency and limits of
detection of the agencies' methods.

Performance characteristics include, for example, determining how many
spores must be present on a tested surface to give a positive result-the

96See B. Perkins and others, "Public Health in the Time of Bioterrorism,"
Emerging Infectious Diseases 8:10 (Oct. 2002): 1015--618. Since the
document did not specify details, what constituted validation was not
discussed.

97Capacity for specialized or more developmental diagnostic and other
tests for anthrax- for example, real time PCR; direct fluorescent
antibody, immunohistochemical, molecular subtyping; and antimicrobial
testing-were established at CDC and, in some instances, other advanced
laboratories such as USAMRIID.

98According to CDC, LRN laboratories processed more than 121,700 samples
for anthrax, the majority being environmental samples from areas of
suspected or confirmed contamination.

99CDC, "Comprehensive Procedures for Collecting Environmental Samples," p.
1.

Validation Is Independently Administered

lowest limit of detection-and whether the same process, if repeated under
similar conditions, will produce similar results. Because all the methods
the agencies used to collect samples and analyze them had inherent
limitations, these methods produced results that were accurate and
specific only within certain limits. To interpret and apply the resultant
data meaningfully, it is essential to know what these limitations were.
Otherwise, a negative result may tell us only that the amount was less
than whatever the detection limit was, rather than that there was no
contamination.

As validation is generally understood, it is independently administered by
an accredited third party, the validating authority, as (1) meeting the
specified requirements for its intended application and (2) conforming to
applicable standards.100 Formal validation can lead to regulatory
acceptance and approval listing. Third-party validation is commonly
performed on a wide range of certifiable methods, employed in such
wellregulated areas as pharmaceuticals, clinical laboratory analysis, and
environmental monitoring. However, before formal validation procedures can
be applied, the specified goals for overall performance, including peer
review of the method's operating principles, must be thoroughly developed.

This process involves well-controlled performance testing, including both
positive and negative controls, as well as calibrated standards. If a
method is to become widely accepted, its principles of operation should
pass the test of expert peer review.101 When recognized performance
standards and validation criteria do not exist, a set of validation
criteria for the method, acceptable to prospective end users for some
intended purpose, must be specified. Besides being validated, a reliable
method-as part of a wellmanaged quality assurance process-must be well
controlled during the proficiency training of its prospective
practitioners and in actual field

100Validation generally requires accredited third-party administration of
concurrent empirical trials at multiple independent laboratories.
Generally, methods are validated by a process of statistical conformity
assessment; by a series of trials with reference to a set of applicable
performance standards, including appropriate positive controls (procedures
employing calibrated physical standards); and by overall method
performance criteria.

101This generally involves the coordinated use of a method on calibrated,
unknown test samples by multiple practitioners (often independent testing
laboratories), under some accredited third party's administration, and
statistical analysis of the results to assess multiple performance
parameters and suitability for use under some specified conditions.

Nonvalidated Sampling Strategies Could Be Based on False Assumptions

practice.102 Successfully completing validation offers some assurance that
a method's final results are sufficiently robust that the method can be
relied on for reproducible results, regardless of the practitioner,
agency, contractor, or laboratory.

Without validated techniques for sampling, transporting, extracting, and
analyzing, agencies' sampling strategies could be based on false
assumptions (see fig. 6). Use of nonvalidated sampling methods means that
the collection efficiency of these methods was not known. Not validating
transportation requirements means that spore viability could have been
reduced, leading to a false interpretation of a negative test result-that
is, that an original sample contained no anthrax spores when in fact it
did, producing a false negative. Transportation conditions were largely
determined by regulations for transporting etiologic agents. There is no
reason, however, why both safety and sample integrity cannot be achieved
by appropriate packaging and shipping conditions. CDC stated that the
evidence in the literature suggests that the integrity of the samples was
never jeopardized. While we agree with this statement, it fails to
recognize that in establishing sampling and associated activities, to
demonstrate that procedures are appropriate and effective, there is a
burden of proof that can only be effectively addressed by validation.

102Controls consist of standardized materials and associated procedures
for using them effectively. They are generally of two types: Negative
controls (typically, sterile specimen blanks) are expected to result in
negative tests and are used to guard against false positives, such as
those stemming from cross-contamination. Positive controls are expected to
yield well-calibrated positive results and are used to guard against
variable inaccuracies and false negative testing results.

Figure 6: Lack of Validation Can Affect Individual Activities and the
Overall Process

Source: GAO analysis of CDC, EPA, and USPS data.

Without validated extraction methods, the basic capabilities and technical
skills that the laboratory staff performing this task need cannot be
understood. For example, if it is expected that a high percentage of
spores will be lost during extraction, the staff must be highly trained so
that the maximum number of spores can be extracted. Similarly, the staff
should be sufficiently trained to analyze the sample extract to reflect
whether the sample was originally contaminated (positive) rather than
containing no spores (false negative). Nonvalidated analytic methods
cannot be demonstrated to be uniform (or reproducible) or trusted to yield
correct results. Consequently, any negative results involving nonvalidated
activities raise questions about their reliability.

Agencies' Advice Cannot Be Definitive without Validation

The agencies' advice on issues related to sample collection and analytic
methods could not be definitive, given the lack of validation and how
information was evolving from agencies' experiences during the
investigation. According to APHL, for example, on November 5, 2001, in a
dialogue between CDC and APHL working group members, an NCID
representative stated that dry DacronTM swabs could be used to sample
environmental surfaces but that wet wipes, although not necessary, would
probably pick up more material. The working group was in the process of
selecting a collection method for USPS contractors to use while doing
precautionary sampling and developing an analytical protocol. The NCID
official had been assisting in adapting the LRN analytic protocol for the
collection method selected-the working group's final decision was to use
dry swabs.

In commenting on USPS draft guidelines-being developed when USPS
contractors were already sampling the facilities under the APHL agreement
(using the USPS Standard Sampling Plan)-CDC and EPA suggested that USPS,
for several reasons, include other methods besides premoistened and dry
swabs. On November 9, for example, CDC advised USPS that using bulk and
vacuum samples, in addition to swabs, could be useful to investigators,
but CDC acknowledged that some state public health laboratories might be
less familiar with the methods needed to analyze such samples.103 CDC
stated that it recognized that USPS's decision to use only swabs was
related to an accommodation reached with APHL's laboratories to more
effectively use state health laboratories for analysis.

In a December 4, 2001, letter to USPS. EPA stated that using methods other
than dry swabs would benefit USPS. EPA said that its experience in
sampling on Capitol Hill indicated that USPS should incorporate other
collection methods into its interim guidelines-such as wet wipes,
premoistened swabs, HEPA vacuum, bulk, and air sampling-for its
environmental sampling from initial steps through decontamination. EPA
said, "All [would] likely benefit from increased sensitivity of these
methods over the current dry swab technique used by USPS."

By this time, USPS had completed the majority of its sampling. However, in
sampling Wallingford's high-bay areas in April 2002 before annual

103CDC's NIOSH officials were commenting on USPS guidelines, Guidance for
the Sampling, Analysis, and Decontamination and Disposal of Anthrax for
Postal Facilities, interim draft 1.2 (Washington, D.C.: Nov. 7, 2001).

cleaning, USPS used not dry swabs but HEPA vacuum, to ensure that no
anthrax was present.104

The scientific community did have some knowledge about the performance of
some of the agencies' methods. For example, evaluations had been carried
out in laboratory settings with swabs, wipes, and vacuuming to detect
anthrax or similar bacteria but with varying results in sample extraction.
In addition, swabs, wipes, HEPA vacuum, and air had been used to collect
samples for hazardous substances other than anthrax. Culture, an analytic
method, was well established for detecting anthrax in clinical samples,
but it was not validated for detecting anthrax in environmental samples.
According to CDC, the analytic methods that the agencies used were
generally considered reliable when multiple tests were performed to
confirm a result.

Nevertheless, the relative efficiency and accuracy of traditional methods
were not known. CDC reported in December 2001 that little data on the
accuracy of the analytic methods for detecting spores existed. According
to a public health official, real-time PCR was the most accurate of the
methods (culture, direct fluorescent antibody, gamma phage lysis) for
analyzing samples collected by different methods (swab, wipe, HEPA vacuum,
and air). However, PCR does not provide information on the viability of
the organism.105 Knowing whether the organism is viable is important in
considering health risks and what antibiotic will be effective against
disease.

To better understand the efficiencies of some of the methods of collection
and analysis, agencies performed limited studies in some of the primary
facilities during the incidents. The studies provided additional
information about the methods' efficiency but did not validate them. One
of the studies-the December 2001 CDC side-by-side study of the performance
of

104CDC completed sampling about December 2, 2001. Its peak sampling events
were October 22 to November 3. USPS sampled between October 18 and
November 28, 2001, except for the South Jersey facility, sampled in
February 2002, and Wallingford's high-bay areas, sampled in April 2002.

105According to DOD, PCR tests were traditionally used in laboratories to
presumptively identify most biological agents, but were time-consuming,
taking approximately 6 hours to produce a result, whereas real-time PCR
(excluding sample preparation time) could take 2 hours or less. However,
according to a DOD official, sample extraction cannot be separated from
the PCR process. In the anthrax incidents, real-time PCR was used for
preliminary testing.

dry and premoistened swabs, wet wipes, and HEPA vacuum sample collection
in the heavily contaminated Brentwood facility-confirmed the views of the
experts and researchers, particularly about the relatively poor
performance of dry swabs. The study found that premoistened swabs detected
spores more than 33 percent of the time when spores were detected by wipe
and HEPA vacuum sock samples. Dry swabs failed to detect spores more than
66 percent of the time when they were detected by wipe and HEPA vacuum
samples. This study concluded that dry swabs should not be used to sample
the environment for anthrax.

However, according to the study, it was not adequate to evaluate the
sampling efficiencies of the wipe and HEPA vacuum samples. The study also
concluded that there was a need to "quantify sampling efficiency to
develop the type of limit-of-detection data normally created for other
types of sampling and analytic methods." As to analysis, two CDC studies
in 2001 found that real-time PCR and direct fluorescent antibody were
sensitive, specific methods for detecting anthrax in environmental samples
and isolates.106 Some of the agencies' studies are described in table 4.

106A. F. Hoffmaster and others, "Evaluation and Validation of a Real-Time
Polymerase Chain Reaction Assay for Rapid Identification of Bacillus
anthracis," Emerging Infectious Diseases 8 (Oct. 2002): 1178-82, and B. K.
De and others, "A Two-Component Direct Fluorescent-Antibody Assay for
Rapid Identification of Bacillus anthracis," Emerging Infectious Diseases
8 (2002): 1060-65.

Table 4: Agency Evaluations, October 2001 through February 2002

Date Agency Objective and method

Conclusion

October CDC      To learn more about the potential for a 
                                               contaminated 
2001a       mail processing machine as a continual       
               source of                                    
               aerosolized anthrax spores and whether       
               particle                                     
               concentration in the air could be estimated. 

Collected surface samples (using 10 RODAC plates and 10 premoistened
swabs) from a Brentwood mail sorting machine (after the facility closed)
to see if it was still contaminated; air samples (10 banks of slit
samplers) were placed about 5 feet above the machine.

October EPA To learn the extent of indoor secondary aerosolization 2001b
of anthrax spores under active and inactive office RODAC plates and swabs
showed anthrax growth. Two plates showed low-level contamination and 3
CFUs; they were negative by the swab method. Air sampling detected anthrax
before and after the machine was activated. Even after processing more
than 1.2 million letters following initial contamination and surface
cleaning, aerosolized particles containing anthrax can still be detected
around a contaminated machine.

Defining the risk of inhalational anthrax in primary and secondary
aerosolization of anthrax spores needs more study.

Anthrax spores released in a U.S. Senate office building were
re-aerosolized in common office activities. The potential for secondary
aerosolization of viable anthrax spores originating from contaminated
surfaces in indoor environments has implications for appropriate
respiratory protection, remediation, and reoccupancy of contaminated
office environments.

conditions.

Collected surface samples (swabs and microvacuums), air samples (Anderson
6-stage sampler and 2-stage sampler), and open agar plates.

December CDC, To compare the relative efficiency of sampling 2001c ATSDR,
methods used to collect spores from contaminated and surfaces.

USPS 	December 17-20, 2001, side-by-side performance comparisons of
surface samples collected at Brentwood with dry and premoistened swabs,
wet wipes, and HEPA vacuum.

February CDC To compare air sampling methods side by side.

2002d	and Evaluated air sampling methods (mixed cellulose,USPS
polytetrafluoroethylene, gelatin-coated, dry filters, and Swabs performed
poorly. Dry swabs were least effective, failing to detect spores more than
75% of the time that wipes and HEPA vacuums detected them from nonporous
surfaces. Dry swabs should not be used to sample the environment for
anthrax; premoistened swabs could be used in certain circumstances. Wipe
and HEPA vacuum sampling yielded similar results on nonporous surfaces.
Developing numerical criteria for surface contamination and potential
human exposure requires understanding sampling efficiency.

All methods detected spores to some degree; walking and light work may
re-aerosolize spores; failure to plate entire sample in analysis may
result in false negative; the Anderson method seemed the most sensitive
for spore collection; and the dry filter unit may have reduced the number
of spores available for collection because of high flow rate and may be
least sensitive, given the air volume passing through a sampler.

Anderson single-stage cascade impactors) for anthrax spores before and
after the operation of mail sorting equipment in the Trenton P&DC.

Source: GAO analysis of CDC, EPA, and USPS data.

aP. M. Dull and others, "Bacillus anthracis Aerosolization Associated with
a Contaminated Mail Sorting Machine," Emerging Infectious Diseases 8
(2002): 1044-47.

bC. P. Weis and others, "Secondary Aerosolization of Viable Bacillus
anthracis Spores in a Contaminated U.S. Senate Office," Journal of the
American Medical Association 288 (Dec. 11, 2002): 2853-58.

cW. T. Sanderson and others, "Surface Sampling Methods for Bacillus
anthracis Spore Contamination," Journal of Emerging Infectious Diseases 8
(2002): 1145-50.

d CDC, "Hazard Evaluation and Technical Assistance Report: NIOSH
Evaluation of Air Sampling Methodologies for Bacillus anthracis in a
United States Postal Service Processing and Distribution Center, Trenton,
New Jersey," report HETA 2002-0109-2927 (Cincinnati, Ohio: Department of
Health and Human Services, CDC, National Institute for Occupational Safety
and Health, 2004).

Lack of Validation Highlighted Experts' and Agencies' Different Opinions

The significance of the lack of validation of the agencies' various
detection activities was highlighted in our discussions with scientists
and researchers who have worked on microbial detection in indoor
environments. Their opinions differed on sampling methods and sample
material appropriate for environmental sampling and processes necessary
for validating methods. Public health and agency officials involved in
making decisions on responding to anthrax contamination also differed.

Experts at USAMRIID indicated that they knew before October 2001 that dry
swabs were ineffective at collecting spores and that the swabs should be
moistened before being used. According to a scientist at Johns Hopkins
University School of Medicine, using dry swabs in environmental testing
has not been justified since the swab-rinse assay was introduced in
1917.107 A NASA study indicated that premoistened swabs were useful in
attempting to detect biological substances on smooth, nonporous surfaces
in a spacecraft.108 As to air sampling methods, according to an expert,
highvolume air samplers would detect spores, even in minimally
contaminated facilities, whether or not the spores had settled onto
surfaces. While not discounting this opinion, another scientist stated
that in air sampling, spores might deteriorate and thus cause negative
results (through culturing), since they would not germinate or grow on a
plate because of stresses encountered during air sampling. This scientist
also noted that air sampling was an expensive approach and would require
isolation of an area. According to a DOD expert, "Endospores are highly
resistant to desiccation (for example, drying process or very low humidity
environment), which is the most likely stress they would encounter in air
sampling and then only if they were sampled onto a dry filter."

As for extraction, experts have stated that spores could not be recovered
efficiently-that is, extracted during laboratory processing-from dry swabs
and that swabs made of synthetic material were more efficient than cotton
swabs for picking up particles, including bacterial spores. As we

107Robert G. Hamilton, testimony, May 19, 2003, pp. 3 and 7.

108National Aeronautics and Space Administration, Office of Space Science,
" NASA Standard Procedures for the Microbial Examination of Space
Hardware," in NASA Procedures and Guidelines, NPG: 5340.1D, final draft
(Washington, D.C.: no date).

discussed earlier, concerned that microbial growth would affect analysis
of the sample material, agency and public health officials differed on
whether swabs should be moistened.

Although most agency officials and scientists agreed that the agencies'
methods were not validated, they held different opinions and took
different approaches with regard to the procedures that are necessary
before any detection method can be considered validated. In addition, we
found that agency officials were defining the term "validation"
differently. According to the NIOSH Manual of Analytical Methods, a
validated method is one that "meets or exceeds certain sampling and
measurement performance criteria."109 However, according to a public
health official and some agency officials, a less formal approach-such as
the established use of a method with demonstrated, consistent outcomes
over time by different users-could also establish a method's validity.

In this regard, a public health official we interviewed said that because
the results from the use of real-time PCR during the 2001 incidents agreed
with the results achieved by culture, real-time PCR was essentially
validated. CDC stated that it had validated the use of real-time PCR for
environmental samples but not direct fluorescent antibody. In addition,
agencies may differ as to what constitutes validation. For example, a 1997
report looking at the validation and regulatory acceptance of
toxicological methods found that the agencies it reviewed did not have a
definition of test validation, although, with variations, they followed
certain procedures to accomplish validation.110

109P. C. Schlecht and P. F. O'Connor, eds., "Glossary of Abbreviations,
Definitions, and Symbols," in NIOSH Manual of Analytical Methods
(NMAM(R)), 4th ed., HHS (NIOSH) publication 94-113 (Washington, D.C.: Aug.
1994), p. A-10.

110National Institute of Environmental Health Sciences, Validation and
Regulatory Acceptance of Toxicological Test Methods: A Report of the Ad
Hoc Interagency Coordinating Committee on the Validation of Alternative
Methods, NIH publication 973981 (Research Triangle Park, N.C.: Mar. 1997).

Agencies Have Taken Some Steps to Prepare for Future Incidents

To prepare for future incidents, the agencies have taken some steps,
basing them on what has been learned about some of the limitations of
their sampling strategies and associated methods. For example, they have
revised their guidelines or developed new ones to reflect some of this
knowledge and experience. However, the information in these guidelines
related to environmental testing is not based on empirical validation
studies.

After the 2001 incidents, the National Response Team, chaired by EPA,
developed a technical assistance document, which is still in draft, as a
specific resource for responding to an actual or a suspected release of
anthrax outside an agricultural environment.111 It was designed for a wide
audience to use, including first responders who discover a potential
release, government agencies responding to a release on their own property
or as part of a federal effort, and facility managers and owners who may
discover a release. The document does not prescribe specific actions for
every case. It provides scientific background and viable options for users
to consider in facing specific circumstances.112

The draft Technical Assistance for Anthrax Response discusses sample plan
development, objectives, approaches, and methods. It also reflects several
statements in CDC's guidance. For example, it states that there are
currently no validated methods of sampling and analysis specifically for
anthrax in environmental samples. In addition, with respect to field-based
methods-that is, HHAs and PCR-based instruments-it states that until
further validation testing is completed and guidelines have been developed
for these methods, they should not be used alone and that any results
should be confirmed with samples analyzed by laboratory culture
methods.113 The draft does not list dry swabs as a collection method.
However, unlike its references on the appropriate use of field-based
methods, it excludes references to the dry swab method's limitations and
whether it should be used for sampling.

111National Response Team, Technical Assistance for Anthrax Response,
Interim-Final Draft Phase I Update (Washington, D.C.: November 2003),
sect. 1.1. The Interim-Final Draft was issued in September 2002.
http://www.nrt.org/Production/NRT/NRTWeb.nsf/AllAttachmentsByTitle/A-47AnthraxTAD/
$File/Anthrax.pdf?OpenElement (Jan. 9, 2005).

112The General Services Administration and OSHA, among others, also
developed guidance on anthrax.

113Section 1.1 of Technical Assistance for Anthrax Response states that
new information related to detection and decontamination will be added as
soon as it is available.

With respect to sampling strategies, the draft suggests that targeted
sampling may be appropriate to determine whether anthrax is present when
the source of the contamination is known and quickly isolated. However,
the draft also states that if the source of the contamination is not known
or quickly isolated, the sampling approach should include statistically
based sampling. This draft document seems to recognize the risks
associated with the use of targeted sampling when certainty does not exist
with respect to the presence or location of the anthrax. Another risk
associated with the use of a targeted approach, identified during our
review, relates to the level of contamination present in the facility.
Since at the outset one may not know for sure the level of contamination,
and if the level of contamination is below some detection limit, negative
results from targeted sampling may give a false sense of security.
However, through using probability sampling, negative results can be
interpreted to provide an evaluation, at a certain level of confidence, of
the maximum level of contamination that may be present. This is the key
advantage of probability versus targeted sampling.

With respect to sampling and analysis, USPS's December 2003 revision of
its "Interim Guidelines for Sampling, Analysis, Decontamination, and
Disposal of B. anthracis Spores" generally reflected related sections in
Technical Assistance for Anthrax Response. For example, for sampling
objectives, sampling approach, and analytic methods, USPS refers to the
relevant chapters in Technical Assistance for Anthrax Response, stating
that USPS "may use any of the sampling methods prescribed in the TAD
[Technical Assistance Document] depending on the nature of the sampling
and site-specific conditions."114 According to USPS officials, USPS is in
the process of updating its guidance and intends to replace the December
2003 guidelines for anthrax with a more comprehensive "all hazards"
emergency response plan for addressing future natural and artificially
created emergencies.

USPS has also begun implementing a biodetection system, having deployed
303 units at 44 sites, as of October 2004. The system collects and does a
preliminary analysis of samples from the environment, triggering an alarm
if anthrax is detected. The technology will detect only anthrax and not
other threat agents. Guidelines for implementing the new detection system
call for taking immediate emergency action, including evacuation,

114USPS, "Interim Guidelines for Sampling, Analysis, Decontamination, and
Disposal of B. anthracis Spores in USPS Facilities," p. 20.

as soon as it is activated. Facilities are to reopen only if a follow-up
analysis of a sample is negative for anthrax-a process that can take
several days.115 According to USPS, OSTP has evaluated the technology.
However, we have not reviewed OSTP's evaluation because it was beyond the
scope of this report.

CDC testified in May 2003 that it was planning to update its November 9,
2001, Interim Anthrax Response Plans and Guidelines.116 An April 2, 2002,
CDC document, "Comprehensive Procedures for Collecting Environmental
Samples for Culturing Bacillus anthracis," stated that preliminary
analytic methods should not be used alone and that any results should be
confirmed, with samples analyzed by laboratory culture methods. In May
2004, CDC officials said that CDC had learned a great deal in fall 2001
about the potential for aerosolization but that its knowledge and approach
were not yet fully reflected in its guidance. According to these
officials, CDC had expected to publish updated guidance on its approach by
the end of 2004, with recommendations for responding to positive
environmental samples in postal facilities.

CDC has made public some of its views and conclusions about the testing
methods and approaches in the postal facilities. For example, it testified
in May 2003 that none of the premoistened or dry swab samples collected in
Wallingford were positive. As a result, CDC recommended that wet wipe and
HEPA vacuum sampling be used in collecting environmental samples for
investigating large facilities. Further, CDC stated that its investigation
in Wallingford showed that extensive sampling was required and that
epidemiologic investigation was essential in identifying sites for
sampling.117

USPS said that by the time it sampled the high-bay areas of Wallingford,
it had applied what had been learned about the collection methods. This

115Follow-up analysis involves culturing the sample that triggered the
alarm. Spores 	collected on a filter in the detection system are cultured
so that the resulting bacteria can 	be positively identified. 	

116Kenneth F. Martinez, "CDC and ATSDR Activities at the Southern
Connecticut Processing 	and Distribution Center in Wallingford, CT,"
statement before the Subcommittee on 	National Security, Emerging Threats,
and International Relations, Committee on 	Government Reform, House of
Representatives, U.S. Congress, Washington, D.C.,	May 19, 2003. 	

117W.T. Sanderson and others, "Surface Sampling Methods for Bacillus
anthracic Spore 	Contamination," Journal of Emerging Infectious Diseases 8
(2002): 1145-50.	

time, USPS used not dry swabs but HEPA vacuums. CDC is also participating
with other agencies, including EPA and DHS, in related research on various
methods, which we discuss later in this report.

In contrast to the situation in 2001, DHS now has a significant role in
responding to acts of terrorism by coordinating the homeland security
functions of many federal agencies, including research. 118 It is not
clear, however, which agency will be specifically responsible for
validation studies. DHS has authority to support research in bioterrorism
and is undertaking or sponsoring some studies, including studies on HHAs,
as are other agencies.119 DHS states that it regularly attends interagency
meetings with representatives from ATSDR, CDC, EPA, and the Defense
Advanced Research Projects Agency. It says that it plans to sponsor
workshops with DOD on biothreat agents and the appropriate method for
sampling in a given scenario. Category A biothreat agents and resultant
diseases include Variola major (smallpox), Clostridium botulinum
(botulism), Yersinia pestis (plague), and Francisella tularensis
(tularemia), as well as anthrax. To the officials' knowledge, agencies
without DHS support are not required to inform DHS of such projects.

DHS is planning several projects related to anthrax sampling. For example,
it is involved in a domestic demonstration and application, a
collaborative project with EPA and CDC's NIOSH. The goals are to identify
"how clean is clean"; improve sample collection efficiencies; identify
rapid viability determination, statistical sampling methods, and a
sampling database; and develop a rapid viability determination method for
spore strips. DHS has also established a working group to develop
standards for surface and air sampling. In January 2005, DHS and DOD's
Technical Support Working Group (TSWG) convened the First Annual National
Conference on Environmental Sampling for Bio-Threat Agents, a forum for
government, industry, academia, and first responders to address critical
issues in environmental sampling.

118In 2001, no federal response plans were triggered, DHS did not exist,
and no agency was designated the overall lead.

119DHS said that it is also developing a Knowledge Management Center at
the National Biodefense Analysis and Countermeasures Center. The center is
to collect and reference all data, such as sampling methodology, that the
federal community can use for response decisions. According to DHS, having
a single repository for information would allow a more timely analysis of
current methodology and capability during an event.

According to a DHS official, Homeland Security Presidential Directive 5
(HSPD-5) identifies DHS as being in charge of managing a federal
response.120 HSPD-5 states that

the Secretary of Homeland Security is the principal federal official for
domestic incident management. Pursuant to the Homeland Security Act of
2002, the Secretary is responsible for coordinating federal operations
within the United States to prepare for, respond to, and recover from
terrorist attacks, major disasters, and other emergencies.

According to the official, DHS would coordinate all involved agencies so
there is one response objective. However, DHS would not override the
existing authority of involved agencies. During the 2001 anthrax
incidents, USPS officials told us that although they received input on
sampling or public health matters from various other agencies, including
DOD, they deferred to the agency of jurisdiction, which they considered
CDC to be. During that period, there was some confusion over which methods
should be used, primarily because of the lack of validated methods and
difficulty arranging for laboratory analysis of all types of samples, as
well as large numbers of samples.

In addition, each of the different agencies had a different focus. For
example, according to CDC,

The lines of authority for managing this line of crisis were very
confusing, and there was a

lack of assigned responsibility government-wide for taking the lead role
in coordinating a

response to these attacks, a situation which has been rectified with the
creation of the DHS.121

It is still not clear which agency would have the lead responsibility for
conducting validation studies and whether DHS would fund them.

120HSPD-5 also states, "To prevent, prepare for, respond to, and recover
from terrorist attacks, major disasters, and other emergencies, the United
States Government shall establish a single, comprehensive approach to
domestic incident management. The objective of the United States
Government is to ensure that all levels of government across the Nation
have the capability to work efficiently and effectively together, using a
national approach to domestic incident management. In these efforts, with
regard to domestic incidents, the United States Government treats crisis
management and consequence management as a single, integrated function,
rather than as two separate functions." George W. Bush, Homeland Security
Presidential Directive 5/HSPD-5, the White House (Washington, D.C.:
February 28, 2003), sect. 3.

121See GAO, U.S. Postal Service, GAO-04-239.

According to APHL surveys since 2001, intended to provide information on
the status of laboratory capability and capacity, there have been some
improvements in this area, following supplemental funding received in
2003. 122 For example, when surveyed in 2002, respondents in 13 states
reported having only one staff member trained to perform confirmatory
testing for one or more category A biothreat agents, including anthrax.
Most reported needing physical facility upgrades, including biosafety
capabilities, and seven did not have real-time PCR capability. The 2003
follow-up survey showed some improvement; for example, all respondents had
at least one staff member trained to perform confirmatory tests for
anthrax and only one had no real-time PCR capability. However, respondents
continued to report the need for facility upgrades, including biosafety
capability, and some had only one real-time PCR instrument and, thus, no
surge capacity. Concern about staffing continued: The "issue most
frequently cited was recruiting new staff." APHL has stated that it
intends to continue to conduct such surveys annually.

While the actions by agencies and others will help increase knowledge,
make available some general guidelines, and provide a forum for
discussion-all important aspects in emergency preparedness-it is not clear
how (1) a well-planned and coordinated effort-that will ensure the
problems and limitations we and others identified will be addressed-is to
be achieved or (2) the limitations in laboratory capacity will be
addressed.123 For example, it is not clear how the entire process for
anthrax detection will be validated. It is also not clear how an
appropriate approach-that will increase confidence that anthrax will be
detected in facilities with both high and low probabilities for
contamination-is to be developed, managed, and funded. Finally, agency
officials also did not

122According to APHL, in May 2002, it surveyed 53 state and territorial
public health laboratories (receiving 48 responses) to establish a
baseline status of laboratory capability and capacity, as of December 31,
2001, which was before the allocation of federal emergency supplemental
funds for terrorism preparedness, released in June 2002. This allocation
provided $146 million for state and local public health laboratory
improvements. APHL conducted a follow-up survey in February 2003 of active
members in 50 states, the District of Columbia, and three territories (51
responded).

123In commenting on our draft report, EPA stated, "Increasing lab capacity
takes considerable time and involves locating appropriate and available
lab space, hiring or locating qualified microbiologists, obtaining
security clearances (6 months to one year), rebuilding laboratory space
for Safety Level 3, immunizing staff to work with anthrax, arranging for
safe sample transport, and obtaining standards and reagents from CDC's
limited repository. Increasing lab capacity is a long term goal, with
extensive efforts underway to do so."

Ongoing Studies May Help Validate Individual Activities but Are Not Aimed
at the Process as a Whole

disagree that the individual activities and the process need to be
validated for other biothreat agents, although officials expressed
concerns about the resources needed for such an undertaking.

Since the fall of 2001, limited comparative studies have been performed or
are under way. However, these studies are limited in addressing only some
aspects of an individual activity rather than the overall process. CDC has
performed some studies of surface sampling methods and analytic methods.
For example, with the FBI, it conducted a study of selected HHAs and
concluded that the 2002 devices were not reliable.124 CDC stated that it
has further studies under way, in conjunction with DOD and EPA, to
determine the collection efficiency and limits of detection for surface
and air sampling methods. In addition, CDC stated that studies involving
researchers from CDC, EPA's National Homeland Security Research Center,
and DOD were to begin to validate sampling methods. According to EPA, its
Homeland Security Research Center is participating in a research project
with CDC and others; a project with a national research laboratory; and
the planning of a third project with the Department of the Navy to
standardize and validate sampling and analytical techniques for surface
sampling methods for anthrax. We describe the findings of some recent and
ongoing studies below:

o 
A study of some of the collection methods concluded that macrofoam swabs,
when processed using certain methods, were superior to other swabs
studied, such as those made of cotton, polyester, or rayon.

125

o 
A study of some of the analytical procedures for ruling out anthrax in the
preliminary phase found that (1) using a particular nutrient growth
medium, rather than the one used during the response, was more efficient
and (2) occasional false positive results had been obtained

124FBI and CDC, "Preliminary Findings on the Evaluation of Hand-Held
Immunoassays for 	Bacillus anthracis and Yersinia pestis," Forensic
Science Communications 5:1 	(Jan. 2003). 	

125The study included minimal agitation, sonification, and vortexing
processing methods 	and premoistened and dry swab preparations to evaluate
four swab materials-cotton, 	macrofoam, polyester, and rayon-used to
sample stainless steel surfaces inoculated with 	a known concentration of
anthrax spores. Results showed that (1) premoistened swabs	were more
efficient at recovering spores than dry swabs, (2) premoistened macrofoam
and 	cotton swabs that were vortexed during processing recovered the
greatest proportions of	spores, and (3) premoistened and vortexed
polyester and rayon swabs were less efficient. 	See L. Rose and others,
"Swab Materials and Bacillus anthracis Spore Recovery from 	Nonporous
Surfaces," Emerging Infectious Diseases 10:6 (June 2004): 1023-29.	

with PCR protocols previously evaluated with reference strains of anthrax
rather than field isolates.126 It is important to note that the
investigators did not have access to the LRN's PCR and were not using the
tests used by U.S. laboratories. CDC has stated that these findings are
irrelevant to the U.S. ability to accurately identify environmental and
clinical Bacillus anthracis isolates.

o 
A study on detection systems and diagnostic support systems for
bioterrorism response, including HHAs and PCR-based instruments,
concluded, "Many of the evaluations performed to date are critically
deficient."127 The study stated that if testing is performed at a
relatively

high pretest probability (as in a heavily contaminated building), a
negative test result will be convincing only if the sensitivity of the
system is very high. This brings to mind the situation at Brentwood, where
the two preliminary HHAs, or "quick tests," were negative in a facility
that was considered likely to be contaminated, based on the fact that it
had processed the contaminated letters. However, the study also stated
that some of the systems reviewed were the subject of ongoing evaluations
that would provide additional information and help users interpret the
results provided by such systems.

o 
Several studies, funded by TSWG, focused on the sensitivity and
specificity of sample collection methods for detecting anthrax and other
biological substances.128

o 
A March 2004 study TSWG funded showed that no one method or procedure
could by itself be relied on, because of the many variables involved.
Variations in humidity, temperature, air pressure and movement, uniformity
(or more likely nonuniformity) of particle

126See J. Papaparaskevas and others, "Ruling Out Bacillus anthracis,"
Emerging Infectious Diseases 10:4 (Apr. 2004): 732-35. The study included
72 environmental nonbacillus anthracis bacilli to study methods for ruling
out anthrax. The study concluded that the most effective methods were (1)
the use of horse blood agar, (2) motility testing after isolates had a
2-hour incubation in trypticase soy broth, and (3) screening isolates with
a Bacillus anthracis-selective agar.

127See D. M. Bravata and others, "Evaluating Detection and Diagnostic
Decision Support Systems for Bioterrorism Response," Emerging Infectious
Diseases 10:1 (Jan. 2004): 100-

08.

128TSWG operates and is overseen by a number of agencies, including DOD
and the Department of State. A national forum that includes several
multiagency subgroups, it identifies, prioritizes, and coordinates
interagency and international research and development requirements for
combating terrorism.

distribution, and sampling technique (not just the type of sampler but the
actual sampling technique and movements) can affect results.129 In
addition, the study showed that sampling efficiencies varied widely (from
1 percent to 85 percent), depending on the surface sampled (glass,
concrete, nylon, and computer screens) and the sampling method (cotton
swab, sponge swipe kit). For one study task, a comparison of the analytic
methods used showed that quantitative PCR was more sensitive than culture
when detecting the microorganism used in the study (that is, Bacillus
globigii spores).130 In addition, through air sampling, it became evident
that the spores had become reaerosolized while surface samples were
collected.

o 
With TSWG funding, the Pacific Northwest National Laboratory is studying
how to enhance the capabilities of the Visual Sample Plan, a software
package. The software enables an agency to quickly create a site-specific
sampling plan that allows it to define, with high confidence, the
magnitude and extent of contamination; guide decontamination efforts; and
verify the effectiveness of decontamination.

The completed and ongoing studies, as well as the evaluations performed in
the facilities, have contributed to, and are likely to continue to
contribute to, knowledge about how to sample for anthrax. However,
questions still remain about the performance characteristics of the
methods. Since the overall process has not been validated, several
unresolved issues remain:

o 
It is still not possible to know (1) with what level of confidence each
sample collection method will reveal the true extent of contamination and
(2) how efficient the methods are, compared with one another when sampling
different types of surfaces, such as those that are (a) porous or
nonporous, (b) simple or complex, or (c) made of different materials, such
as plastic, glass, or carpet.

129Mark P. Buttner, Patricia Cruz-Perez, and Linda D. Stetzenbach,
Development of Biocontaminant Detection/Identification Strategies for CBrN
Countermeasures, draft final technical report (Las Vegas, Nev.: Harry Reid
Center for Environmental Studies, University of Nevada, March 1, 2004).

130Quantitative PCR is a fast, accurate, and reliable way to measure the
distribution and expression of target DNA or RNA.

o 
It is not known how each sample collection method compares when processed
by each analytic method (culture, direct fluorescent antibody, or PCR).
For example, will a HEPA vacuum sample extract analyzed by culture produce
the same result if analyzed by PCR, and how do these results compare with
results of similar analysis of, for example, a wet wipe.

o 
Quantitative results based on standardized sample collection and analytic
methods do not yet give information that relates to health risk to
individuals.

o 
It is not clear (1) how effective emerging technologies will be (such as
those that provide rapid preliminary results in the field), without
improved sensitivity, specificity, and reproducibility, and (2) under what
conditions these technologies can be used in sampling postal facilities or
other indoor environments.

In addition, the five activities are interdependent, and the problems of
one activity can affect the results of a subsequent activity. Therefore,
according to an academic expert we consulted, validation and performance
evaluation of the end result must span all five activities. It is
possible, and even likely in some cases, that different individuals,
agencies, and organizations will perform the activities individually, at
different locations. Standard operating procedures for each activity must
be validated, but an additional validation method that embraces all the
activities-the overall process-is also needed. Further, the analysis
process could be tested in real time in crisis situations to determine
whether overall processing has been effective and accurate. Such testing
could be accomplished by using negative and positive control samples that
pass through all five activities.131

With respect to interpreting sampling results, according to this expert,
it is important to know the limits of detection and the error rate. In
addition, when the error rate is low, ironically, validation exercises to
estimate the

131According to the expert, negative controls might include swabs that are
not used for sample collection but that are passed along with the real
sampling swabs. Crosscontamination from the samples or other controls
would be apparent if the mock swabs generated a positive result. Likewise,
to ensure that sampling and subsequent processing can detect a real
result, positive swabs could be placed in the sample stream at the
collection site. Passage through the five activities should generate a
positive result at the end. The lack of a positive result would indicate
that the sampling scheme and processing could not detect a positive result
reliably, even if there was one.

rate become even larger. For example, at a 1 percent error rate, he said,
one would have to process 100 control samples to detect a single erroneous
result. To estimate a 0.1 percent error rate, the exercise becomes tenfold
larger. In such cases, the actual error rate might not be determined, but
an upper limit can be estimated. For example, the rate might be estimated
at no greater than 1 percent. Understanding the error rate for the
individual activities and the overall process becomes invaluable for
interpreting sampling results.

Without a validated process, the issues and problems we have highlighted
will remain unresolved. Therefore, in detecting anthrax, there can be
limited confidence about the reliability of any of the surface collection
methods or the whole process. As a result, negative results cannot be
viewed with a great degree of confidence, in particular because the
minimum human infectious dose for anthrax is still not known. Therefore,
methods that are sensitive, specific, reproducible, robust, and with a
greater chance of identifying low levels of anthrax are needed. Commenting
on the overall anthrax investigation in the United States, CDC stated in
October 2002 that the investigation had several limitations:

Environmental sampling of potentially contaminated facilities used
different testing methods; because less sensitive testing methods were
used, certain sites may have

                                      132

underrepresented the degree of contamination.

Test Reliability Remains Uncertain Despite Agencies' Progress

In summary, CDC and other agencies have taken a number of actions since
2001 to address testing issues, including research on the comparative
efficiency of certain collection and analytic methods. DHS was not
established until 2003, and the Office of Homeland Security played only a
limited role during the 2001 incidents. Since then, however, DHS has taken
steps to manage subsequent events involving anthrax. Despite these
efforts, the significant limitations and uncertainties with respect to
various aspects of the testing process raise serious concerns about the
reliability of test results. They include federal agencies' lack of
assurance that anthrax will be detected in facilities that are not heavily
contaminated or that are considered to have a low probability of
contamination.

132Daniel B. Jernigan and others, "Investigation of Bioterrorism-Related
Anthrax, United States, 2001: Epidemiologic Findings," Emerging Infectious
Diseases 8 (Oct. 2002): 1019-

28.

DHS has met with other federal agencies doing studies on testing methods,
and it is doing its own studies, but no comprehensive overall plan exists
to identify needed research, priorities, agency responsibilities, or time
schedules. DHS could work with relevant agencies to see that a systematic
validation plan is developed. It could also make a proactive effort to
ensure that testing methods are validated; necessary research is carried
out; and agency guidance, policies, and procedures reflect lessons learned
as a result of the incidents that have occurred and research that has been
performed since 2001.

Key questions we believe need answers include the following:

o 
What sampling strategies can provide a known level of confidence that
anthrax will be detected in facilities, especially those that are not
heavily contaminated?

o 
How efficient are the various testing methods, and what minimum amounts of
anthrax spores have to be present if anthrax is to be detected by these
methods?

o  Do transportation conditions affect the integrity of samples?

o 
How effective are the various methods for extracting material from samples
for analysis?

o 
Do laboratories have the capability and capacity to analyze different
types of samples?

o  How should validation be defined?

o 
What changes to agency policies, procedures, and guidance should be made
to reflect lessons learned and the results of the validation process?

Conclusions
Federal agencies responsible for responding to the 2001 anthrax incidents
have not been fully prepared. They adopted a targeted sampling strategy
that they based on their best judgment at the time. We agree that the
situation in 2001 was unique and that the agencies faced many challenges.
Therefore, we are not faulting agencies for their actions in 2001.
However, an approach for the future that incorporates probability sampling
is needed. Without probability sampling, samples will not be
representative of the total environment. Therefore, testing will not be
able to provide

reasonable assurance, with any defined level of confidence, to workers,
customers, and the public that negative test results mean that a tested
facility is free of contamination, within the limits of detection for the
methods of sample collection and analysis.

Site-specific sampling strategies in 2001 were essentially targeted to
detect anthrax in locations believed to have the highest likelihood of
contamination. While this was effective in facilities with a high level of
contamination, or where information could be obtained on the likely
contamination pathways, such as those facilities that processed the
contaminated letters, it may not have been as effective in facilities
found to have low or localized levels of contamination and when such
information was not available.

When the level of contamination is extremely high and dispersed in a
facility, the method of sampling (for example, wipes versus swabs) may not
be as critical, if the purpose is to find some contaminant. However, at
lower levels, a way of interpreting negative results is needed, and this
requirement emphasizes the importance of validation of methods and
statistically based sampling strategies.

Therefore, it is necessary to invest in empirical studies so as to develop
a probability-based sampling strategy that will account for the complex
geometry and surface types of many facilities. Using a probability-based
sampling strategy, together with validated methods for detecting
contamination, would provide a known level of confidence with which to
interpret any negative results and would thus enable agencies to be more
definitive in determining necessary actions.

The lack of validated methods for assessing contamination in postal
facilities impeded the agencies in responding to the incidents. The
significance of the lack of validated methods was exemplified in the case
of the Brentwood facility, where negative preliminary results were
obtained by field-based methods of analysis, with limitations that appear
to have been not well understood by some agencies. In commenting on our
draft report, CDC stated that "it is important to note that CDC issued a
Health Advisory on October 18, 2001, the very same day that these samples
were collected, which explicitly addressed the severe limitations in

handheld immuno assays for detection of anthrax spores."133 In contrast,
USPS comments on our draft report stated:

The Brentwood facility was kept open based on the advice of the CDC and
not as a result of the two quick field assay tests. Additional swab-based
sampling had been completed on October 18, 2001, but results were not
available until October 22, 2001, the day after closure of the Brentwood
facility (October 21, 2001) due to diagnosis of a confirmed case of
inhalation anthrax disease in a worker. The swab-based sample results
showed that the facility was indeed contaminated. Thus, either the
confirmed anthrax disease case or the positive analytical results for the
presence of viable anthrax spores would have resulted in facility closure.

Whatever the reasons, the facility remained in operation with the
potential of continuing exposure of workers. CDC confirmed a case of
inhalation anthrax in a worker, and the facility was immediately closed on
October 21, 2001. Similarly, the Wallingford experience shows that had a
mail recipient not had a case of inhalation anthrax, the facility might
have been regarded as clean, given the initial negative testing results.

The Brentwood and Wallingford examples demonstrate the need to ensure that
all the methods that are used are validated, so that their performance
characteristics, including their limitations, are clearly known and their
results can be correctly interpreted. "Validation," interpreted in
different ways, should be clearly defined in one way that is agreed on
among the relevant agencies. Validation should be defined so that, at the
very least, it provides information about a method's performance
characteristics and covers specificity, reproducibility, and limits of
detection.

The need that all methods, from sampling to final analysis, be validated,
so that their performance characteristics can be clearly understood, is
not in doubt. But any combination of methods that makes up the overall
process should also be validated because the effect of different
permutations of methods may not be predictable. However, the number of
ways methods may be combined is large, and which particular set of methods
may be used in particular circumstances is not known. Therefore, it may
not be possible to always validate the entire process, especially if
agencies are to

133http://www.bt.cdc.gov/agent/anthrax/environment/handheldassays.asp.
This advisory, which was distributed via Health Alert Network, provided
agencies, including USPS, with clear warnings that (1) these methods were
not sufficiently sensitive; (2) a negative result does not rule out a
level of contamination below 10,000 spores; and (3) the utility and
validity of these assays was unknown.

have flexibility in dealing with particular circumstances. It must be
recognized, however, that an inability to validate the entire process
reduces, to some degree, the level of confidence in the results. To assess
the impact of relying on the validation of individual activities,
experiments could be performed with a limited number of processes,
combining different methods.

We collected data only on initial sampling done in connection with the
2001 anthrax incident, but the issues we have raised clearly apply to all
aspects of sample collection, from initial sampling to verification
sampling. The issues we have raised in this report, however, also apply to
any anthrax incident, including the March 2005 incident involving DOD
facilities in the Washington, D.C., area.

In addition, while the 2001 events involved anthrax, many other biothreat
agents exist. Differences in their characteristics mean different
solutions. Accordingly, efforts to develop sampling strategies and to
validate methods should address requirements specific to those threat
agents as well. However, since addressing other agents would consume
resources and time, all these efforts should be prioritized in a long-term
strategy.

The several agencies that dealt with the anthrax attacks generally worked
well together, but we have identified areas that would have benefited from
one agency's taking the lead in coordinating the response. Given the
mission of DHS and its responsibilities, it appears that DHS is now well
positioned to take a lead role in promoting and coordinating the
activities of the various agencies that have technical expertise related
to environmental testing. In addition, it is important that all
participating agencies recognize and support DHS in that role and that
they have an effective structure for participating in identifying and
addressing the appropriate issues.

Recommendations for Executive Action

Given the lack of validated methods for detecting anthrax contamination in
facilities, we recommend that the Secretary of Homeland Security develop a
coordinated approach to (1) improve the overall process for detecting
anthrax and (2) increase confidence in negative test results generated by
that process. This approach would include working with agencies to ensure
that appropriate validation studies of the overall process of sampling
activities, including the methods, are conducted. Specifically, the
Secretary should

Agency Comments 	and Our Evaluation	

1.
take a lead role in promoting and coordinating the activities of the
various agencies that have the technical expertise related to
environmental testing;

2. ensure that a definition of validation is developed and agreed on;

3.
guarantee that the overall process of sampling activities, including
methods, is validated so that performance characteristics, including
limitations, are clearly understood and results can be correctly
interpreted;

4.
see that appropriate investments are made in empirical studies to develop
probability-based sampling strategies that take into account the
complexities of indoor environments;

5.
ensure that appropriate, prioritized investments are made for all
biothreat agents; and

6.
ensure that agency policies, procedures, and guidelines reflect the
results of such efforts.

We obtained written comments on a draft of this report from CDC, DHS, and
USPS. We also obtained written comments from APHL on excerpts from the
draft that pertained to its role in anthrax testing. Although we requested
comments from DOD and EPA, DOD said it had no comments and EPA provided
only technical comments. The written comments we received from CDC, DHS,
and USPS, as well as APHL, are reprinted in appendixes III (CDC), IV
(DHS), V (USPS), VI (APHL), and VII (DOD). Their key concerns are
discussed below. In addition, most of these agencies, as well as APHL,
provided technical comments, which we addressed in the body of our report,
as appropriate.

CDC, DHS, and USPS, as well as APHL, agreed with our conclusion- methods
for detecting anthrax contamination in facilities were not validated-and
with the thrust of our recommendations-calling for a coordinated,
systematic effort to validate the methods to be used for such testing.
CDC, DHS, and USPS (1) disagreed with or expressed concern about our
conclusions or the recommendation dealing with targeted versus probability
sampling, (2) emphasized that validated testing methods for anthrax were
not available in 2001 and that federal and state organizations did the
best they could under the circumstances, and (3) identified factors or
issues that need to be considered in validating testing methods. DHS
indicated that some validation efforts are now under

way and other federal agencies, including EPA and HHS, have important
roles to play in addressing the sampling and validation issues we raised.
DHS also said that it would work with these agencies to define and address
validation and "develop a scientifically defensible sampling strategy." In
addition, USPS disagreed with our conclusion about negative results-that
there can be little confidence in their reliability due to the sampling
strategy used and the lack of validated testing methods.

CDC generally agreed with our recommendations addressing the need to
coordinate across various federal agencies and to improve and validate
environmental sampling methods for anthrax and other biothreat agents.
However, CDC did not believe that our draft report sufficiently recognized
the importance of targeted sampling. CDC, in its technical comments,
indicated that "the report could be more useful and informative" if it
provided additional information and clarification on the following four
issues: (1) public health context for environmental sampling, (2)
validation, (3) sampling and analytical methods, and (4) probability
versus targeted sampling.

In particular, first, CDC stated that the report's focus on environmental
sampling contributed to "a narrower view" than is needed to "understand
the full picture." According to CDC, when evaluating potential risks at a
given facility, it "typically combines environmental results from initial
assessment sampling information with other information, such as
outbreak-specific epidemiology findings and facility engineering and work
practice factors." In addition, CDC stated, "Environmental samples most
often identify surface contamination which is not the same as exposure.
Surface contamination is not directly translatable to risk of inhalation
anthrax and more research is needed on this correlation." We agree with
CDC that surface contamination is not directly translatable to risk of
infection. However, it is important to recognize that in our report, we
addressed fundamental and broad issues concerning sampling and analysis,
with implications far beyond public health, including key environmental
contamination issues, and that our report did not suggest that surface
contamination is directly translatable to risk. Nevertheless, a clear
understanding of the extent and degree of surface contamination is the
most basic requirement for understanding the risk to humans. Therefore, we
agree with CDC that more research should be done to improve sampling and
analytical methods, as well as the evaluation of risk.

Second, CDC stated that "it would not have been technically possible for
CDC or the other agencies to arrange for validation in a few days time
while in the midst of a national emergency." Further, CDC stated that

proper validation would require significant time and personnel. Therefore,
"full validation of every possible scenario variation would be impractical
and [that it] could not take the place of scientific judgment and
evaluation of the specific event." In our report, we identified the
absence of validation and some of the consequences; we did not state that
validation could have been carried out during the response phase. However,
we clarified our report in response to CDC's concern, as well as similar
concerns expressed by DHS and USPS. Furthermore, our report clearly stated
that empirical validation is a rigorous process, which requires time and
resources. In addition, we recommended that DHS conduct appropriate
validation studies, on a prioritized basis. These studies would not
attempt to address every scenario, but as an adjunct to scientific
evaluation of the specific event, they would enhance the reliability of
sampling and analytical methods.

Third, according to CDC, although validation was not performed, there was
an objective basis for choosing one sampling method over another during
the 2001 incidents. CDC cited its 20-year history of sampling and
analytical method development, collaborative work with LRN level B
laboratories, and a study conducted after the incident. We agree with CDC
that these factors may be useful in assisting agencies in choosing
methods. However, it is also important to note that these factors cannot
adequately substitute for empirical validation studies. We were pleased
that CDC agrees that more information is needed to fully establish the
validity of testing methods and that CDC has indicated that it is now
collecting data in support of validation.

Finally, CDC stated that "probabilistic sampling by itself [emphasis in
original statement] is unlikely to be as effective or expeditious as
targeted sampling" for initially identifying contamination for those cases
where there is some knowledge about the source. According to CDC, a
targeted sampling strategy can provide a rapid determination of whether
contamination is present. However, we believe a major weakness of the
approach is that if all samples are negative, it is not possible to
conclude, with a defined level of confidence, that a facility is free of
contamination. CDC does agree that targeted sampling does not support
statistical inference. In contrast to targeted sampling, probability
sampling allows more detailed interpretation of negative results. Such
sampling allows extrapolation, in a statistically valid way, as to the
level of contamination. In interpreting negative results, a known level of
confidence is needed because evidence suggests that even a few anthrax
spores could cause disease in susceptible individuals.

According to CDC, the report's focus on negative results might obscure a
number of larger issues. For example, CDC pointed out that "A key goal of
initial assessment is rapid [emphasis in original statement] determination
of whether contamination is present so public health decisions can be
quickly made." CDC then suggests that timeliness is important because
public health interventions such as "provision of post-exposure
prophylaxis is most effective if administered within a short time window
after exposure." Nevertheless, if results were falsely negative, agencies
would have no basis for taking public health measures for the occupants of
the contaminated building. Thus, relying solely on targeted sampling could
actually result in delays in implementing time-critical public health
interventions. On the other hand, we recognize that implementation of
probability sampling would generate a larger sample size than initial
targeted sampling, which may not be possible for a laboratory to analyze
at one time. However, we believe that steps can be taken to address this
issue, as we discussed in this report; that is, samples can be analyzed in
a prioritized way. Furthermore, we agree that targeted sampling can play a
useful role in prioritizing sample collection or in selecting areas or
surfaces considered most likely to be contaminated, when the source of
contamination is definitive.

We consider probability sampling to be a viable approach that would
address not only the immediate public health needs-provision of
antibiotics-but also the wider general environmental contamination issues,
such as infrastructure cleanup. In any particular facility, probability
sampling could operate in the following ways: At the outset of a response,
a statistically based probability-sampling plan would be drawn, based on
the facility dimensions, complexities, and other characteristics. Initial
outbreak sampling, within the dictates of the probability-sampling plan,
could be targeted to those areas that, based on scientific and technical
judgments (if available), are considered most likely to be contaminated.
We believe that targeted sampling can be an important component of the
wider probability-sampling plan, provided information on the source of
contamination is definitive. If these early (targeted) samples yield
positive results, then appropriate public health measures could be
instituted. Further sampling of the facility, to address characterization
and cleanup issues, could take place subsequently. But if initial targeted
samples were negative when the likely contamination source is not
definitive, completing the probability-sampling plan would then permit an
assessment, with appropriate confidence limits, of the likelihood of
contamination, even if all of the samples taken were negative.

DHS stated that while it has the overall responsibility for coordination
for future biological attacks, EPA has "the primary responsibility of
establishing the strategies, guidelines, and plans for the recovery from a
biological attack while HHS has the lead role for any related public
health response and guidelines." DHS further stated that EPA "is
developing specific standards, protocols, and capabilities to address the
risks of contamination following a biological weapons attack and
developing strategies, guidelines, and plans for decontamination of
persons, equipment, and facilities [emphasis in original statement]." DHS
pointed out that in the Conference Report on H.R. 4818, the conferees
expressed their expectation that EPA will

enter into a comprehensive MOU [memorandum of understanding] with DHS no
later than	August 1, 2005 that will define the relationship and
responsibilities of these entities with 	regard to the protection and
security of our Nation. The Conferees expect the MOU to 	specifically
identify areas of responsibilities and the potential costs (including
which entity 	pays, in whole or part) for fully meeting such
responsibilities. EPA shall [is to] submit to	the House and Senate
Committees on Appropriations a plan no later than	September 15, 2005 that
details how the agency will meet its responsibilities under the	MOU,
including a staffing plan and budget. 	

Finally, DHS stated, "Even though DHS is in charge during a biological
attack, EPA is primarily responsible for the coordination of the recovery
process. So, DHS will coordinate with EPA to ensure appropriate
investments are made to explore improved sampling."

With respect to our recommendation that DHS develop probability-based
sampling strategies, DHS said that it must first define the necessary
requirements for the sampling process and then evaluate targeted and
probability-based sampling strategies against those requirements. DHS said
that targeted sampling may be beneficial for some applications. We agree
with DHS on the need to define the requirements for the sampling process
and to evaluate sampling approaches against those requirements. On the
basis of the work we have done on this review, we believe that (1) DHS
will find that targeted sampling will not always meet all the requirements
to answer the question of whether a facility is contaminated and (2)
probability-based sampling will be necessary when information on the
source and path of potential contamination is not definitive. In our view,
this will be the case in order for DHS to achieve its goal of having a
"scientifically defensible sampling strategy and plan."

Although USPS disagreed with some aspects of our findings and conclusions,
it generally agreed with our recommendations to DHS and

noted in particular its belief that validated detection methods should be
developed for all biothreat agents. USPS disagreed with our finding about
the reliability of negative results, that is, that there can be little
confidence in them because the agencies involved did not use probability
sampling and there was no validation of agencies' sample collection and
analytical methods. It pointed out that it followed the advice it received
from the best available experts at the time. USPS further pointed out that
the efficacy of its testing approach was confirmed by the August 2004
report of a working group that was convened to respond to a recommendation
we had previously made; this group's findings were discussed earlier in
this report. On the other hand, USPS acknowledged that (1) disputes about
its testing protocols arose among experts after it had substantially
completed its testing and (2) even today, there is still no consensus
among experts on the best sampling method to use.

We are not challenging the conclusions reported in the August 2004 report
by the working group that more that 3 years after the anthrax incident
postal workers in the postal facilities tested in the fall of 2001 faced
little risk from anthrax. However, for the reasons discussed in our
report, the working group's conclusions do not mean that the negative test
results--produced in 2001 using targeted sampling and nonvalidated testing
methods-were reliable. As the working group points out in its August 2004
report, the fact that no one at these facilities has become sick from
anthrax since 2001 provides strong evidence that the number of residual
spores is low or that conditions no longer exist for spores to become
aerosolized and create harmful exposures. But this rationale cannot be
used to conclude that the sampling approach and testing methods used in
2001 produced reliable results. As we learned in 2001, a few spores can
cause death (as was the case with the elderly Connecticut woman); given
that the potential for more people to have been affected by anthrax
existed in 2001, it was fortunate that no one else has become sick. We
cannot rely on the argument that no one has become sick to answer the
question of whether facilities are contaminated. In the future, we need to
base such conclusions on appropriate sampling methods and validated
testing methods. USPS, however, agreed with our recommendations and on the
importance of validation.

APHL agreed with the need for validated testing methods and indicated that
the lack of such methods hindered laboratories in 2001 and remains a
critical gap in preparedness and response today. APHL also said that with
the advent of the Biohazard Detection System in postal facilities, there
is an urgent need for standard sampling and testing methods to avoid
complication and lack of confidence in resolving any initial positive

screening results. In addition, APHL expressed some concerns with the
excerpts from our draft report that it reviewed. APHL said that it was
concerned that the sections of the report it reviewed could be interpreted
as an indictment of its decisions without adequately considering (1) the
urgency of the situation, (2) the context in which decisions had to be
made, and (3) the basis of the decisions. In particular, APHL said that
the report implied decisions were made based on convenience and hearsay
instead of scientific knowledge of conventional microbiology and bacterial
spore characteristics. APHL also said that it found numerous scientific
inaccuracies, misinterpretations, and undocumented statements.

It was not our intent to suggest that APHL's decisions were based on
convenience and hearsay. We stated in our report that limitations existed
in the amount of information available in 2001 about anthrax and testing
methods to detect it. We also pointed out that since the fall of 2001,
agencies have not been fully prepared. In addition, we stated that experts
have differing views on the definition of validation and how validation
should be done. We were not in a position to resolve these disagreements
and based our recommendation for more research partly on these
disagreements. Furthermore, we do not believe that the report contained
inaccuracies and misinterpretations. We reported the information provided
to us by various agencies and experts and obtained documentation or
corroboration whenever possible. As we said in the report, however, there
were instances in which people expressed differing views; in the case of
the use of dry versus premoistened swabs, conflicts existed between what
was sometimes said orally and-based on documents we were provided-what was
written. As we also state in the report, agencies were not in a position
to give definitive advice on issues related to sample collection and
analytic methods due to the lack of validated methods. We believe this
situation contributed to APHL's concerns.

APHL also identified what it considered an example of a technical error,
that is, our statement that

the decision to use dry rather than wet swabs stemmed partly from the
concern of some public health officials, including APHL officials, that
moistened swabs would allow anthrax spores to germinate and grow into
vegetative cells instead of remaining as spores. APHL officials said that
it was feared that vegetative cells would be destroyed during certain
analytical procedures. Other public health officials we interviewed said
this was highly unlikely.

Several experts, as well as other public health officials we consulted,
said it was unlikely that anthrax spores would germinate on premoistened
swabs into vegetative cells. Consequently, spores (as opposed to
vegetative cells) would not be killed during the heat shock procedure. We
clarified the text to reflect this. In addition, APHL stated that concern
that some of the unknown substances (such as paper debris, dust, and
harmless environmental bacteria and fungi) combined with moisture, would
promote germination. APHL was concerned that during transport, the
resulting vegetative cells would be more susceptible to dying off in the
complex milieu than the spores. However, we stated in this report that
anthrax spores are robust compared with other pathogenic microorganisms.
Nevertheless, we also stated that whether transportation conditions could
have affected the postal samples' viability is not known because the
conditions of their transportation were not validated. We addressed APHL's
other technical comments in the report as appropriate.

As we agreed with your office, unless you publicly announce the contents
of this report earlier, we plan no further distribution until 30 days from
its issue date. We will then send copies of this report to other
interested congressional members and committees. In addition, the report
will be available at no charge on GAO's Web site at http://www.gao.gov.

Other staff who contributed to this report included Hazel Bailey, Heather
Balent, Venkareddy Chennareddy, Jack Melling, Penny Pickett, Laurel Rabin,
Mark Ramage, and Bernard Ungar.

If you or your staff have any questions about this report or would like
additional information, please contact me at (202) 512-6412, or Sushil
Sharma, PhD., DrPH, at (202) 512-3460. We can also be reached by e-mail at
[email protected] and [email protected].

Sincerely yours,

Keith A. Rhodes, Chief Technologist Center for Technology and Engineering
Applied Research and Methods

Appendix I: Objectives, Scope, and Methodology

To describe and assess federal agencies' activities to detect anthrax
contamination in postal facilities in 2001, we interviewed officials from
the agencies involved in sampling the facilities or analyzing the samples
that were collected from the facilities. Among them were the United States
Postal Service (USPS); the U.S. Army Medical Research Institute of
Infectious Diseases (USAMRIID) in the Department of Defense (DOD); the
Centers for Disease Control and Prevention (CDC) and its National Center
for Infectious Diseases (NCID) and National Institute for Occupational
Safety and Health (NIOSH), which are within the Department of Health and
Human Services (HHS); the Agency for Toxic Substances and Disease Registry
(ATSDR), also within HHS; the Environmental Protection Agency (EPA); and
the U.S. Army Corps of Engineers.

We interviewed officials from public health laboratories and private
sector laboratories that analyzed some of the samples from the postal
facilities, as well as officials from the Association of Public Health
Laboratories (APHL), which was involved in an agreement with USPS under
which public health laboratories analyzed samples USPS contractors
collected from the facilities. Finally, we interviewed experts,
technicians, and researchers, including scientists who have worked on
microbial detection in indoor environments. These scientists are Robert
Hamilton, Johns Hopkins University School of Medicine; Paul Keim,
University of Arizona; George Ludwig, USAMRIID; Jeff Mohr, U.S. Army
Dugway Proving Ground; and Linda Stetzenbach, University of Nevada at Las
Vegas. We did not review sampling techniques used by the Federal Bureau of
Investigation (FBI), in view of the ongoing criminal investigation.

We performed literature searches and reviewed studies and scientific
literature, including anthrax on surface and air sampling methods for
detecting biological substances on surfaces and in the air. We also
performed literature searches and reviewed agency, association, and
industry documentation on sampling activities-the five activities we
identified. In particular, we looked at the development and key elements
of sampling plans through to laboratory analysis of samples, including the
types of sampling approaches; federal regulations for transporting
infectious substances by land, sea, and air; and extraction and analytic
procedures used by the Laboratory Response Network (LRN) laboratories and
others to confirm the presence of hazardous substances in samples,
including biological substances such as anthrax. We also looked at
potential variables that could be associated with all these activities.

We focused our data collection on sampling activities agencies performed
to detect whether anthrax was present. We also interviewed local public

Appendix I: Objectives, Scope, and Methodology

health officials, USPS managers, and others associated with the primary
facilities. We conducted site visits to some postal facilities that were
affected, as well as some state public health and private sector
laboratories involved in analyzing the samples.

To assess the results of the federal agency testing in the facilities, we
analyzed CDC, EPA, and USPS data on some initial sampling activities
during October 2001 through April 2002, when the Wallingford facility was
sampled for the final time. Throughout our review, we contacted agency and
public health officials to discuss the data they provided and to clarify
any inconsistencies we identified. CDC, EPA, and USPS provided us with
some data on the FBI testing. The data we report on the FBI sampling
events were included in the information CDC, EPA, and USPS provided us.

Because multiple agencies conducted sampling in the postal facilities,
there were multiple sources of information. As a result, we combined the
information CDC, EPA, and USPS provided us into a single database for
analysis. In addition, because multiple sampling events were conducted in
some USPS facilities, we reported the data as numbers of "sampling events"
rather than numbers of facilities sampled. Finally, if there was more than
one sampling event in a particular facility, we included information on
each event. For example, in Wallingford, on November 11, 2001, through
November 28, 2001, there were four separate sampling events before anthrax
was eventually detected. USPS sampled two times, with negative results;
CDC sampled two times, with positive results the second time.

Data for USPS sampling typically came from contractor-generated anthrax
sampling reports. Data for CDC and EPA sampling came from multiple
sources, as did data for facilities that had positive samples. When there
was more than one data source for a particular sampling event, we compared
these sources for consistency. To deal with inconsistencies among sources,
we reported data that were supported by greater detail and that were
reported more often across these sources. The most frequent
inconsistencies involved facility name, number of samples collected, or
date of sampling event.

For USPS sampling events, we determined the collection method, generally
by reviewing and analyzing laboratory documentation and USPS written
sampling plans. From interviews with USPS officials, as well as officials
from some of the laboratories that analyzed the samples, we corroborated
that USPS generally used dry swabs. For CDC and EPA, we determined the
collection methods they used by reviewing and analyzing

Appendix I: Objectives, Scope, and Methodology

documentation they provided, as well as other data sources, such as agency
chronologies, published information on the anthrax investigation, and
interviews with agency laboratory officials.

When appropriate, we used our best judgment on all the information
provided in order to complete information that was missing. For example,
information on some facilities that CDC sampled was incomplete. Therefore,
we assumed that the sample collection method and reason for sampling in
those particular facilities were the same as the method and reason for
other facilities sampled by CDC in the same area at about the same time.
CDC, in light of missing information, agreed with our assumptions. We made
similar assumptions for the FBI sampling events, for which information was
not obtained. For example, we assumed that the FBI used premoistened swabs
in the New Jersey facilities because data from USPS and interviews with
New Jersey public health officials indicated that the FBI had used
premoistened swabs in these facilities. To the extent possible, we
improved the accuracy of the data provided to us by corroborating it with
published data. We relied on sources such as articles in CDC's journal,
Emerging Infectious Diseases, and on interviews with CDC, EPA, USPS,
USAMRIID, U.S Army Corps of Engineers, and public health officials.

To assess the reliability of the CDC, EPA, and USPS data, we (1) compared,
for obvious errors and accuracy, all sources of information on anthrax
sampling events in USPS facilities; (2) interviewed officials- from CDC,
EPA, USPS, and laboratories-who were knowledgeable about the data; (3)
reviewed related documentation, including articles in peer reviewed
journals; and (4) worked with agency officials to correct data problems we
discovered. We also worked with USPS officials to correct for missing
data, and discrepancies as well as differing facility names, before
completing our analysis. For other discrepancies, such as inconsistent
numbers of samples collected, we used our best judgment, which we based on
all the information provided to us, including contractor-generated
sampling reports and agency summaries of sampling events. We generally
used the data in the source with the most specific details of the sampling
event. We also provided agencies, for their review, with copies of our
final data set.

After we determined that the data were sufficiently reliable for the
purposes of this report, we concluded that any remaining discrepancies-
such as inconsistencies in the multiple data sources, that is, the number
of samples collected and the collection methods used during every sampling
event-were likely to be minimal. For example, more samples may have

Appendix I: Objectives, Scope, and Methodology

been collected or USPS may have used wipes as a collection method more
often than we identified. However, such discrepancies do not have a
material impact on our results. We did not independently verify test
result data or laboratory or contractor compliance with testing or
sampling protocols provided to us by USPS and other federal agencies.

To assess whether the agencies' activities were validated and to describe
their validation processes, we interviewed agencies' officials and experts
from CDC (including NCID and NIOSH), EPA, and USPS, as well as APHL,
ASTDR, DOD, Johns Hopkins University, the University of Nevada at Las
Vegas, the U.S. Army Dugway Proving Ground, USAMRIID, and selected public
health laboratories and private sector laboratories. We performed
literature searches and reviewed validation procedures and criteria. We
also reviewed validation methodology, for other types of substances, by
recognized validation authorities. To determine the federal agencies'
actions to address anthrax testing issues, we reviewed the related
policies, procedures, and guidelines they issued after fall 2001;
interviewed various officials, experts, and researchers; and reviewed
literature and other relevant documents.

We conducted our review from May 2003 through November 2004 in Washington,
D.C., and in Atlanta, Georgia; Las Vegas, Nevada; Miami, Florida; New
York, New York; Salt Lake City, Utah; Trenton, New Jersey; and
Wallingford, Connecticut. We conducted our review in accordance with
generally accepted government auditing standards.

Appendix II: Information on Sampling Events in Facilities with Positive
Results

Sampling Samples collected Positive samples Agencya completed Number and
type General locationb Number and type General location

Trenton P&DC (primary facility) Brentwood P&DC (primary facility) Morgan Station
                            P&DC (primary facility)

                               25   Machinery,                                
     FBI   10/18/01  premoistened   corners of    14 positive    Machinery
                                     facility                  
                        swabs                     premoistened 
                                                  swabs        
NJDHSS                      20  Common areas        0             NA       
           10/18/01  premoistened (lobby, locker               
                        swabs          room,                   
                                    lunchroom)                 
                                  Machinery,                                  
CDC and                     57 workstations,                 Desk, floor,
           10/21/01  premoistened offices,        20 positive  
                                  common areas,   premoistened                
NJDHSS               swabs     air-handling    swabs          machinery,
                                  unit                         
                                                                workstations, 
                                                                         air- 
                                                               handling unit  
                                    Machinery,                                
CDC and                     27  rafter, pipe,               Machinery,     
           11//9/01  premoistened      air-       19 positive  air-
NJDHSS               swabs      handling unit  premoistened handling units 
                                                  swabs        
                    8 HEPA vacuum                  4 positive  
                                                      HEPA     
                                                     vacuum    

USPS 10/18/01  29 dry swabs  Machinery, government  14 positive dry swabs  
                                mail area                   Machinery,        
                                                              government mail 
                                                                         area 
USPS 10/18/01     2 HHAs        Machine filter              0 NA           
                                                      8 positive wet wipes No 
CDC  10/23/01 114 wet wipes     No information     information             
                 39 HEPA vacuum                          27 positive HEPA     
                     12 air                                   vacuum          
                                                          0 positive air      

                                       c

USPS 10/22/01	146 dry swab Machinery, vacuums, manual 4 positive dry swabs
Machinery, 2 controls cases manual cases

 CDC 10/25/01 56 dry swabs Machines and other locations 7 positive dry swabs No
                                  information

                             Blue Lake Post Office

FBI 10/14/01	29 premoistened swabs

6 vacuum

3 controls

                          Cages, bins, box, sort area,

d

                           1 positive No information

c

                                machinesvacuums,

                          Boca Raton Main Post Office

FBI 10/12/01	6 premoistened Cases, flats, sort area, canvas 2 positive
Cases and sort swabs bag premoistened swabs area 1 bulk (results for bulk
not

reported)3 controls

CDC and EPA

10/15/01 23 premoistened swabs

1 control

                         Letter throwback, case, cage,

1 positive premoistened swab

                                      Case

                                       c

                                     vacuum

Appendix II: Information on Sampling Events in Facilities with Positive Results

Sampling Samples collected Positive samples Agencya completed Number and
type General locationb Number and type General location

                               Dulles Post Office

CDC 10/25/01	11 premoistened Sorting area, tray, camera 1 positive Sorting
table swabs monitor, mailboxes, TV screen, premoistened swab 1 control
cart, window, computer screen

                               Friendship Station

CDC 10/24/01	32 premoistened Elevator, cart, cases, dock, bins, 1 positive
Composite from swabs sort station, computer monitor premoistened swab
cases

5 controls

  Greenacres Post Office Indianapolis Critical Parts Center & Repair Facility
Jackson Main Post Office Kansas City Stamp Fulfillment Services Lake Worth Post
                                     Office

CDC and 10/19/01 12 premoistened Clerk case, floor, Invalid-laboratory  NA 
                                    bin, shelf                            
EPA              swabs                              error              
                      2 controls                                          
CDC and                          Case, bin, water                      Bin 
           10/20/01 17 premoistened bottle, vehicle,   2 positive         
EPA              swabs           camera             premoistened swabs 
                       1 control                                          

USPS 10/26/01 44 dry Computer, desk, workstation, 2 positive 1 positive on 
                 swabs                               dry swabs          table 
                        c mechanical room, vacuum,                  in repair 
                        dust                                         area and 
                        collector, air filtration,              1 positive on 
                        fan, printer,                           
                                repair area                        printer    

CDC 11/3/01 24 premoistened Machinery, sort      1 positive   Machinery    
                               station, vacuum,c       swab    
                    swabs       fan, vehicle, bin,             
                                    computer,                  
                               workstation, phone,             
                               public area,                    
                                       dock                    
FBI 11/9/01 15 premoistened    No information     Positive  No information 
                    swabs                                      

USPS 10/28/01  26 dry swabs       Trays, sacks,      2 positive 1 positive 
                                     machines, work      dry swabs on a       
                                     area, pallets,                  sack and 
                   2 controls         workstations                    control 
                                                                       sample 
CDC  11/6/01  50 premoistened     No information         0          NA     
                      swabs                                        
                   5 controls                                      
                                  Pallets, box, white                         
USPS 11/28/01  52 dry swabs           powder             0          NA

CDC and 10/16/01 3 premoistened Cases, accountables, ledge 2 positive Case
and ledge EPA swabs premoistened swabs

1 wet wipe

2 controls

Appendix II: Information on Sampling Events in Facilities with Positive Results

Sampling Samples collected Positive samples Agencya completed Number and
type General locationb Number and type General location

                              Lucerne Post Office

CDC and 10/28/01 8 premoistened Missort box, case 1 positive Missort box
EPA swabs premoistened swab

                                Pentagon Station

CDC 10/30/01	17 premoistened PO boxes, lobby, carts, 2 positive PO boxes
swabs computer, case, radio, cabinet premoistened swabs

2 controls

           Princeton Main Post Office Princeton-Palmer Square Station

FBI 10/27/01 23 premoistened No information    1 positive               No 
                                                                  information 
                     swabs                     premoistened swab 
CDC 10/27/01 14 premoistened No information         0              NA      
                     swabs                                       
                  8 HEPA vacuum                                  

CDC 11/3/01 19 premoistened Case, cart, window, TV,    1 positive     Case 
                                       public                            
                    swabs      area, workspace,        premoistened swab 
                               cabinet, CRT                              
                                    screen, lobby                        
FBI 11/9/01 15 premoistened     No information              0          NA  
                    swabs                                                

Raleigh P&DC

USPS 11/8/01 42 dry  Lobby, PO boxes, mailroom  1 positive dry Accountable 
                swabs                              swab           
                       surfaces, machinery, cases,                            
                       air-                                        paper room
                       handling unit, flats,                      
                       vacuum,c                                   
                         accountable paper room                   

                    Rocky Hill Post Office South Jersey P&DC

CDC 11/3/01 15 premoistened Lobby, ledge,         1 positive  Ledge where  
                               missent mail, sort                
                    swabs       area, CRT screen,   premoistened   large mail 
                                    microwave       swab              carrier 
                                                                  is placed   
FBI                            No information         0       No           
       11/9/01 15 premoistened                                   information  
                    swabs                                        

FBI  10/31/01 40 premoistened    CRT station only     1 positive       CRT 
                                        location                      station 
                      swabs            identified       premoistened 
                                                        swab         
USPS                          Docks, machine, cases,      0          NA    
        11/1/01     27 wipes             HVAC,                       
                                   maintenance shop,                 
                                       conference                    
                                      room, lobby                    
CDC  11/11/01 56 premoistened     No information          0          NA    
                      swabs                                          
USPS           60 HEPA vacuum   Docks, machinery,         0          NA    
        2/14/02                       air-handling                   
                                   unit, boiler room                 

Appendix II: Information on Sampling Events in Facilities with Positive Results

Sampling Samples collected Positive samples Agencya completed Number and
type General locationb Number and type General location

                    Southern Connecticut P&DC (Wallingford)

USPS    11/11/01    53 dry swabs    Docks, vacuum,c common areas,   0   NA 
                                       machinery, manual cases, air-      
                                       handling unit                      
USPS    11/21/01    64 dry swabs    Vacuum,c manual cases,          0   NA 
                                       machinery                          
CDC     11/25/01    60 premoistened Machinery, vacuums              0   NA 
                     swabs                                                

CDC 11/28/01    4 swabs      Machinery, bins,     4 positive wet Machinery 
                                    columns,                  wipes 
                 87 wet wipes   stockroom, vacuum  2 positive HEPA  
                90 HEPA vacuum                          vacuum      
                   21 HEPA                                          
                 composite e                                        
                 10 controls                                        

USPS 4/21/02 64 HEPA vacuum High bay areaf	3 positive HEPA High-bay area
vacuum

                               Southwest Station

CDC 10/23/01 20 premoistened Conference room, package 1 positive Bin swabs
window, lobby, desk, mail tote, premoistened swab slots, mail tub, bins

                     Trenton Station E West Palm Beach P&DC

CDC 11/3/01  18 premoistened Truck, dock, bin,    1 positive      Bin      
                                safe, computer                   
                     swabs      screen, fan, public premoistened 
                                    area, sort      swab         
                                  area, janitor's                
                                   closet, vent                  
FBI                            No information      Positive             No 
       11/16/01 15 premoistened                                   information 
                     swabs                                       

CDC and 10/24/01 21 premoistened      Cases             0           NA     
     EPA                 swabs                                      
                       1 control                                    
                                        Vacuum,c                              
CDC and                           machinery, air                 
           10/27/01 71 premoistened      filter        5 positive   Vacuum,
     EPA                 swabs                       premoistened   machinery 
                                                     swabs          
                      4 controls                                    
CDC and 10/30/01 15 premoistened    Machinery       2 positive   Machinery 
     EPA                 swabs                       premoistened   
                                                     swabs          
                      2 controls                                    
CDC and 11/3/01  8 premoistened     Machinery           0           NA     
     EPA                 swabs                                      
                      2 controls                                    
                                    Office,                                   
    USPS                            machinery,       1 positive dry 
           11/11/01  38 dry swabs   manual cases,    swab           Machinery
                                      stamp room,                   
                                         filter                     

Source: GAO analysis of CDC, EPA, and USPS data.

Appendix II: Information on Sampling Events in Facilities with Positive
Results

Notes: "P&DC" stands for "processing and distribution center." "NA" means
not applicable. "No information" means that no information was provided to
GAO.

aWe sought no information directly from the FBI on the sampling events it
conducted. We received information from CDC, EPA, and USPS on the number
and locations of samples collected and the methods used by the FBI.
However, we did not receive complete information on all FBI sampling
events. Therefore, we made assumptions about the method used during the
FBI sampling events for which complete information was not provided, based
on the method reported as having been used by the FBI during the same
period and in the same geographic area.

bLocations in the table do not reflect locations from which every sample
was collected. Instead, these locations are intended to provide a general
idea of the types of locations from which samples were collected.

c"Vacuum" refers to samples collected from vacuums as well as from vacuum
filters.

dInformation on location and collection method was not provided.

eTwenty-one of the HEPA vacuum samples collected during this sampling
event were combined into four composite samples-combinations of more than
one sample collected at various sampling locations. Analysis of composite
samples yields an average value of concentration within a number of
locations, and composite samples can be used to keep analysis costs down.

fHigh-bay areas are elevated areas, including pipes, ducts, lights,
joists, beams, and overhead conveyors.

Appendix III: Comments from the Centers for Disease Control and Prevention

Appendix III: Comments from the Centers for Disease Control and Prevention

Appendix III: Comments from the Centers for Disease Control and Prevention

                         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

                     Page 107 GAO-05-251 Anthrax Detection

                     Page 108 GAO-05-251 Anthrax Detection

Appendix VI: Comments from the Association of Public Health Laboratories

Appendix VI: Comments from the Association of Public Health Laboratories

Appendix VI: Comments from the Association of Public Health Laboratories

Appendix VI: Comments from the Association of Public Health Laboratories

Appendix VII: Comments from the Department of Defense

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