Agricultural Inspection: Improvements Needed to Minimize Threat of
Foreign Pests and Diseases (Letter Report, 05/05/97, GAO/RCED-97-102).
GAO reviewed the Animal and Plant Health Inspection Service's (APHIS)
efforts to minimize the risks to agriculture from pests and diseases
entering the United States, focusing on: (1) recent developments that
could challenge the ability of APHIS' Agricultural Quarantine and
Inspection program to carry out its mission; (2) APHIS' efforts to cope
with these developments; and (3) the effectiveness of the inspection
program in keeping pace with workload changes.
GAO noted that: (1) several developments are challenging APHIS' ability
to effectively manage its inspection program; (2) key among these is the
rapid growth in international trade and travel since 1990, which has
dramatically increased the amount of cargo and the number of passengers
that inspectors are to examine; (3) in addition, policy changes that
emphasize facilitating trade and customer service have put pressure on
APHIS to carry out its increased inspection responsibilities more
quickly in order to speed the flow of passengers and trade; (4) APHIS
has taken several steps to cope with these developments; (5) it
increased funding and staffing for inspections by about 78 percent and
44 percent, respectively, from fiscal year (FY) 1990 to 1996; (6) the
agency has attempted to improve the efficiency and effectiveness of its
inspections by: (a) using other inspection techniques in addition to
visual inspections, such as x-ray technology and detector dogs, to
pinpoint prohibited agricultural products, such as untreated fruits,
vegetables, and meats from countries that present a higher risk for
pests and diseases; and (b) coordinating with other Federal Inspection
Service agencies to maximize inspection activities; (7) APHIS it began
implementing its results monitoring program in FY 1997 to better
understand which ports of entry and commodities pose the highest risks
of entry for harmful pests and disease; (8) despite these changes,
inspectors at the ports GAO visited are struggling to keep pace with
increased workload; (9) heavy workloads have led to inspection
shortcuts, which raise questions about the efficiency and overall
effectiveness of these inspections; (10) on a broader scale, APHIS'
efforts to address its workload problems are hampered by inadequate
information for determining how to best deploy its inspectors; (11) in
particular, its current staffing models, mathematical formulas used to
help determine inspection staffing needs, are not based on reliable
information and do not incorporate risk assessment factors similar to
those being developed in its results monitoring program; and (12)
consequently, APHIS has little assurance that it is deploying its
limited inspection resources at the nation's ports of entry that are
most vulnerable to the introduction of pests and diseases.
--------------------------- Indexing Terms -----------------------------
REPORTNUM: RCED-97-102
TITLE: Agricultural Inspection: Improvements Needed to Minimize
Threat of Foreign Pests and Diseases
DATE: 05/05/97
SUBJECT: Inspection
Pest control
Agricultural pests
Interagency relations
Import regulation
Agricultural products
Plant diseases
Foreign trade policies
International trade restriction
Human resources utilization
IDENTIFIER: NAFTA
North American Free Trade Agreement
USDA Agricultural Quarantine Inspection Program
USDA AQI Results Monitoring Program
Customs Service Automated Commercial System
Treasury Enforcement Communications System
USDA Workload Accomplishment Data System
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Cover
================================================================ COVER
Report to Congressional Committees
May 1997
AGRICULTURAL INSPECTION -
IMPROVEMENTS NEEDED TO MINIMIZE
THREAT OF FOREIGN PESTS AND
DISEASES
GAO/RCED-97-102
Agricultural Inspection
(150919)
Abbreviations
=============================================================== ABBREV
APHIS - Animal and Plant Health Inspection Service
AQI - Agricultural Quarantine Inspection
FIS - Federal Inspection Service
GAO - General Accounting Office
GSA - General Services Administration
INS - Immigration and Naturalization Service
NAFTA - North American Free Trade Agreement
PPQ - Plant Protection and Quarantine
WADS - Workload Accomplishment Data System
Letter
=============================================================== LETTER
B-276421
May 5, 1997
Congressional Committees
Foreign pests and diseases entering the United States cost an
estimated $41 billion annually in lost production and expenses for
prevention and control, according to the U.S. Department of
Agriculture (USDA). USDA's Animal and Plant Health Inspection
Service (APHIS) is responsible for minimizing the risks of
infestation and disease and protecting the health of U.S.
agriculture by, in part, inspecting passengers and cargo entering the
country. As global trade and travel expand, the potential for
infestations is likely to increase, and so is APHIS' inspection
workload.
To assess APHIS' effectiveness in minimizing the risks to agriculture
from pests and diseases entering the United States, we (1) identified
recent developments that could challenge the ability of APHIS'
Agricultural Quarantine and Inspection program to carry out its
mission, (2) reviewed APHIS' efforts to cope with these developments,
and (3) reviewed the effectiveness of the inspection program in
keeping pace with workload changes.
This report is based on work we conducted at APHIS' headquarters in
Washington, D.C., as well as at 12 of the 172 ports of entry where
APHIS inspectors regularly inspect individuals and goods entering the
United States. The ports of entry that we examined represent a high
volume of traffic as measured by people or goods entering the United
States and include the nation's three busiest ports of entry.
Appendix I provides more details on the scope and methodology of our
work.
RESULTS IN BRIEF
------------------------------------------------------------ Letter :1
Several developments are challenging APHIS' ability to effectively
manage its inspection program. Key among these is the rapid growth
in international trade and travel since 1990, which has dramatically
increased the amount of cargo and the number of passengers that
inspectors are to examine. In addition, policy changes that
emphasize facilitating trade and customer service have put pressure
on APHIS to carry out its increased inspection responsibilities more
quickly in order to speed the flow of passengers and trade.
APHIS has taken several steps to cope with these developments.
First, it increased funding and staffing for inspections by about 78
percent and 44 percent, respectively, from fiscal year 1990 to 1996.
Second, the agency has attempted to improve the efficiency and
effectiveness of its inspections by (1) using other inspection
techniques in addition to visual inspections, such as x-ray
technology and detector dogs, to pinpoint prohibited agricultural
products, such as untreated fruits, vegetables, and meats from
countries that present a higher risk for pests and diseases; and (2)
coordinating with other Federal Inspection Service agencies to
maximize inspection activities. Third, it began implementing its
results monitoring program in fiscal year 1997 to better understand
which ports of entry and commodities pose the highest risks of entry
for harmful pests and disease.
Despite these changes, inspectors at the ports we visited are
struggling to keep pace with increased workload. Heavy workloads
have led to inspection shortcuts, which raise questions about the
efficiency and overall effectiveness of these inspections. On a
broader scale, APHIS' efforts to address its workload problems are
hampered by inadequate information for determining how to best deploy
its inspectors. In particular, its current staffing
models--mathematical formulas used to help determine inspection
staffing needs--are not based on reliable information and do not
incorporate risk assessment factors similar to those being developed
in its results monitoring program. Consequently, APHIS has little
assurance that it is deploying its limited inspection resources at
the nation's ports of entry that are most vulnerable to the
introduction of pests and diseases.
BACKGROUND
------------------------------------------------------------ Letter :2
APHIS is the lead federal agency for preventing infestations of
harmful foreign pests and diseases, protecting U.S. agriculture, and
preserving the marketability of agricultural products in the United
States and abroad. The agency's Plant Protection and Quarantine unit
(PPQ) exercises regulatory authority to inspect agricultural
imports,\1 as well as nonagricultural products that may carry pests,
largely through its Agricultural Quarantine Inspection (AQI)
activities. In fiscal year 1996, APHIS allocated an estimated $151.9
million for AQI activities and had about 2,600 inspectors located at
172 land, sea, and air ports of entry. APHIS has other inspection
duties, such as inspections of imported and exported live animals,
that are not the subject of this report.
APHIS is one of the three primary Federal Inspection Service (FIS)
agencies responsible for monitoring the entry of cargo and passengers
into the United States. The two other FIS agencies are the U.S.
Customs Service in the Department of the Treasury and the Immigration
and Naturalization Service (INS) in the Department of Justice. The
U.S. Customs Service is primarily concerned with collecting duties
on imports, enforcing antismuggling laws, and interdicting narcotics
and drugs. INS inspects foreign visitors to determine their
admissibility into the United States and guards against illegal
entry.
Recent multilateral trade agreements--the North American Free Trade
Agreement (NAFTA) and the results of the General Agreement on Tariffs
and Trade's Uruguay Round of Multilateral Trade Negotiations (Uruguay
Round)--have provisions that affect APHIS' inspection activities.\2
Both agreements contain provisions on signatories' use of sanitary
and phytosanitary standards that limit the introduction of foreign
pests and diseases. To prevent the standards from impeding
agricultural trade, they must be based on scientific principles and
risk assessment, provide a level of protection appropriate to the
risk faced, and not restrict trade more than necessary.\3
--------------------
\1 APHIS' regulatory authority is cited in 7 U.S.C. 147-150.
\2 NAFTA is a trade agreement among the United States, Mexico, and
Canada that was implemented in 1994, while the Uruguay Round
agreements, implemented in 1995, apply to over 100 member countries
of the new World Trade Organization.
\3 APHIS is currently developing pest-risk standards to comply with
the trade agreements. These standards, based on risk assessments,
form the foundation for changing inspection program procedures,
including the frequency and intensity of inspections.
SEVERAL DEVELOPMENTS POSE
CHALLENGES TO INSPECTION
PROGRAM
------------------------------------------------------------ Letter :3
APHIS' inspection workload has increased dramatically since 1990
because of growth in imports and exports, increased travel, and
increased smuggling. Furthermore, policy changes have exacerbated
workload demands by increasing pressure to expedite the processing of
passengers and cargo into the United States.
The workload has been directly affected by the increase in
international trade and travel between fiscal years 1990 and 1995.
Overall, the volume of exports and imports rose 45 percent and 52
percent, respectively, while agricultural exports and imports
increased 35 percent and 31 percent, respectively. Moreover, the
number of international passengers traveling to the United States
increased almost 50 percent, reaching 55 million passengers in fiscal
year 1995.
Furthermore, increases in the number of ports of entry, as well as
increased risk at existing ports, have expanded APHIS' workload.
Along the Mexican border alone, six new border stations were approved
between 1988 and 1993, while several other major facilities are
scheduled for expansion. According to APHIS officials, each new port
of entry requires at least five inspectors. Along the U.S.-Canadian
border, changes in risks associated with passengers and cargo have
created the need for increased inspections. APHIS staff at the
Blaine, Washington, port told us that increased risks were
responsible for an increase from 4 inspectors in 1990 to 18 in 1996.
In addition to conducting inspections, inspectors are responsible for
reviewing and issuing certificates for agricultural exports, working
on temporary assignments away from their normal work location, and
performing other duties, such as preventing smuggling and fumigating
cargo. As exports increase, inspectors have had to issue and review
a growing number of certificates for U.S. exports.\4 Temporary duty
assignments range from domestic emergency eradication of pests and
diseases and foreign preclearance activities to meetings and
training. Studies in California and Florida have found that the
smuggling of agricultural products into the United States has grown
and presents a serious pest risk.\5 As a result of increased
smuggling activity across the Canadian and Mexican borders, APHIS
inspectors are performing antismuggling activities, such as working
on investigations and surveillance of markets and border areas.
Along with the greater inspection workload, inspectors face
increasing pressure to expedite the flow of goods and people across
U.S. borders. Responding to the growing importance of trade to the
national economy and to recent trade agreements, APHIS has taken an
active role in facilitating trade. Towards this end, APHIS and its
FIS partners have adopted new customer service standards to move the
increasing import and passenger volume through ports of entry within
specific periods. For passengers, these standards call upon the
agencies to clear international airline passengers within 45 minutes
of arrival. Similarly, APHIS has adopted standards to schedule
inspections of perishable cargo within 3 hours of being notified of
its arrival. APHIS acknowledges the conflict between enforcement
responsibilities and trade facilitation and is seeking an appropriate
balance as guidance for the inspection program.
--------------------
\4 APHIS is responsible for issuing certificates for agricultural
exports. The certificates, known as phytosanitary certificates,
attest to the fact that the goods meet the health and safety
requirements of the importing country.
\5 These studies are (1) "Report of the Governor's Exotic Pest
Eradication Task Force," submitted to Governor Pete Wilson, State of
California, Mar. 1996; and (2) "Final Report on Cooperative Efforts
to Manage Pest Risk in South Florida (draft)," prepared by the
Florida Department of Agriculture and Consumer Services and the U.S.
Department of Agriculture, Aug. 1996.
APHIS CHANGED ITS INSPECTION
PROGRAM TO ADDRESS THE NEW
CHALLENGES
------------------------------------------------------------ Letter :4
APHIS made a number of changes to its inspection program to respond
to the demands of its growing workload. It shifted funds and staff
away from other programs to the inspection program, broadened the
range of inspection techniques, and stepped up efforts to coordinate
with the other FIS agencies. In addition, to help measure the
effectiveness of its inspections and to form a basis for making
further improvements, APHIS recently initiated an effort to compare
the rate at which restricted items are entering the United States,
and the risks associated with those items, with the inspection rates
at individual ports of entry. This effort is designed to determine
if the current inspection program is adequately addressing the risks
of harmful pests and disease entering the country and to identify
which of the country's ports of entry are most vulnerable to such
risks.
APHIS INCREASED RESOURCES
FOR INSPECTION ACTIVITIES
---------------------------------------------------------- Letter :4.1
APHIS has been shifting more funds into inspection activities since
fiscal year 1990. Through fiscal year 1996, the budget for AQI
activities rose 78 percent to $151.9 million, while APHIS' overall
funding rose 20 percent. To provide this increased funding, APHIS
reduced its spending for several other programs, such as the
brucellosis eradication program, which fell from $59 million in 1990
to $23 million in 1996. The 1990 and 1996 farm bills also authorized
the collection of and expanded access to user fees for inspections.
User fees have become the principal revenue source for the AQI
program, accounting for about $127 million of program revenues in
fiscal year 1996. (See app. II for more detail on funding and
staffing for fiscal years 1990-96.)
Since 1990, APHIS has raised AQI staffing levels about 44
percent--from 1,785 to 2,570 positions. The agency shifted positions
from other programs to meet the increased workload. In addition, as
a result of the 1996 farm bill's provisions allowing greater access
to user fee revenues and removing a staff ceiling, APHIS is in the
process of hiring about 200 new inspectors.
APHIS EXPANDED USE OF
ALTERNATIVE INSPECTION
PRACTICES AND INCREASED
INTERAGENCY COORDINATION
---------------------------------------------------------- Letter :4.2
APHIS has taken several steps to make better use of its inspection
resources. To supplement the normal practice of performing visual
inspections of selected cargo and baggage, APHIS has significantly
expanded the use of alternative inspection practices, such as
detector dogs and x-ray equipment. APHIS increased the number of
detector dog teams from 12 in 1989 to 48 in 1996. Inspectors are
also periodically using inspection blitzes--highly intensive
inspections of baggage or cargo--to augment their visual inspection
of selected items. To improve its ability to select passengers for
inspection, APHIS is refining the list of risk characteristics that
inspectors use in selecting passenger bags for inspection. Roving
inspectors currently use these selection characteristics in airports
to make referrals for agricultural inspection. The agency is also
studying opportunities to use roving inspectors at land border ports.
Finally, APHIS is funding research on new x-ray technology that will
identify air passengers' baggage containing restricted items.
APHIS has also attempted to reduce the workload at entry ports by (1)
inspecting passengers and products in the country of origin or (2)
allowing lower-risk products to enter with less intensive scrutiny.
Under the first effort, APHIS has staff oversee or conduct
inspections to preclear products and passenger baggage in the country
of origin so that inspectors at receiving U.S. ports primarily
monitor these products or baggage. APHIS' International Services
unit now operates cargo preclearance inspections in 29 countries and
limited passenger preclearance programs in 2 countries. In addition,
APHIS initiated a cargo release program along the Mexican border to
reduce inspections of high-volume, low-risk commodities\6 and allow
the products to enter with less intensive scrutiny. For example,
according to APHIS, the port of entry with the highest volume of
agricultural imports from Mexico--Nogales, Arizona--had about 75
percent of its shipments in 1995 in the cargo release program.
In addition to taking steps aimed at improving the use of its own
resources, APHIS is working with the other FIS agencies--Customs and
INS--to improve coordination. For example, several work units are
working with the FIS agencies, through Port Quality Improvement
Committees, to improve port operations and are cross-training FIS
staff to educate them on APHIS' inspection needs. In 1996, the FIS
agencies and the Department of State issued a report with
recommendations for improving screening of passengers as they arrive
at U.S. borders. In 1996, APHIS began providing computer equipment
to 33 maritime ports and 26 airports to enable them to link up with
information in Custom's databases on cargo and prior violations.\7
APHIS is trying to improve the linkage with the cargo manifest
database to overcome early problems in obtaining and reviewing cargo
information. For example, APHIS is developing its Automated
Targeting System, which will automatically scan Custom's cargo
manifest database to identify shipments for inspection.
--------------------
\6 The Border Cargo Release program established different inspection
procedures for high-volume, low-risk commodities entering from
Mexico. APHIS defines high-volume commodities as more than 1,000
entries per year and low-risk commodities as those with no more than
one harmful pest found in a 1-year period or no more than three
harmful pests found over a 6-year period. Examples of high-volume,
low-risk commodities are tomatoes, cucumbers, squash, and bell
peppers.
\7 The Automated Commercial System provides cargo manifests for
arriving shipments. The Treasury Enforcement Communications System
contains a list of people and vehicles with prior violations.
APHIS IMPLEMENTED PROGRAM TO
DETERMINE PEST AND DISEASE
RISKS AT PORTS
---------------------------------------------------------- Letter :4.3
In October 1996, APHIS began implementing the AQI Results Monitoring
Program, which is intended to measure the effectiveness of its
inspections nationwide and provide information on which ports of
entry pose the highest risk of having harmful pests and diseases
enter the country. At each port, the program will also identify
risks of harmful pest and disease entry associated with various
commodities, their country of origin, and their means of entry.
APHIS expects the program to be in place at most ports of entry by
September 1997.
The results monitoring program uses random surveys of cargo and
passengers entering the United States to estimate the rates at which
restricted items are entering the country and the risks of harmful
pests and diseases associated with those items. The program allows
APHIS to determine whether the number of inspections performed at a
given location for a given commodity adequately address the risk
posed. The program replaces the traditional measure of inspection
performance, the quantity of material intercepted, with new
performance indicators related to risks associated with commodities
entering the country. This approach will enable APHIS to modify its
inspection program to reduce the threat of harmful pests while not
unduly restricting trade.
INSPECTION PROGRAM HAS NOT KEPT
PACE WITH INCREASING DEMANDS
------------------------------------------------------------ Letter :5
Despite the changes in resources and activities, APHIS' inspection
program at most of the ports we visited has not kept pace with the
increasing pressure from its growing workload and mission. Heavy
workloads have often led APHIS inspectors to shortcut cargo
inspection procedures, thereby jeopardizing the quality of the
inspections conducted. Furthermore, APHIS has little assurance that
it is deploying its limited inspection resources efficiently and
effectively because of weaknesses in the staffing models it uses for
making such decisions.
QUESTIONABLE INSPECTION
PRACTICES
---------------------------------------------------------- Letter :5.1
APHIS' inspectors are to follow certain procedures when examining
goods and passengers entering the United States in order to minimize
the possibility of pest infestation and disease.\8 However, at 11 of
the 12 ports that we examined, inspectors were not always
implementing these procedures for the (1) number of inspections that
should be conducted, (2) number of samples of a shipment that should
be examined, or (3) manner in which a sample should be selected.
According to regional APHIS officials and internal studies, these
types of problems may not be limited to the sites we visited.
At 11 ports of entry we visited, including the 3 busiest ports in the
United States, inspectors said that they are unable to examine enough
vehicles or cargo containers to consider their inspection to be
representative of the movement of goods, to control the flow of
restricted goods, and to minimize risk of pests and disease. Several
of these inspectors said that they were not confident that the
frequency of inspections was adequate to manage the risks. For
example:
-- At the Mexican border crossing with the heaviest passenger
vehicle volume in the country, a supervisory inspector said the
staff were inspecting less than 0.1 percent of the passenger
vehicular traffic because of the high volume of traffic and the
low number of referrals from FIS officials who initially screen
the vehicles. APHIS officials have set a target of inspecting
about 2 percent of all passenger vehicles.
-- Because of staffing shortages, one work unit along the
U.S.-Mexican border can provide inspector coverage of a busy
pedestrian crossing for only 8 of the 18 hours of port
operations.
-- As a result of a low staffing level and the numerous other
duties that must be carried out at a busy U.S.-Canadian border
location, an APHIS manager told us that inspectors cannot
maintain a regular presence at any of the four border crossings
at the port. The inspectors are available to inspect only when
the other FIS agencies make referrals to APHIS.
Problems in conducting a sufficient number of inspections were not
limited to the locations we visited. An APHIS headquarters official
told us the agency does not conduct any inspections at 46 northern
and 6 southern ports of entry. Instead, the agency relies on the
other FIS agencies to perform agricultural inspections, when needed,
at these low-volume ports, although the risks are unknown.
In addition, even for the inspections that they conduct, inspectors
do not always examine the number of samples suggested by the
guidance. For example, inspectors at two ports of entry told us that
they were unable to inspect a large enough sample in a given cargo
shipment to meet APHIS' inspection guidance. More specifically,
during peak season at one high-volume port along the southern border,
inspectors usually inspected one box from each shipment selected for
inspection, or less than 0.5 percent of the shipment. This is far
less than the 2-percent sample recommended in APHIS' guidance. At
another port--the second largest in the country--inspectors curtailed
their inspections of cut flowers, which are considered a high-risk
cargo. The APHIS port director said that inspectors are able to
conduct only cursory inspections during high-volume periods because
the flowers are perishable and the cut flower industry has
continually pressured both political representatives and APHIS to
have inspections performed more quickly.
Finally, in contrast to recommended inspection procedures, APHIS
inspectors do not always select samples in a manner that ensures that
the samples are representative of the shipment being inspected.
APHIS' guidance emphasizes the importance of selecting representative
samples and specifically cautions against "tailgate
inspections"--inspections of goods that are stored near openings and
that may not be representative.\9 A random survey of refrigerated
cargo containers in Miami, conducted by APHIS and the state of
Florida, documented the pitfalls of such inspections. The survey
found that less than 40 percent of the pests discovered in the survey
were located near the container opening.\10 Despite the limitations
associated with tailgate inspections, inspectors at five ports said
they routinely use them in inspecting cargo containers. This
practice extends beyond the ports we visited: A 1996 APHIS report on
cargo inspection monitoring noted that many ports have resorted to
tailgate inspections because of heavy trade volume.\11
In addition to tailgate inspections, we found one port using another
sampling practice that also reduced assurance that the samples
examined represented the entire shipment. In Miami, the second
busiest port in the country, we observed inspectors allowing import
brokers of cut flowers to select samples for inspection. With this
practice, brokers could select samples that are likely to pass
inspection, which reduces the credibility of the inspection.
--------------------
\8 App. III discusses APHIS' inspection procedures.
\9 Sampling rates vary widely, depending on the commodity, any
treatment of the commodity to kill pests, and the source country.
The inspection rates differ, for example, for pears from Chile and
from New Zealand. As a result, the standard for a "representative"
inspection sample varies. The inspection manual for fresh fruits and
vegetables advises inspectors to use 2 percent as a standard sampling
rate for determining the amount of an inspection sample in a
particular shipment and allows adjustments on the basis of experience
with the shipper and the size of the shipment.
\10 "Final Report on Cooperative Efforts to Manage Pest Risk in South
Florida (draft)," prepared by the Florida Department of Agriculture
and Consumer Services and the U.S. Department of Agriculture, Aug.
1996.
\11 "Agricultural Quarantine Inspection Results Monitoring Project,
Cargo Survey Implementation Package." Aug. 23, 1996.
INSPECTION PROGRAM LACKS A
SOUND RESOURCE ALLOCATION
METHOD
---------------------------------------------------------- Letter :5.2
The staffing models that APHIS uses to allocate its inspection
resources have several weaknesses that undermine the agency's ability
to ensure that inspectors are deployed to areas that pose the highest
risk of entry of pests or disease. The weaknesses fall in three
areas. First, the staffing models rely on inaccurate inspection
workload data, which could skew the models' analyses. Second, the
models do not contain risk assessment information similar to that
produced by the results monitoring program because APHIS has not
determined how to include risk data in the model's design. This
limitation restricts APHIS' ability to place inspection resources at
the ports of entry with the highest risks of pest and disease
introduction. Finally, the models are not used to allocate
inspection resources on a national basis. Rather, they are used only
to allocate resources within APHIS regions.
APHIS' staffing models are intended to help determine the number of
inspectors that should be stationed at various locations across the
country. There are four separate models for calculating staffing
needs at airports, land border crossings, maritime ports, and plant
inspection stations. Each of the models calculates staffing needs
by, in essence, multiplying various measures of workload activity
(such as number of inspections, number of vehicle arrivals, and
number of pest interceptions) by the time it takes to complete these
activities and converting that product into an estimate of the number
of inspectors needed.
The accuracy of the workload data used in the models is key to
ensuring that projected staffing needs are also accurate. However,
APHIS has little assurance that the data are accurate. The
inspection workload data used in the model generally comes from
APHIS' Workload Accomplishment Data System (WADS). APHIS officials
at all levels of the inspection program questioned the accuracy of
the data in this system because of inconsistencies in the way the
data were compiled at ports and reported through regional offices to
APHIS headquarters. APHIS inspectors told us that some data they
submitted, such as information on endangered species, was
inaccurately reported or did not appear in the national WADS
summaries. Officials in one region said some data were omitted
because they were not useful at the national level, while inaccurate
data may be due to data entry error. Furthermore, workload
statistics were often estimates of activity rather than real-time
information. Finally, we found that another source of inaccurate
data in WADS can be traced to the poor quality of inspections. If,
for example, inspectors are reporting the results of tailgate
inspections rather than inspections of representative samples of
cargo, WADS data on the number of interceptions could be misleading.
A second weakness with the current staffing models is that they do
not take into consideration variations in the risks of harmful pests
and disease entering the country. These risks can vary by several
factors, such as the commodity, country of origin, port of entry and
means of entry. The results monitoring program may be able to
provide this type of analyses. However, APHIS officials have not yet
determined how to incorporate this information into the models.
Furthermore, there are some concerns about the accuracy of the
results monitoring program because it too is based, in part, upon
information from the WADS.
Finally, the potential benefits of using the staffing models are
limited because they are not used to allocate inspection resources on
a national level. APHIS has instructed its regions and ports to use
the staffing models to help allocate staff at the regional and port
levels. However, regional officials at two of the four regions told
us that they use the staffing models primarily for budget
development, not for allocating staff among the ports within their
regions.
CONCLUSIONS
------------------------------------------------------------ Letter :6
APHIS faces a difficult mission--to ensure that tons of cargo and
millions of passengers entering the United States do not bring in
harmful pests or diseases. Its mission will only become more
difficult as the volume of trade increases and the pressure to
facilitate trade through expedited inspections becomes greater.
In the ports we visited--which included the country's three busiest
ports of entry--APHIS inspectors are struggling to meet these
challenging work demands. Unfortunately, these demands have
sometimes resulted in shortcutting inspection procedures, such as
performing tailgate inspections and allowing brokers to choose the
samples for inspection. In turn, these shortcuts have diminished the
quality of inspections and reduced assurance that an APHIS-inspected
shipment entering the United States contains no harmful pests or
diseases.
In view of APHIS' increasing workload, it is critical that the agency
be able to allocate its limited inspection resources to the ports of
entry with the highest risks of pest and disease introduction. APHIS
currently does not have the management tools to do so. Specifically,
the workload information in the WADS is key to staffing allocation
decisions. However, APHIS officials question the accuracy of the
WADS information, noting, among other things, that the system does
not include all needed workload information and some of the
information that it does include are estimates that may be
inaccurate.
Beyond problems with the workload information, APHIS' current
staffing models do not factor into consideration variations by
commodity, country of origin, and other factors for the risk of pest
or disease introduction. APHIS' results monitoring program will
provide important information on risk. However, APHIS officials have
not yet determined how this information will be integrated into their
staffing models or staffing decisions.
Finally, APHIS has not made a commitment to using its staffing models
to allocate inspection resources from a national perspective.
Rather, it plans to examine resource allocations only within regions.
As a result, APHIS may lack the flexibility for effectively shifting
its resources to target them to the highest risks.
RECOMMENDATIONS
------------------------------------------------------------ Letter :7
To better ensure that APHIS identifies harmful pests and diseases
through the inspections that it conducts, the Secretary of
Agriculture should direct the Administrator of APHIS to issue
guidance that emphasizes the need for APHIS inspectors to adhere to
minimum inspection standards in terms of the methods used to select
samples from shipments chosen for inspection. We recognize that
meeting these minimum standards may result in fewer inspections, but
we believe that a smaller number of reliable inspections is
preferable to a larger number of inspections that do not comply with
inspection guidelines.
To strengthen APHIS' ability to allocate its inspection resources
more effectively and efficiently, we recommend that the Secretary of
Agriculture direct the Administrator of APHIS to develop and
implement plans that will
-- improve the reliability of data in the WADS;
-- integrate a risk assessment factor, developed on the basis of
the results monitoring program, into its staffing allocation
process; and
-- position APHIS to evaluate inspection resources in terms of
national rather than regional needs.
AGENCY COMMENTS
------------------------------------------------------------ Letter :8
We provided a draft of this report to APHIS for its review and
comment. Appendix IV contains APHIS' written response to our draft
report. APHIS agreed that the issues identified in each of our four
recommendations needed to be addressed and indicated actions under
way to address them. For example, to ensure that APHIS inspectors
adhere to minimum inspection standards, APHIS said that it will
provide guidance to reinforce the importance of using the best
possible procedures for preventing pests from becoming established
and will ensure that the inspection standards are consistent with the
risk determinations conducted through the results monitoring
activity. To improve the data in the WADS, APHIS plans to ensure
that inspection program policies are consistently applied nationwide
and that the data used in decisionmaking are accurate and reliable.
To integrate a risk assessment factor into its staffing process,
APHIS is developing a prototype model of staffing guidelines to
integrate data from its results monitoring and risk assessments. To
evaluate inspection resources in terms of national needs, APHIS is
consolidating its four PPQ regions into two and believes that this
will contribute significantly to achieving national consistency in
all APHIS programs.
SCOPE AND METHODOLOGY
------------------------------------------------------------ Letter :9
To assess APHIS' inspection program, we reviewed various studies of
pest exclusion efforts and interviewed officials at APHIS
headquarters, two regional offices, and work units at 12 ports of
entry around the country. At work units, we observed actual
inspections; obtained data on workload, operating procedures, and
mission; and discussed recent developments and changes to the
inspection program. Ports we visited were on the northern and
southern borders of the United States and included international
airports, seaports, rail yards, and mail stations. We performed our
review from May 1996 through March 1997 in accordance with generally
accepted government auditing standards. Appendix I provides details
on our objectives, scope, and methodology.
---------------------------------------------------------- Letter :9.1
This report is being sent to congressional committees responsible for
U.S. agriculture; the Secretaries of Agriculture and the Treasury;
the U.S. Attorney General; the Administrator, APHIS; the
Commissioners, U.S. Customs Service and Immigration and
Naturalization Service; and other interested parties. We will also
make copies available to others on request.
Please contact me at (202) 512-5138 if you or your staff have any
questions. Major contributors to this report are listed in appendix
V.
Robert A. Robinson
Director, Food and
Agriculture Issues
List of Recipients
The Honorable Richard G. Lugar
Chairman
The Honorable Tom Harkin
Ranking Minority Member
Committee on Agriculture, Nutrition,
and Forestry
United States Senate
The Honorable Ted Stevens
Chairman
The Honorable Robert C. Byrd
Ranking Minority Member
Committee on Appropriations
United States Senate
The Honorable Robert F. (Bob) Smith
Chairman
The Honorable Charles W. Stenholm
Ranking Minority Member
Committee on Agriculture
House of Representatives
The Honorable Bob Livingston
Chairman
The Honorable David R. Obey
Ranking Minority Member
Committee on Appropriations
House of Representatives
The Honorable Thad Cochran
Chairman
The Honorable Dale Bumpers
Ranking Minority Member
Subcommittee on Agriculture, Rural Development,
FDA, and Related Agencies
Committee on Appropriations
United States Senate
The Honorable Joe Skeen
Chairman
The Honorable Marcy Kaptur
Ranking Minority Member
Subcommittee on Agriculture, Rural Development,
FDA, and Related Agencies
Committee on Appropriations
House of Representatives
OBJECTIVES, SCOPE, AND METHODOLOGY
=========================================================== Appendix I
The objective of our review was to assess the effectiveness of the
U.S. Department of Agriculture's Animal and Plant Health Inspection
Service (APHIS) in minimizing the risks to agriculture from pests and
diseases entering the United States. Specifically, we (1) identified
recent developments that challenge the Agricultural Quarantine and
Inspection (AQI) program's resources and ability to carry out its
mission, (2) reviewed APHIS' efforts to cope with these developments,
and (3) reviewed the effectiveness of the inspection program in
keeping pace with workload changes. We conducted our review at APHIS
headquarters, two regional offices, and work units at 12 ports of
entry located in the four APHIS regions responsible for plant
inspection programs. APHIS management officials guided our selection
of the ports we visited in order to ensure that these locations were
representative of the challenges and problems faced by APHIS
inspectors at all 172 staffed ports of entry. Ports we visited were
on the northern and southern borders of the United States and
included international airports, seaports, rail yards, and mail
stations. Table I.1 lists the work units that we visited.
Table I.1
Animal and Plant Health Inspection
Service Ports of Entry Visited
APHIS region and port of entry Type of entry
---------------------------------- ----------------------------------
Western region
----------------------------------------------------------------------
Blaine, Washington Air, land, maritime, rail
San Francisco, California Air, mail, maritime
Oakland, California Air, mail, maritime
Los Angeles, California Air, mail
San Diego, California Air, mail
Nogales, Arizona Air, land, rail
Central region
----------------------------------------------------------------------
Brownsville, Texas Air, land, maritime, rail
Pharr, Texas Air, land
Laredo, Texas Air, land, rail
Northeastern region
----------------------------------------------------------------------
Buffalo, New York Air, land, mail, maritime, rail
New York, New York\a Air, maritime, mail
Southeastern region
----------------------------------------------------------------------
Miami, Florida Air, maritime, mail
----------------------------------------------------------------------
\a In New York city, we visited work units at John Fitzgerald Kennedy
International Airport (Jamaica, New York) and Brooklyn, New York.
To identify recent developments affecting the inspection program's
workload and mission, we reviewed statistical reports on agricultural
imports and exports and international air passenger arrivals from
1990 through 1995. We also reviewed reports prepared by APHIS and
state agriculture agencies on trends in workload volume and changes
in pest risk. APHIS provided data on the cost of foreign pest and
disease infestations to U.S. agriculture, but we did not verify the
accuracy of the data or the methodology used. At the ports of entry
we visited, we discussed changes in the volume and complexity of the
port's workload and analyzed data on the number of phytosanitary
export certificates issued by the inspection staff. We also
contacted APHIS' regulatory enforcement officials who analyze trends
in smuggling agricultural goods into the United States. We
identified increases in ports of entry by reviewing reports from the
General Services Administration (GSA) and discussing these increases
with GSA headquarters officials. To assess changes in APHIS'
mission, we reviewed APHIS' mission statements, internal reports, and
organizational initiatives. At all locations, we discussed with
officials the impact of recent trade agreements or other developments
on APHIS' workload and mission.
To review the changes APHIS has made to cope with recent
developments, we identified changes in resource allocations to the
AQI program by reviewing APHIS' budget and staffing documents for
1990 through 1996 and reports on user fees. We discussed with APHIS
officials (1) shifts in staffing and funding, (2) programs used to
reduce the inspection workload at U.S. ports of entry, (3) program
priorities, (4) the implementation and use of the results monitoring
program and staffing models, and (5) inspection coordination with the
other Federal Inspection Service (FIS) agencies. We analyzed data on
inspection techniques and technologies and discussed the use of
various techniques with APHIS officials at all the locations we
visited. At several ports of entry, we observed the use of x-ray
equipment and detector dogs in inspections. We discussed border
cargo release programs with APHIS field staff at U.S.-Mexican border
ports we visited and preclearance programs with officials from the
APHIS International Services unit.
To evaluate the overall effectiveness of the inspection program, we
reviewed inspection manuals and discussed policies, procedures, and
requirements with APHIS headquarters officials. At the ports of
entry we visited, we discussed with port directors, supervisors, and
inspectors how inspections are conducted and how they could be
improved. We also reviewed studies and documents on various APHIS
and FIS initiatives aimed at improving inspections and discussed
these initiatives with officials at the locations we visited.
Additionally, we observed inspections for various modes of entry into
the United States--airport cargo and arriving international air
passengers; pedestrians, vehicle and bus passengers, and truck cargo
at land border crossings; maritime cargo and ships at seaports; rail
cars and rail passengers; and international mail stations.
We performed our review from May 1996 through March 1997 in
accordance with generally accepted government auditing standards.
INSPECTION PROGRAM RESOURCES
========================================================== Appendix II
APHIS significantly increased its funding and staffing for the AQI
program in the 1990s in an effort to keep pace with growing workload
demands. APHIS' funding for the program rose by 78 percent from
fiscal year 1990 through 1996. Figure II.1 lists the funding
allocations APHIS made for the inspection program for fiscal years
1990-96.
Figure II.l: AQI Funding,
Fiscal Years 1990-1996
(See figure in printed
edition.)
Source: APHIS.
Inspection staffing levels rose about 44 percent from fiscal year
1990 through 1996. Figure II.2 lists the authorized staffing levels
for inspection activities.
Figure II.2: Authorized AQI
Staffing Levels, Fiscal Years
1990-96
(See figure in printed
edition.)
Source: APHIS.
COMPONENTS OF THE INSPECTION
PROGRAM
========================================================= Appendix III
The AQI program is APHIS' first line of defense in protecting U.S.
agriculture from harmful pests and diseases. To implement the
inspection program, APHIS has prepared manuals to guide inspections
of commercial shipments and passengers and developed an array of
inspection techniques. These manuals show that a reliable and
credible cargo inspection program requires an adequate number of
inspections and the selection of individual inspection samples that
are representative of whole shipments.
INSPECTION PROCEDURES FOR
COMMERCIAL SHIPMENTS
----------------------------------------------------- Appendix III:0.1
Procedures for inspecting commercial shipments vary according to such
factors as the type of product, risk levels associated with the
product, and country of origin. Detecting the presence of plant
pests or contaminants in a commercial shipment is predicated on
inspecting a sample of the shipment. The procedures include guidance
for ensuring that the sample is representative of the whole shipment.
INSPECTION PROCEDURES FOR
PEDESTRIANS, PASSENGERS, AND
PASSENGER VEHICLES
----------------------------------------------------- Appendix III:0.2
Inspection procedures for pedestrians, passengers, and passenger
vehicles follow a two-stage process, primary and secondary
inspection. Primary inspection involves screening passengers, their
baggage, and vehicles by questioning the passengers, reviewing their
written declaration, and visually observing for referral for further
examination. APHIS is refining the characteristics used in the
screening process to select passengers and baggage for secondary
inspection. Secondary inspection involves a more detailed
questioning of the passenger and a visual examination of baggage
contents, if necessary. To detect pests and contraband, AQI staff
use a range of strategies, such as screening, detector dogs, and
x-rays. For airline flights, APHIS has also developed a list of
low-, medium-, and high-risk countries of origin to help guide the
selection process in the primary inspection area.
(See figure in printed edition.)Appendix IV
COMMENTS FROM THE ANIMAL AND PLANT
HEALTH INSPECTION SERVICE
========================================================= Appendix III
(See figure in printed edition.)
(See figure in printed edition.)
MAJOR CONTRIBUTORS TO THIS REPORT
=========================================================== Appendix V
Ron E. Wood, Assistant Director
Dennis Richards
Mary K. Colgrove-Stone
Michael J. Rahl
Jonathan M. Silverman
*** End of document. ***