OIE-Office Internationale des Epizooties

OIE, an organization headquartered in Paris, France, that has 166 member countries, including the United States.  OIE classifies member countries or certain zones within these countries as

being disease-free if they meet certain criteria detailed in the OIE International Animal Health Code. The international community generally places a high value on products from countries that OIE classifies as disease-free without the use of vaccination. Such countries can export both live animals and animal products easily to other countries. In contrast, countries that are classified as disease-free but who use vaccines are restricted in their ability to trade. Most countries that are foot and mouth

disease (FMD) - free without vaccination resort to a “stamping out,” or cull and burn, process to eradicate the disease.  The OIE is also known as the World Animal Health Organization.

PPQ-Plant Protection and Quarantine

USDA-United States Department of Agriculture

            USDA has primary responsibility for protecting the agriculture sector. 

• Public Health Security and Bioterrorism Preparedness and Response Act of 2002 (the “Bioterrorism Act of 2002”), USDA and HHS gained authority to regulate agents and toxins which pose a threat to c health, animals, plants, and animal and plant products.

• Veterinary Services remain under USDA. Pg 14

HSPD-9-The most important of these directives in relation to agriculture is HSPD-9, which was released in January 2004. The directive establishes a national policy to defend the agriculture and food system against terrorist attacks, major disasters, and other emergencies. Specifically, HSPD-9 outlines goals and assigns lead and supporting roles to agencies to achieve these goals. (See fig. 4.) There are seven categories outlined in HSPD-9: awareness and warning; vulnerability assessments; mitigation strategies; response planning and recovery; outreach and professional development; research and development; and budget.  Pg 17

HSPD-9 assigns lead tasks to USDA and HHS for agriculture and  food matters, respectively.  Pg 18

HSPD-9- improving existing recovery systems that will stabilize agriculture production and rapidly remove and dispose of contaminated animals, plants, and food products, and decontaminate premises following an Agroterrorism attack. Pg 18

HSPD-7 defines USDA and HHS as “sector-specific agencies” with responsibilities for securing the agriculture and food sectors. These agencies, in coordination with DHS, are tasked with collaborating with federal, local, and state governments, as well as private industry and other stakeholders to help protect their respective critical infrastructure sectors, including agriculture. Among other things, HSPD-7 directs DHS to establish systems, mechanisms, and procedures to share homeland security information relevant to threats and vulnerabilities in critical infrastructures with other federal departments and agencies, state and local governments, and private industry in a timely manner. Pg 20

HSPD-8 sets out a national preparedness goal for all hazards, including agriculture. The directive calls on federal agencies to establish readiness priorities, to deliver federal assistance to state and local governments effectively and expeditiously, and to ensure that first responders are prepared to respond to major events. The directive outlines criteria for federal preparedness assistance to the states based on assessments of population concentrations, critical infrastructure, and other risk factors such as terrorism threats. Pg 20

HSPD-5- HSPD-5 directs federal agencies to require that states become compliant with the National Incident Management System in fiscal year 2005 as a condition for receiving federal grant aid for emergency preparedness. To support this directive, DHS has established a number of minimum requirements for states to implement during fiscal year 2005.

Holes in the system-your talking points

Analyzing the Data

• Neither USDA nor DHS has analyzed the inspections and interceptions data to identify trends and potential areas for improvement, but headquarters officials at both agencies told us they would analyze the data in early 2005.

Vaccines

• USDA can not deploy animal vaccines within 24 hours of an outbreak as called by HSPD-9.  USDA only has ONE vaccine, for foot and mouth.
• USDA prefers to immediately slaughter animals rather than vaccinate them. Pg. 6

USDA has very few supplies of vaccines. In place of vaccination, USDA generally prefers to immediately slaughter diseased animals because international rules that the United States and other countries have agreed to abide by are designed to prevent trade in infected or vaccinated animals. Pg 36

• All vaccine is in concentrated form and must go to UK for bottling and testing, then shipped to the US for dispersion.  Pg. 6 (So much for rapid, eh?)
• Only vaccines that are stockpiled in the United States—vaccines for FMD—cannot be rapidly deployed because they are not stored in a “ready-to-use” state. Although HSPD-9 states that vaccines should be capable of deployment within 24 hours, USDA’s stockpiles are concentrates that require additives to become a vaccine. Because the additive for the FMD vaccine is manufactured in the United Kingdom, USDA must first ship the stock there for bottling and subsequent testing. It can take up to 3 weeks to transform the stock into a vaccine once the concentrate arrives in the United Kingdom.
• When deciding if a vaccine should be used this is the USDA protocol:  complex and takes into consideration many variables, such as the location of outbreaks in relation to susceptible animal populations, as well as trade concerns and restrictions. Pg 7 

DHS/USDA Inspections

• USDA transferred the agricultural inspectors to DHS in 2003: resulting in fewer inspections.
• The first line of defense against the entry of foreign animal and plant diseases—have declined over the past 2 years at a time when imports have increased. Since the transfer of most USDA agricultural inspectors to DHS, data show a decline in the number of agricultural inspections at ports of entry nationwide from 40.9 million in fiscal year 2002, when USDA was fully responsible for agricultural inspections, to 37.5 million in fiscal year 2004, when DHS had primary responsibility.

• The act also authorized the transfer of no more than 3,200 inspector positions from USDA’s Plant Protection and Quarantine Unit to DHS.
• In fiscal year 2002, there were 40.9 million agricultural inspections at ports of entry; in fiscal year 2003, the year when USDA inspectors transferred to DHS, 35.0 million inspections were conducted;

and in fiscal year 2004, there were 37.5 million agricultural inspections. USDA data also show that inspections have decreased at certain types of ports and by certain modes of entry nationwide, such as passenger baggage and cargo.  Pg 42

• DHS agricultural inspectors told us they had cut their inspections in late 2004 by more than 50 percent, from an average of about 1,200 cargo containers per week to 500 per week. Pg 41
• USDA data show that inspections at land border crossings increased from 21.2 million agricultural inspections in fiscal year 2002 to 22.5 million such inspections in FY 2004  Pg 42

• USDA data also indicate a decline in the number of agricultural interceptions—seizures of prohibited plant and animal products, and agricultural pests—at ports of entry nationwide since the transfer of

inspectors to DHS. Interceptions dropped from 1.8 million in fiscal year 2002, when USDA had sole responsibility for inspections, to 1.6 million in 2004, when DHS had primary responsibility for agriculture inspections. However, in 2003, a transitional year, interceptions totaled 1.8 million.

Interceptions of reportable pests in particular have declined each fiscal year—from 77,886 in 2002, to 72,988 in 2003, and to 54,109 in 2004.

• In March 2003, USDA transferred 1,517 full-time inspectors, according to DHS officials.

Recently, DHS has been able to hire new agricultural inspectors, but numerous departures left DHS with 1,446 agricultural inspectors and 426 vacancies as of mid-October 2004.  DHS told us that the agency intends to hire more than 500 additional agricultural inspectors by February 2006. Pg 43

• Under the memorandum of agreement between the two agencies, USDA is responsible for  providing risk analysis guidance to DHS, and DHS is responsible for targeting high-risk agricultural passenger and cargo shipments for inspections, using USDA data.
• DHS agricultural inspectors do not always receive timely information about high-risk cargo that should be held for inspection. Pg 44
• DHS and USDA have different databases and information technology systems, including email, which has further hindered their ability to share information.

• DHS is not promptly and effectively seeking input from key stakeholders on critical national guidance documents.  Pg 7
• State and industry officials told us they did not receive draft national guidance in a timely fashion; DHS may not be providing states sufficient guidance to allocate homeland security grant funding for agriculture; and after-action reports on test exercises and real outbreaks are not routinely shared with many stakeholders who could benefit from the lessons learned. 
• DHS officials told us they plan to address this shortage by hiring more than 500 inspectors by fiscal year 2006, but also stated that the ability to hire and deploy new inspectors is impeded by the length of time needed for background checks.

• Since the transfer of most USDA Plant Protection and Quarantine (PPQ) inspectors to DHS in March 2003, government officials, reports, and data indicate that the nation may be more vulnerable to the introduction of foreign animal and plant diseases through ports of entry into the United States.

In addition, the transfer of inspectors has reduced USDA’s ability to respond to agricultural emergencies.

How Long Did You Review the Drafts/Legislation?

• Officials in key agricultural states and industry representatives told us that DHS did not give them enough time to review and comment on draft federal guidance. Pg 7
• Plan may set unrealistic expectations regarding the states’ capabilities to meet the requirements of the plan. Pg 8  (Trouble in the camp-pit your State vs. the Federal)

Concentrated Farms are MORE vulnerable to terrorism/disease

• Highly concentrated breeding and rearing practices of our livestock industry make it a vulnerable target for terrorists because diseases could spread rapidly and be very difficult to contain. Between 80 and 90 percent of grain-fed beef cattle production is concentrated in less than 5 percent of the nation’s feedlots.
• UK’s cattle fiasco caused $5 billion in economic losses with 4 million animals killed.
• “Agroterrorism can be broader and include the entire food chain, our definition does not refer to the deliberate contamination of manufactured food items.”

Government Agencies Have not even completely evaluated vulnerability assessments

• FDA and USDA are in varying stages of conducting vulnerability assessments to determine which agricultural products are most vulnerable to terrorist attacks. (In other words they don’t even know our vulnerabilities yet)  Pg.5

Funding

• DHS, USDA, and HHS have funded research to address a range of issues related to Agroterrorism. For example, DHS provided $33 million in 2004 to establish two university-based Centers of Excellence to oversee research on post-harvest food protection and on diseases that affect livestock and poultry

(In other words that $33 million you see floating around on funding goes only to 2 universities for post-harvest food protection and on disease research. i.e.-not us small farmers)

Emergency Coordinators for the “emergency”

• USDA created 16 Area and Regional Emergency Coordinator positions to help states develop individual emergency response plans and to serve as a technical resource for states, industry, and other stakeholders.
• Even if the vacancies were filled, the current number of emergency coordinators is insufficient, as each coordinator is responsible for up to 6 states on the animal health side and 27 states on the plant side.   Pg 8  ( Spread a little thin don’t you think?)
• Since 2002, USDA has created 14 Area Emergency Coordinator positions across the nation for animal health.  Wisconsin’s Animal Health Emergency Management System, the nation’s first statewide plan that parallels the National Animal Health Emergency Management System

Veterinary

• Only 26% of veterinarian graduates take a course specifically on FAD (foreign diseases).
• Many U.S. veterinarians lack training to recognize the signs of foreign animal diseases, according to a 2004 report produced for USDA. Pg 29
• To be accredited, an individual must have graduated from an accredited school of veterinary medicine, submitted an application certifying the ability to complete 16 tasks such as recognizing common breeds of livestock, completed a core orientation session, and be licensed or legally able to practice without supervision. Pg29
• APHIS’s Veterinary Services administers the National Veterinary Accreditation Program. This voluntary program certifies private veterinary practitioners to work cooperatively with federal veterinarians and state animal health officials.
• USDA officials told us that it has a cadre of certified private veterinary practitioners who partner with APHIS to report any suspected foreign animal disease cases to federal officials. These surveillance efforts are further augmented by the work of 450 specially trained foreign animal disease diagnosticians who actively search for FMD and other foreign animal diseases across the country. USDA continues to train 100 foreign animal disease diagnosticians annually.
• Veterinarians work in private practice where this skill is not required. According to the American Veterinary Medical Association, approximately 74 percent of practicing veterinarians in the United States work in private practice.  Similarly, the Association of American Veterinary Medicine

reports that only about 5,000 veterinarians work in public service,

• To maintain accreditation status under the new standards, veterinarians will have to periodically complete supplemental education requirements. These supplemental training modules will be available on-line to the entire accredited veterinarian population. Through a cooperative agreement with Iowa State University, APHIS has already initiated development of 6 supplemental training modules for the new accreditation process. These modules focus heavily on the recognition of the clinical signs of many of the most prominent foreign animal diseases and on how to respond to a potential foreign animal disease outbreak. The new program will institute a 3-year renewal period for veterinary accreditation for all veterinarians. If documented supplemental training is not completed before the 3-year renewal period expires, the accreditation status of the veterinarian will be inactivated.

• While the DOD uses on-site rapid tools the USDA is resistant to this technology. Pg. 6

Funding-

• In fiscal year 2003, USDA received approximately $495 million for homeland security activities, which included those that address Agroterrorism and other routine USDA programs. FDA received approximately $160 million in fiscal year 2003 for homeland security efforts, including protecting against Agroterrorism.
• This transfer established DHS as the primary source of much federal homeland security funding to state and local governments. In fiscal year 2005, DHS will distribute formula and discretionary grants to the states through the Homeland Security Grant Program. Pg 16
• The FY 2005 Homeland Security Grant Program combines six separate grant programs into one application. These programs are the State Homeland Security Program, the Law Enforcement Terrorism Prevention Program, the Citizen Corps Program, Emergency Management Performance Grants, the Metropolitan Medical Response System Program, and the Urban Areas Security Initiative.
• DHS, USDA, and HHS are funding research to enhance the nation’s protection against Agroterrorism. Of note, DHS is providing $33 million over 3 years to establish two university-based Centers of Excellence to oversee research into post-harvest food protection and diseases that affect livestock and poultry.
• CDC has also provided $1 million in annual funding to a university for developing a center for food security and public health that will support efforts such as online programs to educate veterinarians in foreign animal diseases.

Databases

·        Under federal law, once the President makes an official declaration of an emergency or a major disaster, DHS is authorized to direct federal agencies to support state and local efforts; coordinate relief assistance; USDA has not yet integrated the databases of the member laboratories within its own networks, nor have they integrated with HHS laboratories for diseases of common concern. As a result, USDA’s ability to look at diagnostic data from across the country, detect trends, and implement a response is limited, and HHS may not receive timely information from USDA on agricultural diseases that could spread to humans.   Pg 8  

·        The goal but not reality YET- Networks are intended to link laboratories that screen for animal, plant, and human health diseases across the nation and help to provide diagnostic surge capacity In the event of a disease outbreak. Within each network, the laboratories use standardized diagnostic protocols and procedures to ensure consistent results. Food Emergency Response Network to integrate 93 local, state, and federal laboratories for the detection of biological, chemical, and radiological agents in food.

Economic Impact of Disease in Agriculture

• The deliberate introduction of animal and plant diseases at the farm level would cause severe economic disruption given that agriculture accounts for 13 percent of the U.S. gross domestic product and 18 percent of domestic employment.  Pg10
• Food and Agriculture Sector Coordinating Council to facilitate the flow of alerts, plans, and other information between the federal and state governments and industry groups.

Disease Protocol as it is now:

• If an animal is suspected of having a disease a sample would be collected from the animal.
• Federal officials will Federal Express the sample to NVSL or Plum Island.
• USDA technicians would diagnose within 3-4 days.
• During this time all other animals in the vicinity of the sick animal would be quarantined.
• Should the USDA confirm the “presence of a disease” the affected herd and all cattle, sheep, goats, swine, and wildlife-infected or not-within a minimum 10 kilometer zone around the infected farm would be killed.  Pg 31
• If the disease were to spread beyond the initial zone, authorities would continue to quarantine and kill animals until the disease was “stamped out.”
• Yet until animals are vaccinated, USDA will have no recourse but to slaughter animals in a systematic manner to contain the spread of the disease. Pg 37

• Confirmatory testing is done for several reasons, including economics and trade relations. USDA officials told us they believe that caution should be used in spending public funds and that the particular virus and strain or type of virus must

be known before expending resources.

• Rapid diagnostic tools are designed to yield results in less than an hour and are intended to be used outside of specialized laboratories, at the site of an outbreak. Importantly, the tools can detect disease before the animal shows clinical signs of infection. Pg 32
• Decon- the person who collected the sample, can then be decontaminated using a common solution, such as acetic acid in the case of FMD,
• The mobile unit would be located just off the farm to eliminate contaminating the unit. Procedures would be the same as those for any official taking a sample from a farm suspected of having a highly contagious disease.  Pg 35