Live Animal Imports: Agencies Need Better Collaboration to Reduce the Risk of Animal-Related Diseases
GAO-11-9
Published: Nov 08, 2010. Publicly Released: Nov 08, 2010.
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Highlights
The United States legally imported more than 1 billion live animals from 2005 through 2008. With increased trade and travel, zoonotic diseases (transmitted between animals and humans) and animal diseases can emerge anywhere and spread rapidly. The importation of live animals is governed by five principal statutes and implemented by four agencies. GAO was asked to examine, among other things, (1) potential gaps in the statutory and regulatory framework governing live animal imports, if any, that may allow the introduction and spread of zoonotic and animal diseases and (2) the extent to which the agencies collaborate to meet their responsibilities, and face barriers, if any, to collaboration. GAO reviewed statutes, met with agency officials, visited ports of entry, and surveyed experts on animal imports.
The statutory and regulatory framework for live animal imports has gaps that could allow the introduction of diseases into the United States, according to the experts GAO surveyed, discussions with agency officials, and scientific studies. Specifically, (1) The Department of Health and Human Services' Centers for Disease Control and Prevention (CDC) has regulations to prevent the importation of live animals that may pose a previously identified disease risk to humans for some diseases, but gaps in its regulations may allow animals presenting other zoonotic disease risks to enter the United States. CDC has solicited comments in advance of a rulemaking to better prevent the importation of animals that pose zoonotic disease risks. (2) The Department of the Interior's Fish and Wildlife Service (FWS) has regulations to prevent imports of nonnative live animals that could become invasive. However, it has not generally emphasized preventing the introduction of disease through importation. FWS is taking some initial steps to address disease risks. For example, in January 2010, the department directed FWS to review statutory authorities and regulations to address existing problems concerning nonnative live animals and recommend tools to better prevent the introduction of new threats. In contrast, the U.S. Department of Agriculture's Animal and Plant Health Inspection Service (APHIS) has regulations to prevent importing live animals it finds may pose a disease risk to agricultural animals. In 2008, APHIS issued a long-term strategy that would broaden its oversight of live animal imports. APHIS, the Department of Homeland Security's Customs and Border Protection (CBP), CDC, and FWS have collaborated to meet their responsibilities related to live animal imports by taking actions in five areas--strategic planning, joint strategies, written procedures, leveraging resources, and sharing data. However, experts GAO surveyed and agency officials GAO interviewed identified barriers to further collaboration on live animal imports, such as different program priorities and unclear roles and responsibilities, which are inherent when multiple agencies have related responsibilities. For example, experts noted that because each of the agencies is focused on a different aspect of live animal imports, no single entity has comprehensive responsibility for the zoonotic and animal disease risks posed by live animal imports. Experts also reported the need for an entity to help the agencies overcome these barriers to collaboration. Furthermore, the agencies have largely incompatible data systems, and a completion date for CBP's planned data system, which would provide the agencies with full operational access to information on incoming shipments of live animals, has not been established. In addition, APHIS, CBP, CDC, and FWS have yet to jointly determine which data elements on live animal imports are needed in this system for them to effectively oversee these imports, according to CBP officials. As a result, it is unclear whether the data elements in the completed system will meet interagency needs. GAO recommends that the Secretaries of Agriculture, Health and Human Services, Homeland Security, and the Interior develop a strategy to address barriers to agency collaboration that may allow potentially risky imported animals into the United States and jointly determine data needs to effectively oversee imported animals. In commenting on a draft of this report, the Departments of Agriculture, Interior and Homeland Security generally agreed with GAO's findings and recommendations. The Department of Health and Human Services provided technical comments only.
Recommendations
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| Department of Agriculture | To better prevent the importation of live animals carrying zoonotic and animal diseases and improve the responsible agencies' collaboration, the Secretaries of Agriculture, Health and Human Services, Homeland Security, and the Interior should develop and implement, in coordination with the relevant federal agencies, a strategy for their collaboration in preventing the importation of animals that may be carrying zoonotic and animal diseases into the United States. This strategy should help the agencies (1) Identify and resolve differing program priorities so that the agencies can work collaboratively to ensure that live animal imports posing a risk of zoonotic and animal diseases do not enter the United States. Such efforts could include collaborative methods for prevention, such as a comprehensive risk assessment system for live animal imports. (2) Lay out individual agency roles and responsibilities for all live animal imports, including how a collaborative effort will be led. (3) Identify resources dedicated to live animal imports and leverage these resources to the extent possible to support the agencies' efforts. (4) Examine ways to systematically share data on shipments of live animal imports that are regulated by more than one agency until ACE is able to offer data-sharing capabilities to each agency. (5) Explore the need for any additional legislative or executive authority to develop and implement this strategy such as the authority to establish a coordinating entity (e.g., an interagency workgroup). |
The Department of the Interior coordinated the responses to this recommendation for the three primary agencies responsible for regulating live animal imports--Health and Human Services/Centers for Disease Control and Prevention, U.S. Department of Agriculture/Animal and Plant Health Inspection Service, and Department of the Interior/U.S. Fish and Wildlife Service--and provided a document that described the agencies' plans and actions. This document stated that the agencies are strongly committed to ensuring that live animal imports do not contribute to the introduction of diseases into the United States that can affect humans, wildlife, or agricultural animal species. Although the document described the agencies' strategy as well as actions taken in response to some of the recommendation's specific elements, it also expressed concerns about the economic and staffing resources needed to implement the strategy and key planned actions. According to the document, while collaboration among agencies provides an opportunity to share resources and maximize cost savings, many of the activities proposed, including the formation of a permanent interagency committee for coordinated management of and response to oversight concerns for live animal imports would be difficult to implement and complete unless adequate resources were made available to support activities. As noted above, the agencies took actions in response to some of the recommendation's specific elements. For example, the three agencies identified priorities by developing lists of potential pathogens of concern that are specific to each department's statutory authority and ranked these pathogens by specific agency criteria. However, the document notes that many of these pathogens cross over multiple agency concerns and states that the proposed committee would take these concerns into consideration when evaluating policy, regulations or actions specific to pathogens under discussion. In July 2015, a Department of the Interior official said the resources needed to form a permanent interagency committee to implement the agencies' strategy and other planned actions were still not available.
|
| Department of Health and Human Services | To better prevent the importation of live animals carrying zoonotic and animal diseases and improve the responsible agencies' collaboration, the Secretaries of Agriculture, Health and Human Services, Homeland Security, and the Interior should develop and implement, in coordination with the relevant federal agencies, a strategy for their collaboration in preventing the importation of animals that may be carrying zoonotic and animal diseases into the United States. This strategy should help the agencies (1) Identify and resolve differing program priorities so that the agencies can work collaboratively to ensure that live animal imports posing a risk of zoonotic and animal diseases do not enter the United States. Such efforts could include collaborative methods for prevention, such as a comprehensive risk assessment system for live animal imports. (2) Lay out individual agency roles and responsibilities for all live animal imports, including how a collaborative effort will be led. (3) Identify resources dedicated to live animal imports and leverage these resources to the extent possible to support the agencies' efforts. (4) Examine ways to systematically share data on shipments of live animal imports that are regulated by more than one agency until ACE is able to offer data-sharing capabilities to each agency. (5) Explore the need for any additional legislative or executive authority to develop and implement this strategy such as the authority to establish a coordinating entity (e.g., an interagency workgroup). |
The Department of the Interior coordinated the responses to this recommendation for the three primary agencies responsible for regulating live animal imports--Health and Human Services/Centers for Disease Control and Prevention, U.S. Department of Agriculture/Animal and Plant Health Inspection Service, and Department of the Interior/U.S. Fish and Wildlife Service--and provided a document that described the agencies' plans and actions. This document stated that the agencies are strongly committed to ensuring that live animal imports do not contribute to the introduction of diseases into the United States that can affect humans, wildlife, or agricultural animal species. Although the document described the agencies' strategy as well as actions taken in response to some of the recommendation's specific elements, it also expressed concerns about the economic and staffing resources needed to implement the strategy and key planned actions. According to the document, while collaboration among agencies provides an opportunity to share resources and maximize cost savings, many of the activities proposed, including the formation of a permanent interagency committee for coordinated management of and response to oversight concerns for live animal imports would be difficult to implement and complete unless adequate resources were made available to support activities. As noted above, the agencies took actions in response to some of the recommendation's specific elements. For example, the three agencies identified priorities by developing lists of potential pathogens of concern that are specific to each department's statutory authority and ranked these pathogens by specific agency criteria. However, the document notes that many of these pathogens cross over multiple agency concerns and states that the proposed committee would take these concerns into consideration when evaluating policy, regulations or actions specific to pathogens under discussion. In July 2015, a Department of the Interior official said the resources needed to form a permanent interagency committee to implement the agencies' strategy and other planned actions were still not available.
|
| Department of Homeland Security | To better prevent the importation of live animals carrying zoonotic and animal diseases and improve the responsible agencies' collaboration, the Secretaries of Agriculture, Health and Human Services, Homeland Security, and the Interior should develop and implement, in coordination with the relevant federal agencies, a strategy for their collaboration in preventing the importation of animals that may be carrying zoonotic and animal diseases into the United States. This strategy should help the agencies (1) Identify and resolve differing program priorities so that the agencies can work collaboratively to ensure that live animal imports posing a risk of zoonotic and animal diseases do not enter the United States. Such efforts could include collaborative methods for prevention, such as a comprehensive risk assessment system for live animal imports. (2) Lay out individual agency roles and responsibilities for all live animal imports, including how a collaborative effort will be led. (3) Identify resources dedicated to live animal imports and leverage these resources to the extent possible to support the agencies' efforts. (4) Examine ways to systematically share data on shipments of live animal imports that are regulated by more than one agency until ACE is able to offer data-sharing capabilities to each agency. (5) Explore the need for any additional legislative or executive authority to develop and implement this strategy such as the authority to establish a coordinating entity (e.g., an interagency workgroup). |
The Department of Homeland Security's Customs and Border Protection (CBP) has taken sufficient actions in response to this recommendation. The Department of Health and Human Service's Centers for Disease Control and Prevention (CDC), the U.S. Department of Agriculture's Animal and Plant Health Inspection Service (APHIS), the Department of the Interior's U.S. Fish and Wildlife Service (FWS), and CBP were members of an interagency steering committee that developed a strategy document in response to this recommendation. However, CBP's role differs from that of the other three agencies. The strategy document noted that the response to this recommendation is being proposed by the primary agencies responsible for regulating live animal imports (CDC, APHIS, and FWS), and not CBP, which maintains a support role for such processes and does not have regulatory requirements or resources specific to live animal imports. According to the strategy, CBP will act in a secondary role to assist CDC, APHIS, and FWS as they implement their recommendations, contingent on legal authorities and resource capabilities. Furthermore, the strategy proposes to "establish a permanent interagency committee for coordinated management of and response to oversight concerns for live animal importations." Permanent membership would consist of representatives from APHIS, FWS, and CDC because these agencies have the most relevant statutory authority and expertise for live animals and their associated importation risks. According to the strategy, other agencies, such as CBP, should be added as needed based on any required subject expertise or for other advisory or supportive purposes.
|
| Department of Health and Human Services | To better prevent the importation of live animals carrying zoonotic and animal diseases and improve the responsible agencies' collaboration, the Secretaries of Agriculture, Health and Human Services, Homeland Security, and the Interior should jointly determine, in collaboration with CBP, the data elements that APHIS, CDC, and FWS will need Automated Commercial Environment (ACE) to contain, so that the agencies can effectively oversee all live animal imports. |
The Department of Homeland Security's Customs and Border Protection (CBP) as well as the Departments of Agriculture, Health and Human Services, and the Interior have taken actions in response to this recommendation. Through International Trade Data System initiatives, CBP's Automated Commercial Environment (ACE) is to become the single window for the trade community to submit data required to clear live animal imports, including determining which government agencies have authority over an entry. Each agency--APHIS, CDC, and FWS--has identified its respective information collection requirements for ACE.
|
| Department of the Interior | To better prevent the importation of live animals carrying zoonotic and animal diseases and improve the responsible agencies' collaboration, the Secretaries of Agriculture, Health and Human Services, Homeland Security, and the Interior should jointly determine, in collaboration with CBP, the data elements that APHIS, CDC, and FWS will need Automated Commercial Environment (ACE) to contain, so that the agencies can effectively oversee all live animal imports. |
The Department of Homeland Security's Customs and Border Protection (CBP) as well as the Departments of Agriculture, Health and Human Services, and the Interior have taken actions in response to this recommendation. Through International Trade Data System initiatives, CBP's Automated Commercial Environment (ACE) is to become the single window for the trade community to submit data required to clear live animal imports, including determining which government agencies have authority over an entry. Each agency--APHIS, CDC, and FWS--has identified its respective information collection requirements for ACE.
|
| Department of Homeland Security | To better prevent the importation of live animals carrying zoonotic and animal diseases and improve the responsible agencies' collaboration, the Secretaries of Agriculture, Health and Human Services, Homeland Security, and the Interior should jointly determine, in collaboration with CBP, the data elements that APHIS, CDC, and FWS will need Automated Commercial Environment (ACE) to contain, so that the agencies can effectively oversee all live animal imports. |
The Department of Homeland Security's Customs and Border Protection (CBP) as well as the Departments of Agriculture, Health and Human Services, and the Interior have taken actions in response to this recommendation. Through International Trade Data System initiatives, CBP's Automated Commercial Environment (ACE) is to become the single window for the trade community to submit data required to clear live animal imports, including determining which government agencies have authority over an entry. Each agency--APHIS, CDC, and FWS--has identified its respective information collection requirements for ACE.
|
| Department of Agriculture | To better prevent the importation of live animals carrying zoonotic and animal diseases and improve the responsible agencies' collaboration, the Secretaries of Agriculture, Health and Human Services, Homeland Security, and the Interior should jointly determine, in collaboration with CBP, the data elements that APHIS, CDC, and FWS will need Automated Commercial Environment (ACE) to contain, so that the agencies can effectively oversee all live animal imports. |
The Department of Homeland Security's Customs and Border Protection (CBP) as well as the Departments of Agriculture, Health and Human Services, and the Interior have taken actions in response to this recommendation. Through International Trade Data System initiatives, CBP's Automated Commercial Environment (ACE) is to become the single window for the trade community to submit data required to clear live animal imports, including determining which government agencies have authority over an entry. Each agency--APHIS, CDC, and FWS--has identified its respective information collection requirements for ACE.
|
| Department of the Interior | To better prevent the importation of live animals carrying zoonotic and animal diseases and improve the responsible agencies' collaboration, the Secretaries of Agriculture, Health and Human Services, Homeland Security, and the Interior should develop and implement, in coordination with the relevant federal agencies, a strategy for their collaboration in preventing the importation of animals that may be carrying zoonotic and animal diseases into the United States. This strategy should help the agencies (1) Identify and resolve differing program priorities so that the agencies can work collaboratively to ensure that live animal imports posing a risk of zoonotic and animal diseases do not enter the United States. Such efforts could include collaborative methods for prevention, such as a comprehensive risk assessment system for live animal imports. (2) Lay out individual agency roles and responsibilities for all live animal imports, including how a collaborative effort will be led. (3) Identify resources dedicated to live animal imports and leverage these resources to the extent possible to support the agencies' efforts. (4) Examine ways to systematically share data on shipments of live animal imports that are regulated by more than one agency until ACE is able to offer data-sharing capabilities to each agency. (5) Explore the need for any additional legislative or executive authority to develop and implement this strategy such as the authority to establish a coordinating entity (e.g., an interagency workgroup). |
The Department of the Interior coordinated the responses to this recommendation for the three primary agencies responsible for regulating live animal imports--Health and Human Services/Centers for Disease Control and Prevention, U.S. Department of Agriculture/Animal and Plant Health Inspection Service, and Department of the Interior/U.S. Fish and Wildlife Service--and provided a document that described the agencies' plans and actions. This document stated that the agencies are strongly committed to ensuring that live animal imports do not contribute to the introduction of diseases into the United States that can affect humans, wildlife, or agricultural animal species. Although the document described the agencies' strategy as well as actions taken in response to some of the recommendation's specific elements, it also expressed concerns about the economic and staffing resources needed to implement the strategy and key planned actions. According to the document, while collaboration among agencies provides an opportunity to share resources and maximize cost savings, many of the activities proposed, including the formation of a permanent interagency committee for coordinated management of and response to oversight concerns for live animal imports would be difficult to implement and complete unless adequate resources were made available to support activities. As noted above, the agencies took actions in response to some of the recommendation's specific elements. For example, the three agencies identified priorities by developing lists of potential pathogens of concern that are specific to each department's statutory authority and ranked these pathogens by specific agency criteria. However, the document notes that many of these pathogens cross over multiple agency concerns and states that the proposed committee would take these concerns into consideration when evaluating policy, regulations or actions specific to pathogens under discussion. In July 2015, a Department of the Interior official said the resources needed to form a permanent interagency committee to implement the agencies' strategy and other planned actions were still not available.
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