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Report to the Committee on Homeland Security and Governmental Affairs, 
U.S. Senate: 

United States Government Accountability Office:
GAO: 

November 2010: 

Live Animal Imports: 

Agencies Need Better Collaboration to Reduce the Risk of Animal-
Related Diseases: 

GAO-11-9: 

GAO Highlights: 

Highlights of GAO-11-9, a report to the Committee on Homeland Security 
and Governmental Affairs, U.S. Senate. 

Why GAO Did This Study: 

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. 

What GAO Found: 

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, 

* 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. 

* 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. 

What GAO Recommends: 

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. 

View [hyperlink, http://www.gao.gov/products/GAO-11-9] or key 
components. For more information, contact Lisa Shames at (202) 512-
3841 or shamesl@gao.gov. 
[End of section] 

Contents: 

Letter: 

Background: 

Gaps in the Statutory and Regulatory Framework for Some Live Animal 
Imports May Contribute to Disease Risks, according to Experts and 
Agency Officials: 

Agencies Have Collaborated to Meet Their Responsibilities, but Experts 
and Agency Officials Identified Barriers to Further Collaboration: 

APHIS, CDC, and FWS Have Reported Some Information on Their 
Performance on Live Animal Imports: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: Agencies' Processes for Overseeing Live Animal Imports: 

Appendix III: Data on the Number of Live Animals Imported in Recent 
Years: 

Appendix IV: Examples of Recent U.S. Animal Disease Outbreaks Causing 
Animal, Human, and Environmental or Economic Harm: 

Appendix V: Overview of Federal Agencies' Disease Risk Screening for 
Selected Types of Imported Animals: 

Appendix VI: Experts Responding to Our Survey on Live Animal Imports: 

Appendix VII: GAO Survey Questions and Responses: 

Appendix VIII: Comments from the U.S. Department of Agriculture: 

Appendix IX: Comments from the Department of Homeland Security: 

Appendix X: Comments from the Department of the Interior: 

Appendix XI: GAO Contact and Staff Acknowledgments: 

Related GAO Products: 

Tables: 

Table 1: Overview of Federal Agencies' Disease Risk Screening for 
Selected Types of Imported Animals: 

Table 2: Number of Live Animal Imports Regulated by APHIS, Fiscal 
Years 2005 through 2008: 

Table 3: Number of Live Animal Imports Regulated by FWS, Fiscal Years 
2005 through 2009: 

Abbreviations: 

ACE: Automated Commercial Environment: 

APHIS: Animal and Plant Health Inspection Service: 

Bd: Batrachochytrium dendrobatidis: 

CBP: Customs and Border Protection: 

CDC: Centers for Disease Control and Prevention: 

DHS: Department of Homeland Security: 

FWS: Fish and Wildlife Service: 

ITDS: International Trade Data System: 

MOU: memorandum of understanding: 

SARS: severe acute respiratory syndrome: 

USDA: U.S. Department of Agriculture: 

[End of section] 

November 8, 2010: 

The Honorable Joseph I. Lieberman:
Chairman:
The Honorable Susan M. Collins:
Ranking Member:
Committee on Homeland Security and Governmental Affairs:
United States Senate: 

The United States is the world's leading import market for live 
animals: From 2005 through 2008 more than 1 billion live animals were 
legally imported into the United States for agriculture, clinical 
research, education and exhibition, the aquarium and pet industries, 
and other uses. However, these imports have the potential to transmit 
zoonotic diseases--infectious diseases that can be transmitted between 
animals and humans and can cause a substantial number of deaths. 
Furthermore, zoonotic diseases have represented about 75 percent of 
newly emerging infectious diseases in recent years. Because of growing 
international trade and travel, these zoonotic diseases can emerge 
anywhere and spread rapidly around the globe, as demonstrated by the 
2003 outbreak of severe acute respiratory syndrome (SARS), a viral 
respiratory illness that caused pneumonia in most patients and was 
responsible for over 700 deaths in East Asia and 43 deaths in Canada. 
Over the past few years, another zoonotic disease, a highly pathogenic 
strain of avian influenza, killed millions of wild and domestic birds 
worldwide and infected over 400 people, more than half of whom died. 
The spread of zoonotic diseases, as well as other diseases affecting 
only animals, can take a major economic toll on many industries. For 
example, the highly pathogenic avian influenza in East Asia cost the 
affected economies an estimated $10 billion. In the United States, an 
outbreak of exotic Newcastle disease--a contagious and fatal viral 
disease affecting birds--resulted in the destruction of over 4.5 
million birds in 2002 and 2003 at a cost of more than $395 million in 
lost trade. 

The laws governing the importation of live animals include five 
statutes that are implemented by four agencies. Specifically, 

* Animal Health Protection Act. The U.S. Department of Agriculture's 
(USDA) Animal and Plant Health Inspection Service (APHIS) may prohibit 
imports of particular animals to prevent the introduction of any pest 
or disease affecting agricultural animals, such as cattle, horses, 
poultry, and swine. 

* Lacey Act. The Department of the Interior's Fish and Wildlife 
Service (FWS) administers the prohibition against the import of 
animals that have been individually listed in the statute or 
prescribed in FWS regulation to be "injurious to human beings, to the 
interests of agriculture, horticulture, forestry, or to wildlife or 
the wildlife resources of the United States." 

* The Endangered Species Act of 1973. FWS administers the prohibition 
against the import of animals that have been listed as threatened or 
endangered species and implements other international agreements 
related to these species. 

* Public Health Service Act. The Department of Health and Human 
Services' Centers for Disease Control and Prevention (CDC) issues 
regulations to prevent the introduction, transmission, and spread of 
communicable diseases, including zoonotic diseases. 

* Tariff Act of 1930. The Department of Homeland Security's (DHS) 
Customs and Border Protection (CBP) is responsible for inspecting 
imports for compliance with United States law and assisting all 
federal agencies in enforcing their regulations--including regulations 
for live animal imports--at ports of entry. 

As we have previously reported, when responsibilities cut across more 
than one federal agency--as they do for the regulation of live animal 
imports to prevent the introduction and spread of diseases--it is 
important for agencies to work collaboratively.[Footnote 1] Taking 
into account the nation's long-range fiscal challenges, we noted that 
the federal government must identify ways to deliver results more 
efficiently and in a way that is consistent with its multiple demands 
and limited resources. We also identified key practices that can help 
enhance and sustain federal agencies' collaboration. In addition, we 
have previously reported on the need to collaborate on animal disease 
issues. For example, we reported in 2007 on the steps that USDA took 
to prepare for highly pathogenic avian influenza in poultry and 
recommended that USDA and DHS clarify their roles during emergency 
responses to a disease outbreak.[Footnote 2] Both USDA and DHS 
officials told us that they have taken preliminary steps to clarify 
and better define their coordination roles. For example, the two 
agencies meet on a regular basis to discuss such coordination. 

In this context, you asked us to examine (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; (2) the extent to which APHIS, CBP, CDC, and FWS collaborate 
to meet their responsibilities and face barriers, if any, to 
collaboration; and (3) the performance information that the 
responsible agencies have reported on live animal imports. 

To identify potential gaps in the statutory and regulatory framework, 
we reviewed relevant statutes, the agencies' implementing regulations, 
and other agency documents. We also reviewed APHIS and FWS data on the 
number, type, and exporting country of all imported animals regulated 
by these two agencies for fiscal years 2005 through 2009. For the 
APHIS and FWS data, we analyzed documentation related to the data, and 
worked with agency officials to identify data problems, and determined 
the data were sufficiently reliable for the purposes of providing 
background to this report. To obtain information on potential gaps in 
the statutory and regulatory framework as well as agencies' processes 
for overseeing live animal imports, we interviewed officials at agency 
headquarters and ports of entry--airports in Atlanta, Baltimore, Los 
Angeles, New York, and Washington, D.C., and the land border crossings 
with Mexico at Otay Mesa and San Ysidro, California. At these ports, 
we focused our review on the legal importation of live animals and not 
on agencies' actions to prevent animal smuggling. We also reviewed 
scientific studies on zoonotic and animal diseases, including studies 
by the National Academies of Sciences. 

To examine the extent to which the four agencies collaborate to meet 
their responsibilities and face barriers, if any, to collaboration, we 
reviewed each agency's strategic plans, policies, and protocols; 
reviewed documentation on the allocation of staff resources; and 
interviewed headquarters officials. We also examined the degree to 
which the agencies' collaborative efforts reflected the key practices 
we had identified that can help enhance and sustain collaboration 
among federal agencies. 

To address the first two objectives, we also conducted a two-round 
survey to identify potential gaps in the current statutory and 
regulatory framework, how well responsible agencies collaborate to 
meet their responsibilities, and potential barriers to collaboration. 
The first round of the survey was conducted from January through 
February 2010, and the second round was conducted from April through 
May 2010. We identified knowledgeable experts who had primary 
employment responsibilities related to or dependent on live animal 
imports, authored peer-reviewed papers, presented at professional 
conferences, provided testimony on the subject matter to Congress, or 
were recognized by their peers as experts on live animal imports. To 
ensure a cross section of different sectors, we selected experts from 
federal and state government, academia, nongovernmental organizations, 
and industry to obtain a broad spectrum of opinions. For the first 
round, we sent surveys that consisted of open-ended questions 
(questions that solicit additional information) to our initial list of 
39 experts, and we received responses from 33, resulting in a response 
rate of about 85 percent. On the basis of recommendations provided by 
those responding in our first round and other experts, we expanded our 
list of experts to 64 for the survey's second round, which consisted 
of closed-ended questions (questions with a set of answers to choose 
from). Of these 64 experts, we received responses from 56, resulting 
in a response rate of about 88 percent for the second round. 

To examine the performance information the responsible agencies have 
reported on live animal imports in their planning and reporting 
documents, we reviewed strategic plans, operational plans, mission 
statements, and annual performance plans and reports from APHIS, CBP, 
CDC, and FWS. A more detailed discussion of our scope and methodology 
is presented in appendix I. 

We conducted this performance audit from August 2009 through October 
2010, in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives. 

Background: 

APHIS, CBP, CDC, and FWS share responsibility for preventing the 
importation of live animals that may introduce and spread zoonotic and 
animal diseases.[Footnote 3] APHIS, CDC, and FWS have developed 
regulations that provide specific requirements and restrictions on the 
importation of animals. In some cases, more than one agency may 
regulate a given animal. For example, CDC regulates dogs for their 
risk of spreading rabies to humans, and APHIS regulates dogs from 
countries with screwworm, a parasite that can cause great damage to 
domestic livestock and other warm-blooded animals, for their risk of 
spreading this parasite to agricultural animals. Information on each 
agency's responsibilities and oversight activities follows and is 
presented in greater detail in appendix II. 

Agencies That Are Responsible for Live Animal Imports: 

While CBP is responsible for overseeing all imports and assists other 
agencies in enforcing their import regulations, APHIS, CDC, and FWS 
have specific statutory and regulatory responsibilities for protecting 
human, domesticated animal, and wildlife health from risks posed by 
live animal imports. 

APHIS. APHIS restricts the importation of live animals that it has 
determined may pose a disease risk to agricultural animals, such as 
cattle, horses, poultry, sheep, and swine. APHIS requires that many of 
the animals it regulates be visually inspected at the port of entry 
and generally requires the animals be accompanied by health 
certificates signed by a licensed veterinarian in the country of 
export and import permits. APHIS determines the level of inspection 
for animals on the basis of their associated disease risk, for both 
the type of animal and country of export. As a result of this 
determination, APHIS may restrict imports of certain animals from 
certain countries or require that animals undergo quarantine and 
disease testing. APHIS veterinarians inspect live animal imports at 15 
land ports along the border with Mexico, 20 land ports along the 
border with Canada, and 30 airports across the continental United 
States, and in Alaska, Hawaii, and Puerto Rico. In addition, APHIS 
maintains animal quarantine facilities in southern California, 
southern Florida, and New York state and oversees private quarantine 
facilities for birds and horses in southern California. At these 
quarantine facilities, imported animals are held until test results 
for various diseases are received. 

CBP. CBP assists other federal agencies in enforcing their import 
regulations, has the primary authority to inspect imports, and seeks 
to interdict shipments of contraband and the illegal importation of 
live animals and other products while facilitating the flow of legal 
travel and trade. According to CBP officials, when a live animal 
shipment arrives at a port of entry, CBP holds and refers the shipment 
to the responsible agency or agencies. CBP holds the import until an 
agency representative is available to release it. After the 
responsible regulating agency has released the import, CBP clears the 
import for entry into the United States. CBP staff are present at more 
than 300 land, air, and sea ports of entry and are trained in the 
procedures to follow when live animals are presented for customs 
clearance. 

CDC. CDC restricts the importation of live animals that it has 
determined pose a risk to public health. CDC's restrictions on these 
imports vary by type of animal and can include banning certain 
imports, requiring permits, requiring vaccination certificates, and 
requiring quarantine. CDC staff are not present at all ports of entry 
to routinely inspect live animal imports. According to CDC officials, 
CDC relies on APHIS, CBP, and FWS staff to enforce its regulations at 
ports of entry. When the agencies' staff have questions about 
enforcing CDC's regulations, they are to contact CDC quarantine public 
health officers, who are often located at a CDC quarantine station 
that is at or near the port of entry. CDC has 20 quarantine stations 
in the continental United States, Alaska, Hawaii, and Puerto Rico. 

FWS. FWS restricts the importation of certain wildlife. Specifically, 
FWS restricts the importation of injurious wildlife and threatened or 
endangered species and related species for which international trade 
is regulated under international agreements. Injurious wildlife 
includes animals that are individually listed in the Lacey Act or 
prescribed in FWS regulations to be injurious to human beings; to the 
interests of agriculture, horticulture, or forestry; or to wildlife or 
the wildlife resources of the United States. FWS seeks to prevent the 
introduction of invasive species as injurious wildlife under the Lacey 
Act. Invasive species are alien (or nonnative) species whose 
introduction does, or is likely to, cause economic or environmental 
harm or harm to human health.[Footnote 4] At ports of entry, FWS 
wildlife inspectors review the required import documents and, for some 
live animal shipments, perform visual inspections. If FWS determines 
that the animals are prohibited from importation based on FWS 
regulations, for example, are injurious to wildlife or threatened or 
endangered species, it rejects the import unless it has an FWS permit, 
which may be issued under certain conditions, such as educational 
purposes. FWS has about 120 wildlife inspectors who handle shipments 
at 49 ports of entry nationwide, including 7 land ports along the 
Mexican border, 24 land ports along the Canadian border, and 18 
designated ports for air, ocean, rail, and truck across the 
continental United States and in Alaska and Hawaii. 

Number, Type, and Purpose of Live Animals Imports: 

APHIS and FWS data systems provide information on the number of and 
purpose for live animal imports, as well as on the country from which 
the import has been shipped into the United States in recent years. 
[Footnote 5] According to the APHIS data system, about 32 million live 
animals--mostly agricultural or aquacultural--were imported under 
APHIS regulation in fiscal year 2008, the most recent year for which 
verified data were available. They included cattle, fish, poultry, and 
swine. According to the FWS data system, about 177 million live 
animals--all wildlife--were imported under FWS regulation in fiscal 
year 2009. About 157 million of these imports were fish. Other types 
of animals imported under FWS regulation included amphibians, birds, 
corals, crustaceans, insects, mammals, mollusks, and reptiles. More 
information about the number and type of live animal imports is in 
appendix III. 

Interagency Collaboration: 

In 2000, we reported that agencies face a range of barriers when they 
attempt to collaborate with other agencies.[Footnote 6] With these 
barriers in place, federal agencies carry out programs in a 
fragmented, uncoordinated way, resulting in a patchwork of programs 
that can waste scarce funds, confuse and frustrate program customers, 
and limit the overall effectiveness of the federal effort. 
Subsequently, in 2005, we identified key practices that can help 
enhance and sustain collaboration among federal agencies.[Footnote 7] 
Among the practices we identified were (1) defining and articulating a 
common outcome; (2) defining and agreeing on roles and 
responsibilities; (3) establishing mutually reinforcing or joint 
strategies; (4) identifying and addressing needs by leveraging 
resources; and (5) establishing compatible policies, procedures, and 
other means to operate across agency boundaries. In our 2005 report, 
we stated that while we generally believe that the application of as 
many of these practices as possible increases the likelihood of 
effective collaboration, we also recognize that there is a wide range 
of situations and circumstances in which agencies work together. 

The One Health Initiative Discusses Collaboration to Address Zoonotic 
and Animal Diseases: 

Recognizing that zoonotic and animal diseases are interconnected, 
several organizations--including the American Medical Association, the 
American Veterinary Medical Association, and CDC--have taken steps to 
support the One Health concept, which is a worldwide strategy for 
expanding interdisciplinary collaboration and communications in all 
aspects of health care for humans and animals. In 2007, the American 
Veterinary Medical Association established the One Health Initiative 
Task Force to study the feasibility of a campaign to facilitate 
collaboration and cooperation among health science professions, 
academic institutions, governmental agencies, and industries to help, 
among other things, assess, treat, and prevent cross-species disease 
transmission. In 2008, the task force framed the issue, stating that 
the convergence of people, animals, and the environment has created a 
new dynamic in which the health of each group is inextricably 
interconnected.[Footnote 8] Examples of recent diseases causing 
animal, human, environmental, or economic harm are described in 
appendix IV. 

The National Invasive Species Council Focuses on Collaboration among 
Federal Agencies: 

In 1999, an executive order established the National Invasive Species 
Council, cochaired by the Secretaries of Agriculture, Commerce, and 
the Interior.[Footnote 9] Its members are the Secretaries and 
Administrators of 13 federal departments and agencies. The council was 
charged with providing national leadership; seeing that the federal 
invasive species activities are coordinated, complementary, cost- 
efficient, and effective; and encouraging planning and action at 
local, tribal, state, and regional levels. The range of invasive 
species issues that the council is attempting to address includes live 
animal imports that may bring diseases into the United States. The 
executive order also required the Secretary of the Interior to 
establish the Invasive Species Advisory Committee, a group of 30 
nonfederal stakeholders from diverse constituencies (representing 
state, tribal, local, and private concerns) around the nation, to 
advise the council on invasive species issues. In 2008, the council 
issued its most recent management plan for invasive species, the 2008-
2012 National Invasive Species Management Plan. The management plan 
lists goals and performance elements that identify the federal agency 
with the lead or participant role. It includes tasks pertaining to 
pathogens or diseases. For example, one of the tasks is to develop a 
process for identifying high-priority invasive plants, animals, and 
plant or animal pathogens for agencies' actions. The council is 
currently preparing a progress report on the implementation of the 
2008-through-2012 plan, with an expected completion date of October 
2010. 

Recent Studies Have Discussed the Regulation of Live Animal Imports: 

Studies by the National Academies of Sciences and others have found 
significant deficiencies in the regulation of live animal imports that 
may allow the introduction and spread of emerging zoonotic and animal 
diseases. For example, 

* A 2005 National Academies of Sciences report referred to a 
"patchwork of federal policies and agencies with limited or ill-
defined jurisdiction" for the importation of wildlife, "a significant 
gap in preventing and rapidly detecting emergent diseases," and "a 
lack of coordinated federal oversight" over disease issues associated 
with these animals.[Footnote 10] It found that wildlife are imported 
daily with little or no health monitoring, increasing the likelihood 
that zoonotic or animal diseases will enter the United States. The 
report also noted that the animal health infrastructure "does not have 
formal and comprehensive-based science and risk analysis systems for 
anticipating potential challenges to animal health; ranking their 
likelihood of occurring and likely severity; evaluating alternative 
prevention, detection, and diagnostic systems; and using this 
information to make appropriate policy decisions." 

* A 2007 study by the Defenders of Wildlife, a nonprofit organization 
that supports wildlife conservation, concluded that no law mandates a 
comprehensive assessment of the potential risk from the importation of 
a given nonnative species to human and animal health.[Footnote 11] 

* In the November 2009 issue of CDC's journal, Emerging Infectious 
Diseases, scientists reported on their study of mammal imports and 
concluded that these imports provide numerous opportunities for 
zoonotic pathogens to enter the United States. The study recommended 
increased surveillance of imported animals that pose an increased risk 
of harboring zoonotic pathogens.[Footnote 12] 

Gaps in the Statutory and Regulatory Framework for Some Live Animal 
Imports May Contribute to Disease Risks, according to Experts and 
Agency Officials: 

The statutory and regulatory framework governing live animal imports 
has gaps that could allow the introduction and spread of zoonotic 
diseases and diseases affecting wildlife, according to the experts we 
surveyed, our discussions with agency officials, and scientific 
studies on zoonotic and animal diseases. In particular, while APHIS 
has regulations in place to protect agricultural animals from the risk 
of diseases in live animal imports, CDC does not fully use its 
statutory authority to prevent the importation of live animals that 
may pose a risk of zoonotic diseases, and FWS generally does not 
restrict the entry of imported wildlife that may pose disease risks. 

APHIS Has Regulations to Protect U.S. Agriculture from Live Animal 
Imports That Could Carry Disease: 

APHIS has regulations to prevent the importation of live animals that 
it has determined could pose a disease risk to agricultural animals. 
For example, APHIS requires that commercial birds, such as those 
imported for resale, breeding, or public display from countries other 
than Canada be quarantined until found free of evidence of 
communicable diseases of poultry. In addition, APHIS restricts the 
importation of certain animals from certain countries, such as cattle 
from countries where foot-and-mouth disease--a highly contagious viral 
disease of cloven-hoofed animals such as cattle, swine, and sheep--has 
been detected. 

USDA's Office of Inspector General has performed several audits of 
APHIS's live animal import processes in recent years. For example, an 
August 2010 audit report identified weaknesses in the procedures APHIS 
used to handle animals destined for a quarantine facility, beginning 
with the precautions it took when receiving the animals into the 
country and continuing to the conditions at the quarantine facilities. 
[Footnote 13] According to the report, APHIS officials did not 
identify these weaknesses because they did not exercise sufficient 
oversight to ensure import and quarantine requirements were met. 
Instead, they relied on the experience and expertise of port staff and 
import center officials. In addition, a 2008 audit report on APHIS's 
controls over live animal imports indicated that APHIS relies on 
health certificates from the exporting country to certify the animal's 
health condition, age, and other import requirements.[Footnote 14] 
However, the report stated, APHIS does not have adequate processes to 
determine whether individual problems detected represent a larger 
systemic noncompliance that needs to be addressed by agency inspection 
personnel or the exporting country. The Inspector General recommended 
that APHIS establish an automated system of records to document and 
track problems with live imported animals and report these problems to 
key stakeholders. According to the Inspector General, APHIS planned to 
implement this recommendation and to have officials analyze data from 
the system each month and communicate with stakeholders regarding 
corrective actions. According to agency officials, APHIS began using 
this system--the Veterinary Services Process Streamlining System--in 
June 2010. 

We found that the agency has screening processes in place for the 
imported animals it regulates that generally do not exist for other 
imported animals regulated by other agencies. For example, as table 1 
shows, for cattle from Canada or Mexico, APHIS is to assess whether 
key diseases are present in the prospective exporting country, require 
a health certificate from a veterinarian in the exporting country, and 
visually inspect the cattle. In addition, for cattle not from Canada, 
Mexico, Central America, or the West Indies, APHIS requires that the 
cattle be quarantined to determine that they are free from disease. As 
the table shows, CDC and FWS do not generally have similar processes 
for the animals they regulate. (See app. V for additional types of 
imported animals and federal agency disease risk screening 
requirements.) 

Table 1: Overview of Federal Agencies' Disease Risk Screening for 
Selected Types of Imported Animals: 

Type of imported animal: Cattle from Canada or Mexico[B]; 
Regulating agency[A]: APHIS; 
Disease testing at quarantine facility: [C]; 
Assessment by U.S. agency of disease presence in exporting country: 
APHIS; 
Health certificate from exporting country: APHIS; 
Visual inspection at U.S. ports of entry for disease: APHIS. 

Type of imported animal: Commercial birds not from Canada; 
Regulating agency[A]: APHIS; FWS; 
Disease testing at quarantine facility: APHIS; 
Assessment by U.S. agency of disease presence in exporting country: 
APHIS; 
Health certificate from exporting country: APHIS; 
Visual inspection at U.S. ports of entry for disease: APHIS. 

Type of imported animal: Rodents from Africa; 
Regulating agency[A]: CDC; FWS; 
Disease testing at quarantine facility: [C]; 
Assessment by U.S. agency of disease presence in exporting country: 
CDC[D]; 
Health certificate from exporting country: [C]; 
Visual inspection at U.S. ports of entry for disease: FWS[E]. 

Type of imported animal: Rodents not from Africa; 
Regulating agency[A]: FWS; 
Disease testing at quarantine facility: [C]; 
Assessment by U.S. agency of disease presence in exporting country: 
[C]; 
Health certificate from exporting country: [C]; 
Visual inspection at U.S. ports of entry for disease: [C]c. 

Type of imported animal: Amphibians; 
Regulating agency[A]: FWS; 
Disease testing at quarantine facility: [C]; 
Assessment by U.S. agency of disease presence in exporting country: 
[C]; 
Health certificate from exporting country: [C]; 
Visual inspection at U.S. ports of entry for disease: [C]. 

Source: APHIS, CDC, and FWS regulations and guidance and discussions 
with agency officials. 

Note: FWS does not screen shipments of live animals for disease risk, 
with the exception of imported salmon. FWS requires that all carriers 
transporting wild mammals and birds to the United States have a 
certificate of veterinary medical inspection signed by a veterinarian. 

[A] CBP does not develop regulations for how to import an animal, so 
it is not included in the list of regulating agencies. 

[B] Cattle from Mexico are tested for tuberculosis and brucellosis and 
checked for ticks prior to entry into the United States. 

[C] APHIS, FWS, and CDC do not perform this screening process for this 
imported animal. 

[D] In 2003, CDC restricted the importation of rodents from Africa 
based on concerns about monkeypox. 

[E] FWS inspects shipments of rodents from Africa to assess if the 
rodents are in compliance with CDC regulations. 

[End of table] 

Although APHIS does not regulate the importation of all live animals, 
most of the experts responding to our survey supported a broader role 
for APHIS. (See appendices VI and VII for more details on these 
experts and their responses to the survey.) Specifically, 

* Fifty-three of the 55 experts responding to our survey question 
about APHIS's statutory and regulatory framework indicated that 
changes are needed to prevent the importation of zoonotic and animal 
diseases. 

* Forty-eight of the 54 experts responding to a question in our survey 
strongly or somewhat supported giving APHIS the authority to consider 
the disease risk from wildlife as part of its existing risk assessment 
process. 

In 2008, APHIS took a step toward broadening its oversight of live 
animal imports and becoming more responsive to emerging disease 
threats. It issued a long-term strategy--known as VS2015--that 
identifies key changes APHIS states are essential for the organization 
in 2015, including (1) an expanded veterinary health mission and (2) 
an increased focus on disease prevention, preparedness, detection, and 
early response activities.[Footnote 15] Specifically, 

Expanded veterinary health mission. Consistent with the One Health 
concept, APHIS would expand its mission to address not only disease 
issues that affect agricultural animals but also those associated with 
zoonotic and wildlife diseases. According to the long-term strategy, 
APHIS plans to: 

* provide national leadership on the animal health component 
associated with public health, 

* work with wildlife entities to address health issues that affect 
production agriculture and wildlife health, and: 

* lend its veterinary assets (e.g., laboratory networks, stockpiles, 
and response corps) and provide leadership in areas within its 
expertise (e.g., epidemiology, surveillance, planning, risk analysis, 
and modeling) when public health issues arise involving nonnative and 
wildlife species. 

Increased focus on disease prevention, preparedness, detection, and 
early response activities. APHIS's goal is to reduce the frequency of 
disease outbreaks that affect animals by emphasizing prevention and 
preparedness. According to the long-term strategy, APHIS plans to: 

* design and direct comprehensive national animal health surveillance 
systems capable of finding foreign, emerging, and known diseases, and 
of supporting international reporting and trade verification 
requirements; 

* investigate potential emerging animal health threats and apply 
decision criteria to determine appropriate early responses; 

* when needed, extend its prevention and early response efforts to 
address animal health issues occurring outside of the United States, 
including identifying, prioritizing, planning, and directing APHIS- 
funded animal health surveillance and disease control or eradication 
programs carried out overseas; and: 

* assist other countries as they develop their animal health 
capacities and provide leadership in the development of global animal 
health standards and methods. 

In support of VS2015, APHIS formed an internal work team that, 
according to agency officials, is working on more comprehensive 
training of APHIS staff; better use of technology for collaboration, 
communication, and data tracking; and the engagement of industry as a 
more active partner. 

CDC Has Regulations for Some Live Animal Imports but Does Not Prevent 
the Importation of Many Animals That May Pose a Risk of Zoonotic 
Diseases: 

CDC has regulations to prevent the importation of certain live animals 
that may pose a previously identified disease risk to humans for some 
diseases, such as rabies, but, according to agency officials, CDC's 
regulations are limited to specific species and regions and do not 
comprehensively prevent the importation of animals that are known to 
present a high risk of zoonotic diseases. That is, CDC restricts 
imports of some animals to prevent the introduction of specific 
diseases: nonhuman primates, to prevent the spread of tuberculosis, 
among other things; bats, to prevent the introduction of a variety of 
infectious pathogens, including Ebola virus; rodents from Africa, to 
prevent monkeypox; dogs and cats, to prevent zoonotic diseases in 
general and rabies in dogs; and certain turtles, to prevent 
Salmonella. In 2004, CDC banned the importation of birds from 
specified countries based on the threat that imports from such 
countries increased the risk that highly pathogenic avian influenza 
may be introduced into the United States. In 2009, CDC rescinded this 
ban. According to CDC's notice rescinding the ban, APHIS's import 
restrictions on birds and poultry adequately address risks to human 
health, and CDC will work closely with APHIS to monitor the 
international situation regarding highly pathogenic avian influenza. 

Even though CDC has these restrictions, imported animals that present 
a zoonotic risk could enter into the United States. For example, 

* While CDC generally requires proof of current rabies vaccination and 
the confinement of most dogs for up to 30 days after vaccination, it 
has received reports of large-volume shipments of puppies intended for 
immediate resale. According to agency officials, these animals often 
appear younger than the age on their accompanying documents, that is, 
they are too young to receive an effective rabies vaccination, and 
their vaccination status is questionable. In addition, according to 
agency officials, if CDC finds at ports of entry that a dog was not 
vaccinated for rabies, the agency allows it to enter, if the owner 
agrees to keep the dog confined until it can be properly vaccinated 
and then confined for an additional 30 days following vaccination to 
prevent the potential spread of rabies. However, state and local 
agencies that are to monitor confinement frequently lack resources to 
do so, according to CDC officials. 

* CDC's regulations do not require rabies vaccinations for cats, which 
are highly susceptible to certain strains of rabies virus and can also 
transmit the infection to humans. 

In addition, experts responding to our survey told us that CDC 
generally reacts only when a zoonotic disease problem arises. For 
example, since the 1970s it has been well known that monkeypox, a 
zoonotic disease, was endemic to Africa. However, according CDC 
officials, CDC did not have a process to conduct a risk assessment on 
the potential movement of monkeypox to the United States. Furthermore, 
they said, if such a risk assessment process had been in place, CDC 
might have restricted the importation of certain animals from Africa. 
After a 2003 outbreak of monkeypox in the United States, which 
sickened over 70 people, CDC restricted the importation of African 
rodents and other animals that may carry the monkeypox virus. However, 
CDC still allows the importation of rodents from countries outside of 
Africa, and these imported rodents are not subject to examination to 
determine whether they may be carrying zoonotic disease. Furthermore, 
according to experts responding to our survey and CDC officials, the 
importation of many other wildlife species is allowed with little or 
no screening for zoonotic disease risks. For example, mice, rats, and 
gerbils are not screened for zoonotic diseases, but the animal family 
that includes these animals has been found to harbor 21 zoonotic 
diseases. 

CDC's regulation of live animal imports does not sufficiently protect 
against zoonotic disease risks, according to the experts responding to 
our survey and scientific studies. According to 50 of the 55 experts 
responding to our survey question about CDC's statutory and regulatory 
framework, changes are needed. For example, 40 of the 51 experts 
responding to a question in our survey strongly or somewhat supported 
giving CDC the authority to use pre-import screening, such as a 
process that assesses disease risk by species and country and 
determines allowable imports on the basis of that assessment. CDC is 
considering other regulatory mechanisms that would allow CDC to 
suspend the entry of animal imports into the United States from 
designated foreign countries for public health reasons. Decisions to 
suspend animal imports from designated foreign countries would be 
based on the existence of a communicable disease in that country and 
the likelihood that allowing such imports would increase the 
likelihood of introducing disease into the United States. While these 
regulatory mechanisms are not specifically "pre-import screening," 
these mechanisms may serve the same purpose. 

The CDC officials we interviewed acknowledged gaps in the agency's 
regulation of live animal imports for zoonotic diseases. To address 
this problem, in 2007, CDC issued an advance notice of proposed 
rulemaking on live animal imports to take steps to better prevent the 
introduction of zoonotic disease into the United States. The questions 
raised in the advance notice of proposed rulemaking include whether 
CDC should (1) establish a regulation that maintains a list of species 
or categories of high-risk animals for which importation is restricted 
(e.g., either prohibited from entry or subject to certain 
requirements), (2) apply these potential restrictions to broad 
taxonomic groupings (e.g., all rodents) or individual species, (3) 
issue these potential restrictions on a limited geographical basis 
(i.e., certain countries or regions) or more broadly, and (4) make 
rabies vaccination a requirement for entry into the United States for 
all dogs and cats. CDC is currently analyzing the comments that it 
received, revising the proposed language, and conducting economic 
analyses. CDC expects to publish a notice of proposed rulemaking in 
2011. 

Although FWS Has Regulations for Injurious Wildlife, It Does Not 
Restrict the Entry of Imported Wildlife That May Pose Disease Risks: 

Under the authority of the Lacey Act, FWS has implemented regulations 
to restrict imports of various types of nonnative live animals that 
have been identified as injurious wildlife because, for example, they 
could become invasive.[Footnote 16] However, FWS's regulations allow 
other types of wildlife to enter the United States with little 
assessment of the disease risk or health status of the animal, despite 
the possible presence of diseases in animals that are not endemic to 
the United States. For example, FWS does not restrict the importation 
of live amphibians or assess their risk for the presence of disease, 
creating a risk that the Bd fungus (Batrachochytrium dendrobatidis)-- 
which causes a highly contagious disease that is potentially fatal to 
amphibians--will continue to enter and spread. The Department of the 
Interior has been petitioned by the Defenders of Wildlife to ban 
imports of live amphibians unless they are free of the Bd pathogen. As 
of September 2010, the department planned to gather information from 
the public before deciding whether to develop a regulation in response 
to this petition. Furthermore, the Lacey Act's process to ban the 
importation of injurious wildlife often requires too much time for the 
process to be effective, according to FWS officials and experts 
responding to our survey. On average, it takes about 4 years for FWS 
to identify a species or group of species as injurious wildlife. 
During this time, the animals in question continue to be imported into 
the United States. 

In addition, according to FWS officials, FWS inspectors visually 
inspect some live wildlife imports, which may include observation for 
signs of disease, but they are not veterinarians, and they do not have 
expertise in detecting diseased animals. Furthermore, experts 
responding to our survey said that visual inspections have limited 
effectiveness in detecting diseased animals. They noted that it is 
often difficult to distinguish between a healthy, uninfected animal 
and an apparently healthy but infected animal, and even healthy 
animals can carry pathogens that could harm other species or humans 
but not harm the host. 

In written comments to our survey, some experts reported that the 
Lacey Act should be amended to better prevent the importation of live 
animals that pose disease risks, while other experts said FWS should 
use its current authority to improve its regulations in this area. 
According to 52 of the 55 experts responding to our survey question 
about FWS's statutory and regulatory framework, changes are needed. Of 
the 53 experts who responded to our survey questions about specific 
potential changes, 44 strongly or somewhat supported giving FWS the 
authority to use pre-import screening, and 43 strongly or somewhat 
supported having FWS expedite the process for classifying species as 
injurious wildlife. 

The Department of the Interior has taken preliminary steps that may 
address gaps in FWS's regulation of live animal imports. In addition 
to reviewing the petition to restrict amphibian imports, in January 
2010, the Secretary of the Interior directed FWS to comprehensively 
review statutory authorities and regulations to address existing 
invasive species problems and to recommend potential tools to more 
effectively prevent the introduction of new invasive threats. 
According to Department of the Interior testimony provided at a March 
2010 hearing on invasive species, FWS is reviewing several proposals 
to create a more proactive and comprehensive approach to preventing 
the spread of invasive species, including streamlining the evaluation 
process, examining gaps that the Lacey Act's injurious wildlife 
provisions leave in the listing process, revising its risk assessment 
process, and supporting improved regulatory and educational 
approaches.[Footnote 17] 

Agencies Have Collaborated to Meet Their Responsibilities, but Experts 
and Agency Officials Identified Barriers to Further Collaboration: 

APHIS, CBP, CDC, and FWS have collaborated to meet their 
responsibilities by taking actions in five areas--strategic planning, 
joint strategies, written procedures, leveraging resources, and 
sharing data--but experts responding to our survey and agency 
officials we interviewed identified barriers to further collaboration 
on live animal imports. As we have previously reported, agencies 
encounter a range of barriers when they attempt to collaborate with 
other agencies.[Footnote 18] Experts also identified the need for an 
entity to help the agencies overcome these barriers. 

Although Agencies Have Collaborated to Meet Common Goals, They Face 
Barriers to Additional Collaboration: 

Strategic planning. APHIS, CBP, CDC, and FWS have engaged in strategic 
planning that recognizes the need for joint efforts to reduce the 
risks of zoonotic and animal diseases from live animal imports. 
Specifically, according to APHIS's 2007-through-2012 strategic plan, 
it is working with CBP to reduce pest and disease threats at the 
borders. The strategic plan also states that the agency's risk 
assessment protocols must recognize the growing importance of zoonotic 
diseases and the need to work with public health agencies to reduce 
the risk of these diseases. Within APHIS, the program office of 
Veterinary Services' strategic plan--VS2015--states that Veterinary 
Services intends to meet future animal health challenges, such as 
emerging zoonotic and animal diseases, by 2015. According to this 
plan, Veterinary Services will expand its mission to include public 
health concerns connected to any type of animal. In addition, the plan 
states that Veterinary Services will work with wildlife entities to 
address health issues that affect the health of both agricultural 
animals and wildlife. Such collaboration would involve working with 
CDC and FWS. According to CBP's strategic plan for 2009 through 2014, 
CBP is actively pursuing new relationships with CDC to enhance CBP's 
response to public health threats. CDC officials told us that it has 
identified a strategic goal to enhance CDC's ability to prevent, 
detect, and respond to zoonotic diseases associated with the 
importation of live animals.[Footnote 19] Furthermore, according to 
FWS's law enforcement strategic plan for 2006 through 2010, increased 
coordination will be required with agencies (such as CDC and APHIS) 
that are responsible for addressing linkages between wildlife trade 
and the cross-border spread of zoonotic and animal diseases. 

As we have previously reported, federal agencies can use their 
strategic and annual performance plans as tools to drive collaboration 
with other agencies and partners and establish complementary goals and 
strategies for achieving results.[Footnote 20] While the agencies' 
strategic planning addresses some concerns about the disease risk from 
live imported animals, it does not specify how they will collaborate 
to address the risk of disease from live animal imports. Such 
specificity is difficult, according to several experts responding to 
our survey, in part because the agencies' program priorities are based 
on different missions, constituencies, and priorities. In particular, 
experts responding to our survey 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 diseases risks posed by live animal imports. As one expert 
noted, the principal barrier to collaboration is agencies' "failure to 
take a broader view of the entire importation process," focusing 
instead on only those components of the process each agency controls 
under its statutory authority. As we have previously reported, when 
agencies do not have a compelling rationale, such as legislation, 
directives, or their perceptions of the benefits from collaboration, 
it is difficult to overcome differences in missions and priorities and 
to define and articulate a common outcome that is consistent with 
their respective agency missions.[Footnote 21] However, as the One 
Health concept recognizes, human and animal diseases are 
interconnected. In this regard, the federal agencies that are 
responsible for live animal imports appear to have a common goal--
preventing the introduction and spread of zoonotic and animal diseases 
from live animal imports. 

Joint strategies to reduce disease risk from imported live animals. 
Several of the agencies we reviewed participated in joint strategies 
to directly or indirectly address risks posed by imported live 
animals. For example, 

* APHIS, FWS, and the Department of Commerce's National Oceanic and 
Atmospheric Administration jointly developed the National Aquatic 
Animal Health Plan in 2008.[Footnote 22] Under this plan, the agencies 
are to prepare coordinated research and development strategies and 
budget recommendations to provide a framework for how the three 
agencies should develop programs for diseases that affect the health 
of aquatic animals, including finfish, crustaceans, and mollusks. 
[Footnote 23] Activities addressed in the plan include (1) defining 
pathogens of national concern; (2) preventing, controlling, and 
managing pathogens or the diseases caused by those pathogens; (3) 
describing and implementing surveillance programs; and (4) describing 
strategies for continued outreach and awareness regarding national 
aquatic animal health strategies and the plan. As of July 2010, an 
advisory committee was being formed and a surveillance network had 
been established for viral hemorrhagic septicemia, a deadly infectious 
fish disease that affects 28 susceptible species of fresh and 
saltwater fish and is a growing threat in the Great Lakes region. 
While this plan is not fully launched, experts responding to our 
survey commented that the effort has strengthened collaboration among 
international, federal, and state partners. According to the 
Department of the Interior, this plan is a model for federal 
cooperation with regard to movement of aquatic animal diseases, and it 
will be broadened to include amphibians and reptiles in the future. 

* The National Invasive Species Council's 2008-2012 National Invasive 
Species Management Plan, which is the council's primary coordination 
tool for the prevention and control of invasive species, includes an 
objective to expand the coordination of invasive species programs and 
expenditures to leverage resources. It also directs the relevant 
agencies to update the budget for federal agencies' expenditures 
concerning invasive species. The council expects to report on the 
plan's progress in October 2010. APHIS, CBP, and FWS have participated 
in the council since its inception, while CDC has recently rejoined 
the group. 

* The Aquatic Nuisance Species Task Force--an intergovernmental 
organization composed of 13 federal agencies, including FWS, APHIS, 
and the Department of Commerce's National Oceanic and Atmospheric 
Administration--is working to prevent and control aquatic nuisance 
species.[Footnote 24] The task force was established by the 
Nonindigenous Aquatic Nuisance Prevention and Control Act of 1990. 
[Footnote 25] In 2007, the task force developed a strategic plan for 
2007 through 2012 that includes an objective for analyzing and 
evaluating rapid response plans, including plans for foreign animal 
disease events, to see how they could apply to reported introductions 
of invasive species. In addition, the task force and the National 
Invasive Species Council have identified various pathways by which 
pathogens can be introduced into the country. These pathways include 
container water in which aquatic animals are transported. According to 
FWS officials, this container water can contain pathogens and, in some 
instances, importers may not disinfect the water before disposing of 
it. 

* In 2009, APHIS, CBP, CDC, and several southern California animal 
agencies formed a task force to address issues with the importation of 
puppies, such as reducing and eliminating the illegal smuggling and 
selling of dogs that are underage, in poor health, or do not have the 
required health certifications. 

These strategies are positive steps toward furthering the common goal 
of preventing disease risk from live animal imports. As we have 
previously reported, collaborating agencies need to establish 
strategies that work in concert with those of their partners or are 
joint in nature.[Footnote 26] Such strategies help in aligning the 
partner agencies' activities, core processes, and resources to 
accomplish the common outcome. In addition, all 56 experts responding 
to our survey indicated that it is very or moderately important for 
the federal agencies to collaborate to develop a coordinated national 
strategy to better align activities, processes, and resources. 

According to the experts responding to our survey, the agencies 
develop joint strategies to respond quickly to emergencies as they 
arise, but the agencies tend to develop joint strategies in reaction 
to an identified problem, rather than in anticipation of it. For 
example, one expert noted that the outbreak of monkeypox in 2003 
spread to prairie dogs and subsequently to humans. The expert, as well 
as CDC officials, commented that although this outbreak was addressed 
promptly, it might have been avoided if officials had considered the 
risk of this disease and taken appropriate actions before an outbreak 
occurred. 

Several studies and CDC officials also cited the need for a formal 
joint strategy to prevent the introduction of zoonotic and animal 
diseases, such as a comprehensive risk assessment system, and for 
responding to health risks, such as having plans and resources for 
early detection and response. Experts also commented that the 
development of such a system should focus on how live animal imports 
affect the health of humans, agricultural animals, and wildlife. 
Moreover, the 2005 National Academies of Sciences report noted that 
the animal health infrastructure does not have formal and 
comprehensive science-based risk analysis systems for anticipating 
potential challenges to animal health. In addition, experts responding 
to our survey commented that a comprehensive risk assessment system 
should be established on the basis of an analysis of imported animals 
to assess the threat that these animals pose. The experts stated that 
the components of this risk assessment system might include an 
analysis of the species' exporting country, diseases of concern, 
typical packaging and delivery times, and methods of shipment of 
concern, among other things. Suggested uses of the risk assessment 
include targeting passengers and cargo most likely to be carrying 
prohibited animals, and making decisions based on this information. 
According to experts responding to our survey, agencies could use this 
information to determine whether the importation of particular species 
from certain countries should be banned and which animals require pre-
import screening, including the increased use of disease testing and 
quarantine at the ports of entry. For example, such risk assessment 
could be similar to APHIS's process, which assesses the disease risk 
within defined regions on a consistent and scientific basis and 
evaluates the animal health status of countries or regions requesting 
approval to import live animals into the United States. 

Written procedures for ports of entry. The four agencies have written 
procedures to follow when working with other federal agencies at ports 
of entry. In particular, three of the agencies--APHIS, CBP, and FWS-- 
signed a memorandum of understanding (MOU) on forfeiture that lays out 
the specific roles and responsibilities each has for seizing, 
quarantining, and disposing of birds that are brought into the United 
States in violation of laws or regulations. In addition, APHIS and CBP 
signed an MOU that outlines the agencies' roles for entry and 
inspection of the imported animals that APHIS regulates. Two of the 
four agencies--APHIS and CBP--also have other types of written 
procedures, while CDC is developing guidance, according to CDC 
officials. Specifically, 

* APHIS has guidance that outlines the procedures and responsibilities 
that its division of Veterinary Services is to follow with CBP in 
handling legally and illegally imported pet and performing birds 
arriving as passenger baggage, from when the birds arrive at the port 
of entry until they are released to enter into the United States or 
refused entry. For example, the guidance specifies which birds are 
eligible for entry and which agency is responsible for (1) 
transferring birds to a quarantine station and (2) obtaining supplies 
for handling the birds. 

* CBP has a standard operating procedure that informs its staff at 
ports of entry of procedures to follow in handling shipments of APHIS- 
regulated live fish. Specifically, if the species has been approved by 
APHIS for import, CBP staff are to allow it to proceed; if the species 
has not already been approved, then the staff are to hold the shipment 
for Veterinary Services; if the species is not regulated by APHIS, CBP 
is to hold the shipment for USDA's Agricultural Marketing Service, 
which administers programs that facilitate the marketing of U.S. 
agricultural products. 

* CBP and APHIS have written guidance for coordinating their 
processing of live animals arriving at Canadian land border ports of 
entry. 

* CBP and APHIS have written procedures for the importation of 
livestock at four Mexican land border ports of entry and certain 
cattle at all Mexican land border ports of entry. 

* CBP has written procedures to help its port staff make appropriate 
referrals to other agencies. 

* According to CDC officials, the agency is developing internal 
standard operating procedures to distribute to its staff at ports of 
entry on CDC-regulated animals. The officials said the first such 
guidance will be on how to handle imported turtles, although the 
officials did not know when this guidance would be issued. 

While the agencies have developed some written procedures, officials 
told us that they do not have written procedures for all animal 
imports. In the absence of written procedures, agencies collaborate 
informally at ports of entry on how to handle incoming shipments. 
Specifically, according to FWS headquarters officials we spoke with, 
FWS and CDC port officials regularly coordinate on physical 
inspections of live animals they both regulate, such as nonhuman 
primates, turtles and tortoises, and bats. For example, according to 
CBP officials, when turtles are imported into the United States, CBP 
usually contacts FWS inspectors. According to FWS officials, if the 
type of turtle being imported is not banned, FWS may contact CDC or 
APHIS for inspection or further action if it believes there is 
potential for another type of violation, such as undersized turtles 
that pose a risk for Salmonella (CDC) or turtles with ticks that may 
have Heartwater infection (APHIS), a potentially fatal disease to 
cattle. In addition, officials at ports of entry from CBP and APHIS 
told us that they usually have access to an official from another 
agency to speak with if questions arise about a shipment. For example, 
CBP officials at several ports told us they contact APHIS, CDC, and 
FWS officials informally through e-mails, telephone calls, and in 
person in order to verify that procedures are being followed for live 
animal imports they regulate. Finally, some experts responding to our 
survey noted that officials at some ports have cultivated effective 
collaborative relationships. 

However, we have previously reported that by using informal 
coordination mechanisms, agencies may rely on relationships with 
individual officials to ensure effective collaboration and that these 
informal relationships could end once personnel move to their next 
assignments.[Footnote 27] Without written procedures, agencies' roles 
and responsibilities are not clearly defined. We reported that 
agencies can strengthen their commitment to work collaboratively by 
articulating their roles and responsibilities in formal documents to 
facilitate decision making. Such formal documents can include MOUs, 
interagency guidance, or interagency planning documents, signed by 
senior officials in the respective agencies. These documents can 
clarify which agencies will be responsible for particular activities, 
and how they will organize their joint and individual efforts. 

Experts responding to our survey generally agreed that uncertainty 
about agencies' roles and responsibilities for imported animals is a 
barrier, particularly for species that are (1) not regulated for 
disease risk by any agency or (2) regulated by more than one agency. 
For example, several of the experts noted that federal regulations do 
not address the risk to human and animal health posed by the 
importation of most nonnative wild animals, such as non-African 
rodents, and that where regulations do allow for the import of 
nonnative wild animals, no disease assessment is made. In addition, 
the agencies do not have written procedures for all species that are 
regulated by more than one agency, such as reptiles. For example, 
APHIS and FWS do not have a written procedure to coordinate their 
shared responsibilities for regulating reptiles--which are a source of 
Salmonella infection in humans and also carry disease-causing 
parasites. 

Leveraging resources. APHIS, CBP, CDC, and FWS have taken steps to 
leverage resources--staff and funding--to enhance their ability to 
address disease risks associated with live animal imports. For example, 

* APHIS has provided CDC headquarters with a liaison to represent 
USDA's interests on a broad range of topics, including live animal 
imports, and shares information with CDC on zoonotic diseases. CDC 
officials stated that they are currently exploring the possibility of 
establishing a DHS liaison. 

* APHIS, FWS, the U.S. Coast Guard, and the Department of Commerce's 
National Oceanic and Atmospheric Administration worked together to 
launch two national campaigns designed to help the public understand 
its role in preventing the introduction and spread of zoonotic and 
animal diseases. The first campaign, called "Stop Aquatic 
Hitchhikers," is directed toward the public who engage in aquatic 
activities to, among other things, prevent the spread of invasive 
species, zoonotic diseases, and animal pathogens. The second campaign, 
"Habitattitude," is directed toward, among others, pet owners to 
promote environmentally friendly behaviors, such as not releasing 
nonnative pets into the environment. 

While the agencies have worked together to leverage their resources, 
they do not separate the amount of funding and level of staff for live 
animal imports from other agency activities.[Footnote 28] As a result, 
they may not be able to determine whether their funding and staff are 
sufficient, and the extent to which they could be leveraged in a 
collaborative effort. Furthermore, the four agencies vary 
significantly in the extent to which they have resources for 
regulating live animal imports, according to agency officials and 
experts responding to our survey. For example, APHIS has staff who 
perform services--such as review of information provided by foreign 
governments--to support assessments of the risk of live animal imports 
into the United States. In addition, APHIS has quarantine facilities 
that inspect and test imports for diseases prior to an animal being 
released into the United States. In contrast, FWS does not have 
similar resources for assessing risk and has no quarantine facilities. 
The experts responding to our survey also noted that resource 
constraints, such as limited facilities and staff, make it difficult 
for the four agencies to devote enough time to collaboration when they 
face time constraints in completing daily tasks. The experts 
responding to our survey noted that under these conditions it is 
challenging for the agencies to collaborate. 

As we have previously reported, collaborating agencies should identify 
the human, information technology, physical, and financial resources 
needed to initiate or sustain their collaborative effort.[Footnote 29] 
By assessing their relative strengths and limitations, collaborating 
agencies can look for opportunities to obtain additional benefits that 
would not be available if they were working separately. Forty-nine of 
the 54 experts who responded to a survey question about leveraging 
resources strongly or somewhat supported leveraging APHIS resources to 
assist FWS in preventing the importation of animal diseases, and 48 
indicated that APHIS resources should be leveraged to assist CDC in 
preventing the importation of zoonotic diseases. In addition, 
according to APHIS officials we spoke with, APHIS has expertise that 
could assist FWS and CDC in assessing disease risks in other 
countries. Furthermore, 50 of 56 experts responding to our survey 
reported that it is very or moderately important for federal agencies 
to collaborate to develop a plan to maximize existing resources. 

Data sharing. As we have reported, agencies can facilitate 
collaboration by coordinating data information systems for carrying 
out shared objectives.[Footnote 30] According to CBP officials, the 
agency is developing the International Trade Data System (ITDS) within 
the Automated Commercial Environment (ACE) system. ACE will serve as a 
Web-based portal for exchanging trade information among federal 
agencies that share the responsibility for facilitating international 
trade.[Footnote 31] Currently, APHIS and FWS can access data, such as 
importer data and other related information, but cannot enter 
information into the system. In its 2009 Report to Congress on the 
International Trade Data System, CBP stated that agencies 
participating in ITDS, including APHIS, CDC, and FWS, have formed 
working groups to ensure, among other things, that data elements are 
identified and specified to the detail necessary in shipment 
information. For example, according to agency officials, a working 
group of agencies that use data on or oversee imported eggs was 
formed. While agencies do not yet have access to an integrated data 
system, agency officials and experts responding to our survey 
identified efforts to share data. For example, FWS has shared its data 
with CDC to identify possible health risks from imports of nonnative 
wildlife. In addition, according to APHIS officials, the agency is 
beginning to implement terminology in its trade database that is 
consistent with CBP's so that the agencies can share information about 
incoming shipments. 

According to CBP officials, APHIS, CDC, FWS and other agencies will 
ultimately be able to enter and retrieve information using the ACE 
system. However, CBP officials do not have a target date for when 
APHIS, CBP, CDC, and FWS would have full operational access to ACE, 
and they stated that a unified data system has been a goal since 1995; 
ITDS has been ongoing since 2006. In addition, while the agencies 
participating in ITDS have formed workgroups for some types of trade 
data, APHIS, CBP, CDC, and FWS have yet to jointly determine which 
data elements are needed for them to effectively oversee live animal 
imports, according to CBP officials. As a result, it is unclear 
whether the data in the completed system will meet interagency needs. 

Until ITDS is completed, the agencies responsible for live animal 
imports continue to collect and rely on data that are not easily 
shared. Experts responding to our survey pointed out that the agencies 
have not linked their data systems so that they can share information 
on live animal shipments, as well as track violations. In particular, 
APHIS and FWS maintain separate databases that contain information on 
shipments of animals that they regulate, and CBP maintains a database 
on all imports, including live animals. However, the three databases 
do not interface, so that agencies regulating the same shipment of 
live animals can have access to the same information at the same time. 

Experts Responding to Our Survey Identified the Need for an Entity to 
Help the Agencies Overcome Barriers to Collaboration: 

The experts responding to our survey, including federal and state 
agency officials, also generally pointed to the need for some formal 
entity to help overcome barriers to achieving their common interest in 
preventing the importation of animals that may be carrying zoonotic or 
animal diseases. For example, one expert observed that such an entity 
could help the agencies identify gaps and inconsistencies in the 
overall regulation of live animal imports for zoonotic and animal 
diseases and enable the agencies to collaborate regularly, and 53 of 
56 experts responding to our survey reported that it was very or 
moderately important for the agencies to collaborate to identify gaps 
in regulations related to live animal imports. We asked the experts 
about the extent to which they would support the creation of a 
workgroup to help the federal agencies collaborate in preventing the 
importation of animals that may be carrying zoonotic and animal 
diseases. Most of the experts responding to this question--52 of 55-- 
strongly or somewhat supported the creation of such a workgroup. (See 
app. VII for the experts' detailed responses.) 

APHIS, CDC, and FWS Have Reported Some Information on Their 
Performance on Live Animal Imports: 

APHIS and FWS routinely report information on their performance to 
oversee the importation of live animals, and CDC has reported 
performance information for one species. CBP does not report any 
performance information on live animal imports. As we have previously 
reported, agencies can use performance information to make decisions 
oriented toward improving results.[Footnote 32] In that same report, 
we stated that federal managers can use performance information to 
identify performance problems and look for solutions, develop 
approaches that improve results, and make other important management 
decisions, including those that affect future strategies, planning and 
budgeting, identifying priorities, and allocating resources. 

APHIS. APHIS has reported performance information on live animal 
imports that aligns with the goals it established in its strategic 
plan for its Veterinary Services program office.[Footnote 33] 
Specifically, APHIS measured progress on its performance goal of 
protecting the United States from the occurrence of adverse animal 
health events. For example, APHIS reported that in fiscal year 2009 it 
conducted risk assessments on the animal health status of at least 14 
foreign countries that have been denied access to U.S. import markets. 
In fiscal year 2009, APHIS conducted risk analyses in the European 
Union for the presence of exotic Newcastle disease, highly pathogenic 
avian influenza, and classical swine fever--a highly contagious virus 
that can cause high mortality rates in swine populations. 
Additionally, APHIS reported that in fiscal year 2009 it did not have 
any disease outbreaks associated with imports of animals from foreign 
regions that APHIS has reviewed for animal health status. 

CBP. CBP has not reported any performance information on live animal 
imports. As we previously noted, however, it has agencywide and field 
operations strategic plans that recognize the agency's role in 
preventing the importation of zoonotic and animal diseases.[Footnote 
34] 

CDC. In general, CDC has not developed comprehensive performance 
information on live animal imports. However, CDC has reported on 
mortality rates for one live animal import--nonhuman primates. In its 
2008 annual performance report, CDC reported that this mortality rate 
was less than 1 percent for fiscal years 2005, 2006, 2007, and 2008, 
down from about 20 percent before 1989. CDC attributed this 
improvement to its instituting facility inspections and new infection 
control requirements. In that same report, CDC reported on its 
performance goal of maintaining low mortality in nonhuman primates 
imported to the United States for science, exhibition, and educational 
purposes to, for example, reduce the potential exposure of humans to 
zoonotic diseases, such as Ebola and tuberculosis.[Footnote 35] 

FWS. FWS reported performance information dealing with live wildlife 
imports in its 2008 operational plan. In this plan, FWS reported on 
the number of injurious wildlife interdicted at international ports of 
entry and land borders (270), number of shipments that contained 
injurious wildlife (54), the number of wildlife shipments physically 
inspected (31,000), and the number of interdicted wildlife shipments 
(4,000). This information supports FWS's performance goal of 
preventing the unlawful import, export, and interstate commerce of 
foreign fish, wildlife, and plants in its law enforcement strategic 
plan for 2006 through 2010.[Footnote 36] 

Conclusions: 

With the growth in emerging zoonotic diseases, as well as the risk of 
other animal diseases in an increasing global marketplace, federal 
agencies play an increasingly important role in preventing the 
introduction of these diseases into the United States. However, as we 
found, gaps in the statutory and regulatory framework across federal 
agencies increase the risk that some live animal imports will carry 
diseases into the United States, as was the case for African rodents 
carrying monkeypox in 2003. Of the three agencies responsible for 
regulating live animal imports for disease risks--APHIS, CDC, and FWS--
only APHIS comprehensively assesses an animal's disease risk or health 
status, and APHIS has issued a strategy for expanding its role in 
overseeing nonagricultural animals. In contrast, CDC and FWS have gaps 
in their oversight of disease risks from live animal imports. CDC's 
regulations direct its focus to particular species or diseases, and 
the agency does not have a process for identifying risks from some 
emerging diseases that could be imported in live animals. FWS 
generally does not restrict the entry of imported wildlife that may 
pose disease risks and does not generally assess the disease risk or 
health status of these animals. Experts responding to our survey 
indicated that changes are needed in FWS's statutory authority, its 
regulations, or both. Recognizing such issues, APHIS, CDC, and FWS 
have separately proposed additional actions to better protect against 
disease risks from live imported animals, including actions that may 
involve pre-import screening. 

The four agencies we reviewed have collaborated to meet their 
responsibilities to some extent. They have recognized the need to work 
together in their strategic planning, formulated some joint 
strategies, developed some written procedures for collaboration, 
leveraged resources in some situations, and shared some data on live 
animal imports. However, experts responding to our survey and agency 
officials identified barriers to further collaboration in each of 
these areas. These barriers--such as different program priorities and 
unclear roles and responsibilities--are inherent when multiple 
agencies have related responsibilities. Furthermore, the agencies have 
largely incompatible data systems, and it appears that some time will 
pass before these issues are resolved or ACE is able to offer a 
conduit for data sharing among APHIS, CBP, CDC, and FWS. Because the 
agencies have not determined which data they will need, it is also 
unclear whether the data elements in the latest version of ACE will 
meet interagency needs. While these barriers pose a challenge, the 
agencies still have a common interest in preventing the introduction 
of diseases from live animal imports. Recognizing this common 
interest, the experts responding to our survey, including federal and 
state officials, reported that increased collaboration through some 
type of formal entity, such as a workgroup, is needed to help overcome 
these barriers. Furthermore, the experts and the National Academies of 
Sciences noted that the absence of a risk assessment system for 
comprehensively addressing disease risks from live animal imports 
could result in zoonotic and animal diseases entering the United 
States. 

Recommendations for Executive Action: 

To better prevent the importation of live animals carrying zoonotic 
and animal diseases and improve the responsible agencies' 
collaboration, we recommend that the Secretaries of Agriculture, 
Health and Human Services, Homeland Security, and the Interior take 
the following two actions: 

* 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: 

- 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. 

- Lay out individual agency roles and responsibilities for all live 
animal imports, including how a collaborative effort will be led. 

- Identify resources dedicated to live animal imports and leverage 
these resources to the extent possible to support the agencies' 
efforts. 

- 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. 

- 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). 

* Jointly determine, in collaboration with CBP, the data elements that 
APHIS, CDC, and FWS will need ACE to contain, so that the agencies can 
effectively oversee all live animal imports. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to USDA, the Department of Health 
and Human Services, DHS, and the Department of the Interior for their 
review and comment. In their written comments, USDA, DHS, and the 
Department of the Interior generally agreed with our findings and 
recommendations. The Department of Health and Human Services only 
provided technical comments, which we included as appropriate. 

USDA agreed with our recommendations and commented that it appreciates 
our emphasis on increasing the level of collaboration among federal 
agencies. USDA also commented that it believes a key component to 
successfully leveraging the agencies' strengths lies in finding new 
ways to approach these opportunities and that it therefore supports 
the formation of an interdepartmental steering committee for the 
oversight of animal imports as soon as possible. USDA also stated that 
in collaboration with the committee and other departments, it would 
seek to determine the need for creating additional authority, clarify 
the scope of existing authority, and implement current authority more 
efficiently through expanded memorandums of agreements or other 
interdepartmental cooperative measures. Furthermore, USDA stated that 
it would report to us on the components of a successful strategy for 
addressing our recommendations. USDA's written comments are presented 
in appendix VIII. 

DHS also agreed with our recommendations and stated that it would work 
with the other departments to gauge interest in development of a joint 
strategic implementation plan. In addition, DHS described its existing 
collaborative efforts with APHIS, CDC, and FWS, with respect to live 
animal import processes and agencies' data needs. DHS's written 
comments are presented in appendix IX, and we incorporated DHS's 
technical comments as appropriate. 

The Department of the Interior agreed with our findings and 
recommendations. In addition, the department provided the following 
comments: 

* While GAO asked experts whether a workgroup should be created to 
help federal agencies collaborate, GAO did not consider whether an 
existing body could perform this function. The use of an existing 
interagency body to serve as a coordinating entity to help federal 
agencies prevent the importation of animals that may be carrying 
zoonotic and animal diseases was not mentioned in experts' responses 
to the first round of our survey, which was the basis for asking this 
question. Placing a coordinating entity for live animal imports within 
an existing interagency body may help avoid duplication of effort. If 
the agencies determine that it is appropriate to place the 
coordinating entity for live animal imports within an existing 
interagency body, this response would be consistent with our 
recommendation. 

* The report does not refer to possible confusion that may be caused 
by multiple agencies having related authorities, and the report could 
have provided more information on agency outreach to the public. 
However, as the department noted, the issue of public outreach was not 
a central question of our review. 

* The report should emphasize the National Aquatic Animal Health Plan 
as a model for federal cooperation with regard to movement of aquatic 
animal diseases. We believe the report recognizes this plan, stating 
that it is an example of federal agencies' joint strategies to reduce 
disease risks from live animal imports, and provided more information 
on the plan's relevant efforts. 

The Department of the Interior's written comments and our responses 
are presented in appendix X. 

We are sending copies of this report to the appropriate congressional 
committees; the Secretaries of Agriculture, Health and Human Services, 
Homeland Security, and the Interior; the Director, Office of 
Management and Budget; and other interested parties. The report is 
also available at no charge on GAO's Web site at [hyperlink, 
http://www.gao.gov]. 

If you or your staff have any questions about this report, please 
contact me at (202) 512-3841 or shamesl@gao.gov. Contact points for 
our Offices of Congressional Relations and Public Affairs may be found 
on the last page of this report. Key contributors to this report are 
listed in appendix XI. 

Signed by: 

Lisa Shames: 
Director, Natural Resources and Environment: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

This report examines the (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; (2) 
extent to which the U.S. Department of Agriculture's Animal and Plant 
Health Inspection Service (APHIS), Department of Homeland Security's 
Customs and Border Protection (CBP), Department of Health and Human 
Services' Centers for Disease Control and Prevention, (CDC), and 
Department of the Interior's Fish and Wildlife Service (FWS) 
collaborate to meet their responsibilities and face barriers, if any, 
to collaboration; and (3) the performance information that the 
responsible agencies have reported on live animal imports. 

To identify potential gaps in the statutory and regulatory framework, 
we reviewed relevant statutes, including the Animal Health Protection 
Act, the Public Health Service Act, the Lacey Act, and the Endangered 
Species Act of 1973; the agencies' implementing regulations; and 
agency documents on the procedures employed to regulate the 
importation of live animals from APHIS, CBP, CDC, and FWS. We 
interviewed officials from these agencies at agency headquarters and 
ports of entry. Using information from interviews of agency officials 
and agency documents, we compared the level of inspection and review 
used by each of the agencies to regulate the importation of various 
types of animals, including mammals, birds, fish, and reptiles. In 
addition, we reviewed scientific studies on zoonotic and animal 
diseases, including studies by the National Academies of Sciences. 

We also reviewed APHIS and FWS data on the number, type, and exporting 
country of all imported animals regulated by these two agencies that 
entered the United States for fiscal years 2005 through 2009. For the 
APHIS and FWS data, we analyzed documentation related to the data and 
worked with agency officials to identify any potential data problems 
and determined that the data were sufficiently reliable for the 
purposes of providing background information in this report. We 
analyzed the APHIS and FWS data to determine the number of animals 
imported each fiscal year, the countries from which animals are most 
frequently imported, and the purposes for which animals are most 
frequently imported. 

To examine the extent to which the agencies collaborate to meet their 
responsibilities and face barriers, if any, to collaboration, we 
reviewed strategic plans, memorandums of understanding, standard 
operating practices, and other policies and protocols from each of the 
four agencies. We also reviewed joint strategies developed by 
interagency working groups, such as the National Invasive Species 
Council's management plan and the National Aquatic Animal Health Plan. 
We interviewed agency headquarters officials and agency officials at 
ports of entry, including airports in Atlanta, Georgia; Baltimore, 
Maryland; Los Angeles, California; New York, New York; and Washington, 
D.C.; and the Otay Mesa, California, and San Ysidro, California, land 
border crossings between California and Mexico, on ongoing and planned 
efforts for coordination. We obtained documentation on the allocation 
of staff resources. Finally, we assessed the agencies' collaboration 
efforts according to practices we identified that can help enhance and 
sustain collaboration among federal agencies. 

To help address the first two objectives, we conducted a two-round 
survey to identify (1) potential gaps in the current statutory and 
regulatory framework that may allow for the introduction of and spread 
of zoonotic and animal diseases, (2) how well the responsible federal 
agencies work together to meet their responsibilities, and (3) 
potential barriers to collaboration. The process we followed is based 
on GAO guidance for identifying experts for panels or other work 
requiring expertise in a specific area. We identified potential 
experts on disease risk posed by live animal imports who had primary 
employment responsibilities related to or dependent on live animal 
imports, authored peer-reviewed papers, presented at professional 
conferences, provided testimony on the subject matter to Congress, or 
were recognized by their peers as experts on live animal imports. We 
then selected experts from federal and state government, academia, 
nongovernmental organizations, and industry to obtain a broad spectrum 
of views. We conducted pretests with several survey recipients prior 
to distributing both surveys. The goals of the pretests were to ensure 
that (1) the questions were clear and unambiguous and (2) terminology 
was used correctly. The first round of the survey consisted of five 
open-ended questions (questions that solicit additional information) 
in which experts provided their opinions on gaps in the current 
statutory and regulatory framework, how well the responsible federal 
agencies work together to meet their responsibilities, and potential 
barriers to collaboration. In the first round, we received responses 
from 33 out of the 39 experts contacted, resulting in a response rate 
of about 85 percent. 

We performed a content analysis of the responses to the open-ended 
questions in order to compile a list of gaps in the statutory and 
regulatory framework, corrective actions to address those gaps, the 
effectiveness of federal agencies' collaboration, and barriers to 
federal agencies' collaboration mentioned by the experts. We used this 
list to construct the second round of survey questions. These were 
primarily closed-ended (questions with a set of answers to choose 
from). We expanded our second round of the survey to include 
additional experts recommended by those responding to our first round 
and other experts. Of the 64 experts we contacted, 56 provided 
responses, resulting in a response rate of about 88 percent in the 
second round. 

The first round of the survey was conducted from January through 
February 2010, and the second round was conducted from April through 
May 2010. To the extent possible, we followed up with experts to 
clarify their responses. The questions and aggregated responses are 
presented in appendix VII. Responses to the survey express only the 
views of the experts. 

To examine what performance information the responsible agencies 
report on live animal imports in their planning and reporting 
documents, we reviewed strategic plans, operational plans, mission 
statements, and annual performance plans and reports from APHIS, CBP, 
CDC, and FWS. Review of these documents allowed us to determine the 
extent to which these agencies set out performance goals, established 
measures to assess performance toward achieving those goals, and 
reported on the effectiveness of their efforts for activities directly 
involving live animal imports. We analyzed the extent to which each of 
the four agencies used performance objectives and measures and reports 
on the effectiveness of these activities for live animal imports. 

We conducted this performance audit from August 2009 through October 
2010, in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives. 

[End of section] 

Appendix II: Agencies' Processes for Overseeing Live Animal Imports: 

This appendix describes the processes that the U.S. Department of 
Agriculture's Animal and Plant Health Inspection Service, Department 
of Homeland Security's Customs and Border Protection, Department of 
Health and Human Services' Centers for Disease Control and Prevention, 
and Department of the Interior's Fish and Wildlife Service use for 
processing live animal imports for entry into the United States. 

APHIS: 

APHIS restricts the importation of live animals that it has determined 
may pose a disease risk to agricultural animals, such as cattle, 
horses, poultry, sheep, and swine. APHIS has developed import 
processes that depend on the level of risk associated with either the 
type of animal or country of export. APHIS has a memorandum of 
agreement with CBP whereby CBP refers live animal shipments to APHIS 
port veterinarians for inspection. APHIS port veterinarians visually 
inspect all applicable live animal shipments and review the import 
documentation, which may include a declaration of importation, 
vaccination records, and health certificates from a licensed 
veterinarian in the country of export. APHIS requires that most 
imported animals that it regulates be accompanied by a health 
certificate. A licensed veterinarian in the country of export inspects 
the animals and then signs the health certificate certifying the 
health status of the animals and whether U.S. requirements are met. 
The most common type of certification states that the animals to be 
imported were inspected and determined to be free of communicable 
disease. 

If the animals do not pass inspection, the animals are either 
quarantined and then reinspected or are refused entry. For example, if 
cattle from Mexico fail a visual inspection for tick-free status, they 
are dipped and quarantined for 10 to 14 days and then presented for a 
second inspection. If ticks are found during the second inspection, 
the cattle will be rejected, branded as rejected, and sent back to 
Mexico. For those animals that require quarantine, such as horses, 
importers are required to reserve space at either an APHIS-managed 
animal import center or an APHIS-approved private quarantine facility. 
During the quarantine, the animal undergoes disease testing. Animals 
that test positive for a regulated disease are refused entry into the 
United States. 

APHIS has established processes for specific animals and exporting 
countries. For example, for imports from Canada and Mexico, APHIS has 
established streamlined processes, such as eliminating requirements 
for permits or quarantine for some animals. Additionally, commercial 
birds--birds that are imported for resale, breeding, or public 
display--entering the United States through a land border from Canada 
are not required to have a permit or undergo quarantine, as long as 
they are accompanied by a veterinary health certificate from a 
Canadian government veterinarian. Commercial birds not imported from 
Canada are required to be quarantined and tested for avian influenza. 
In some instances, APHIS restricts the importation of animals based on 
risk. For example, APHIS restricts the import of commercial birds from 
countries with highly pathogenic avian influenza and cattle from 
countries with foot-and-mouth disease. An example of species-specific 
regulation can be found with imports of fish susceptible to Spring 
viremia of carp; such species include the common carp and goldfish. 
APHIS checks that these imports have the required documents, visually 
checks the shipments to ensure that they are not leaking or emitting 
an atypical odor, and assesses the animals' disease status if the 
shipment is chosen for inspection. 

APHIS relies on a manual process to account for and track the movement 
of the live animal imports from CBP to APHIS inspection at the border 
and to their final destination. According to agency officials, APHIS 
is developing an automated data system, the Veterinary Services 
Process Streamlining System, which is expected to replace the existing 
manual, paper-oriented process and will track live animal imports, 
exports, interstate movement of animals, and veterinary accreditation. 
According to APHIS officials, the new system became operational in 
June 2010 and will be able to track live animal imports in calendar 
year 2011. 

CBP: 

CBP assists APHIS, CDC, and FWS in enforcing their import regulations, 
has the primary authority to inspect imports, and seeks to interdict 
shipments of contraband and the illegal importation of live animals 
and other products while facilitating the flow of legal trade and 
travel. If there is a problem with a particular shipment, CBP will 
levy the appropriate fines and penalties. 

CBP requires importers to file entry documents that describe the 
merchandise, quantity, value, and exporting country, among other 
things, and a Harmonized Tariff Schedule classification, which is a 
schedule of tariffs associated with individual products. All entry 
documents must be filed before the imported goods are allowed to be 
released into U.S. commerce. For faster release, importers or their 
brokers may provide CBP with pre-arrival notification of an incoming 
shipment by submitting information on the shipment locally or 
electronically submitting information on the shipment to either CBP's 
legacy computer system, the Automated Commercial System, or the 
Automated Commercial Environment, the agency's replacement system. CBP 
screens the incoming information through its information systems to 
verify if the shipment meets the criteria or requires further 
examination or inspection. According to agency officials, if CBP then 
determines that further inspection is needed by APHIS, FWS, or CDC, 
CBP will hold the shipment, provide minimal custodial care, and 
contact the relevant agency. According to agency officials, CBP holds 
the shipment until an agency representative of the other government 
agency is available to inspect and release it. According to agency 
officials, if an agency representative is unavailable, then CBP denies 
entry of the shipment. 

CDC: 

CDC restricts the importation of live animals that it has determined 
pose a risk to public health and bans the importation of certain 
animals. All live animal imports on which CDC has placed import 
restrictions are to be visually examined by the inspecting personnel 
to ensure that the animal has no obvious signs of infectious diseases. 
Dogs and cats that show signs of infectious diseases are to be 
examined, tested, or treated by a licensed veterinarian at the owner's 
expense. According to agency officials, other CDC-regulated animals 
that show signs of infectious diseases, such as nonhuman primates, are 
inspected at an import facility. For many of the animal imports 
restricted by CDC, the agency requires a permit for importation. 
Imports that are restricted to these purposes and require a permit 
include African rodents, civets, live bats,[Footnote 37] and shipments 
of more than six turtles with a shell length of less than 4 inches. 
For nonhuman primates only, CDC requires that persons or facilities 
importing such animals be registered with CDC. If the shipment has the 
required documents, it is released to a registered importer. Nonhuman 
primates are quarantined for 31 days after entry on the importer's 
premises. No permit is required for the importation of dogs and cats. 
Generally dogs greater than 3 months of age from countries where 
rabies is present must have a valid certificate of vaccination against 
rabies signed by a licensed veterinarian showing that the dog was 
vaccinated greater than or equal to 30 days prior to import. If the 
dog is more than 3 months old and does not have a vaccination 
certificate, the dog may be admitted if the owner agrees to confine 
the dog until vaccination, vaccinate the dog within 4 days upon 
arrival at the ports of entry, and then confine the dog for an 
additional 30 days following vaccination. If the dog is more than 3 
months old and has a certificate showing a vaccination done less than 
30 days prior to arrival, the dog may be admitted if the owner signs 
an agreement to confine the dog for the balance of 30 days. If the dog 
is less than 3 months old, the dog may be admitted if the owner signs 
an agreement to confine the dog until it is 3 months old, and then 
have it vaccinated and confined for an additional 30 days. Confinement 
is defined as restricting the animal to a building or other enclosure, 
in isolation from other animals and people, except for contact 
necessary for its care. If the dog is allowed out of the enclosure, 
the owner must muzzle the dog and use a leash. After agreeing to these 
conditions, the dog is released and the agreement is forwarded to a 
CDC quarantine station. The rabies vaccination requirement does not 
apply to dogs that have been exclusively in a rabies-free area for at 
least 6 months immediately preceding arrival or since birth. Cats are 
only required to pass visual inspection. 

FWS: 

FWS has restrictions on the importation of certain wildlife. 
Specifically, FWS restricts the importation of injurious wildlife and 
threatened or endangered species and related species for which 
international trade is regulated under international agreements. 
According to agency officials, FWS inspectors work with public health 
officials and other federal inspectors at ports of entry to enforce 
wildlife regulations and ensure the safety and legality of wild animal 
imports. According to agency officials, FWS inspectors coordinate with 
the other agencies to ensure that the requirements for animals that 
are jointly regulated by FWS and APHIS and/or CDC have been met, such 
as APHIS prohibitions on hedgehogs that can transmit foot-and-mouth 
disease or CDC inspection requirements for small turtles. Importers of 
wildlife shipments generally must provide FWS with a 48-hour notice of 
the shipment's arrival. Commercial importers of wildlife must be 
licensed by FWS. 

According to agency officials, the following processes occur at the 
port of entry. The shipment is declared at the port of entry, and FWS 
reviews the accuracy and consistency of the required documents, which 
depend on species and can include declaration forms, permits, import/ 
export licenses, invoices, and packing lists. Following documentation 
review, FWS inspectors then decide if a physical inspection is 
required. Common reasons for inspecting shipments include the type of 
live animal, exporting country, importer history, intelligence on the 
shipment, outcome of documentation review, or random selection. If the 
shipment fails a physical inspection, FWS either seizes the animals 
with the violations and releases the remainder of the shipment or 
seizes the entire shipment, based on the type of animal or violation. 
If the shipment passes physical inspection and has the required 
documentation, then FWS clears the shipment. If the shipment is not 
selected for physical inspection and the required documentation is 
present, then FWS clears the shipment. 

[End of section] 

Appendix III: Data on the Number of Live Animals Imported in Recent 
Years: 

APHIS and FWS provide information on the number of live animal 
imports, the purpose of the animal import, and the country from which 
the import has been shipped for recent years. APHIS's Import Tracking 
System records the number of APHIS-regulated animals imported by 
fiscal year. FWS's Law Enforcement Management Information System 
records the number of FWS-regulated animals imported by fiscal year. 
The APHIS and FWS data systems may overlap because both agencies 
regulate some of the same species, such as certain fish and birds. CDC 
does not maintain a database on live animal imports. 

APHIS: 

Table 2 shows the number of APHIS-regulated animals imported for 
fiscal years 2005 through 2008. 

Table 2: Number of Live Animal Imports Regulated by APHIS, Fiscal 
Years 2005 through 2008: 

Type of animal: Swine; 
Fiscal year: 2005: 8,114,546; 
Fiscal year: 2006: 8,638,151; 
Fiscal year: 2007: 9,511,180; 
Fiscal year: 2008: 10,374,424. 

Type of animal: Fish; 
Fiscal year: 2005: 0[A]; 
Fiscal year: 2006: 0[A]; 
Fiscal year: 2007: 7,754,013; 
Fiscal year: 2008: 7,537,149. 

Type of animal: Koi carp; 
Fiscal year: 2005: 0[A]; 
Fiscal year: 2006: 0[A]; 
Fiscal year: 2007: 3,370,220; 
Fiscal year: 2008: 4,211,454. 

Type of animal: Poultry; 
Fiscal year: 2005: 10,412,974; 
Fiscal year: 2006: 9,396,557; 
Fiscal year: 2007: 6,312,181; 
Fiscal year: 2008: 3,769,190. 

Type of animal: Goldfish; 
Fiscal year: 2005: 0[A]; 
Fiscal year: 2006: 0[A]; 
Fiscal year: 2007: 2,086,047; 
Fiscal year: 2008: 3,540,739. 

Type of animal: Cattle; 
Fiscal year: 2005: 1,506,998; 
Fiscal year: 2006: 2,374,679; 
Fiscal year: 2007: 2,291,255; 
Fiscal year: 2008: 2,494,891. 

Type of animal: Bison; 
Fiscal year: 2005: 906; 
Fiscal year: 2006: 12,025; 
Fiscal year: 2007: 19,307; 
Fiscal year: 2008: 27,586. 

Type of animal: Horses; 
Fiscal year: 2005: 43,553; 
Fiscal year: 2006: 37,426; 
Fiscal year: 2007: 30,202; 
Fiscal year: 2008: 26,301. 

Type of animal: Ornamental fish; 
Fiscal year: 2005: 0[A]; 
Fiscal year: 2006: 0[A]; 
Fiscal year: 2007: 498,456; 
Fiscal year: 2008: 7,254. 

Type of animal: Other[B]; 
Fiscal year: 2005: 3,225; 
Fiscal year: 2006: 7,132; 
Fiscal year: 2007: 4,215; 
Fiscal year: 2008: 1,949. 

Type of animal: Unknown[C]; 
Fiscal year: 2005: 70,496; 
Fiscal year: 2006: 20,686; 
Fiscal year: 2007: 10,426; 
Fiscal year: 2008: 1,852. 

Type of animal: Total; 
Fiscal year: 2005: 20,152,698; 
Fiscal year: 2006: 20,486,656; 
Fiscal year: 2007: 31,887,502; 
Fiscal year: 2008: 31,992,789. 

Source: APHIS Import Tracking System. 

Note: At the time of our review, fiscal year 2008 was the last year 
for which verified data were available. 

[A] As discussed below, the agency began regulating the import of fish 
in 2006. 

[B] Other animals include sheep, goats, elk, deer, moose, caribou, 
reindeer, llamas, alpacas, pet birds, zoological animals, camels, 
exotics, and reptiles. 

[C] According to APHIS, data in this category could not be identified 
or verified at the species level. 

[End of table] 

Prior to fiscal year 2007--when APHIS began recording large numbers of 
fish imports--APHIS recorded that imports of live swine, poultry, and 
cattle were about 99 percent of its regulated live animal imports. 
About 94 percent of these imports came from Canada, with the remainder 
generally coming from Mexico. These animals were primarily imported 
for slaughter plants or farms. By fiscal year 2008, imports of fish 
represented about half of the total number of APHIS live animal 
imports, with the largest suppliers of these animals, including China, 
Malaysia, Hong Kong, the United Kingdom, Thailand, and Singapore, 
primarily importing these fish for commercial purposes. According to 
agency officials, APHIS reported large numbers of fish beginning in 
fiscal year 2007 because of a new regulation on the import of fish, 
which previously were not required to have APHIS permits and thus were 
not counted by APHIS. In August 2006, APHIS issued regulations 
requiring importers of species of fish that are susceptible to Spring 
viremia of carp, a contagious, fatal viral disease, to obtain an APHIS 
permit prior to importation into the United States. 

FWS: 

Table 3 shows the number of FWS-regulated live wildlife imported from 
2005 through 2009. FWS officials attributed the decline of live animal 
imports in fiscal year 2009 in part to the recession, as well as the 
increase in FWS user fees, which included new handling fees. 

Table 3: Number of Live Animal Imports Regulated by FWS, Fiscal Years 
2005 through 2009: 

Type of animal[A]: Crustaceans; 
Fiscal year: 2005: 11,021,121; 
Fiscal year: 2006: 12,457,692; 
Fiscal year: 2007: 12,649,912; 
Fiscal year: 2008: 10,097,441; 
Fiscal year: 2009: 9,232,677. 

Type of animal[A]: Amphibians; 
Fiscal year: 2005: 5,360,493; 
Fiscal year: 2006: 5,050,831; 
Fiscal year: 2007: 4,594,679; 
Fiscal year: 2008: 4,164,832; 
Fiscal year: 2009: 3,575,934. 

Type of animal[A]: Mollusks; 
Fiscal year: 2005: 1,013,423; 
Fiscal year: 2006: 1,145,732; 
Fiscal year: 2007: 1,438,519; 
Fiscal year: 2008: 1,950,384; 
Fiscal year: 2009: 1,444,248. 

Type of animal[A]: Insects; 
Fiscal year: 2005: 1,037,268; 
Fiscal year: 2006: 971,078; 
Fiscal year: 2007: 1,105,246; 
Fiscal year: 2008: 1,714,148; 
Fiscal year: 2009: 1,208,392. 

Type of animal[A]: Reptiles; 
Fiscal year: 2005: 1,591,606; 
Fiscal year: 2006: 1,440,749; 
Fiscal year: 2007: 1,469,399; 
Fiscal year: 2008: 1,187,679; 
Fiscal year: 2009: 946,243. 

Type of animal[A]: Corals; 
Fiscal year: 2005: 711,747; 
Fiscal year: 2006: 699,348; 
Fiscal year: 2007: 980,559; 
Fiscal year: 2008: 840,657; 
Fiscal year: 2009: 768,931. 

Type of animal[A]: Mammals; 
Fiscal year: 2005: 78,488; 
Fiscal year: 2006: 115,910; 
Fiscal year: 2007: 237,767; 
Fiscal year: 2008: 591,322; 
Fiscal year: 2009: 289,843. 

Type of animal[A]: Spiders; 
Fiscal year: 2005: 215,289; 
Fiscal year: 2006: 241,627; 
Fiscal year: 2007: 224,872; 
Fiscal year: 2008: 203,170; 
Fiscal year: 2009: 175,505. 

Type of animal[A]: Worms; 
Fiscal year: 2005: 1,810,855; 
Fiscal year: 2006: 839,689; 
Fiscal year: 2007: 322,656; 
Fiscal year: 2008: 119,268; 
Fiscal year: 2009: 162,412. 

Type of animal[A]: Birds; 
Fiscal year: 2005: 299,983; 
Fiscal year: 2006: 225,244; 
Fiscal year: 2007: 246,710; 
Fiscal year: 2008: 240,250; 
Fiscal year: 2009: 159,795. 

Type of animal[A]: Echinoderms (e.g., starfish, sea urchin); 
Fiscal year: 2005: 29,553; 
Fiscal year: 2006: 48,156; 
Fiscal year: 2007: 22,626; 
Fiscal year: 2008: 40,111; 
Fiscal year: 2009: 133,924. 

Type of animal[A]: Miscellaneous[B]; 
Fiscal year: 2005: 2,818,367; 
Fiscal year: 2006: 2,695,776; 
Fiscal year: 2007: 2,087,462; 
Fiscal year: 2008: 2,097,805; 
Fiscal year: 2009: 1,649,071. 

Type of animal[A]: Unknown[C]; 
Fiscal year: 2005: 900; 
Fiscal year: 2006: 246; 
Fiscal year: 2007: 116; 
Fiscal year: 2008: 42; 
Fiscal year: 2009: 145. 

Type of animal[A]: Subtotal; 
Fiscal year: 2005: 25,989,093; 
Fiscal year: 2006: 25,932,078; 
Fiscal year: 2007: 25,380,523; 
Fiscal year: 2008: 23,247,109; 
Fiscal year: 2009: 19,747,120. 

Type of animal[A]: Fish; 
Fiscal year: 2005: 205,539,504; 
Fiscal year: 2006: 227,125,679; 
Fiscal year: 2007: 200,289,950; 
Fiscal year: 2008: 181,531,235; 
Fiscal year: 2009: 157,377,941. 

Type of animal[A]: Total; 
Fiscal year: 2005: 231,528,597; 
Fiscal year: 2006: 253,057,757; 
Fiscal year: 2007: 225,670,473; 
Fiscal year: 2008: 204,778,344; 
Fiscal year: 2009: 177,125,061. 

Source: FWS's Law Enforcement Management Information System. 

Note: This table does not include data for imported animals that were 
recorded by weight rather than number. FWS recorded some shipments 
that were not individually counted in fiscal years 2005 through 2009, 
and those shipments that were measured by weight included the 
following species: fish, crustaceans, echinoderms, mollusks, 
miscellaneous, amphibians, insects, annelids, corals, mammals, 
arachnids, and reptiles. 

[A] Animals are grouped by animal class. Animal classes are scientific 
groupings of animals based on common characteristics. 

[B] According to FWS, the agency uses this category for grouping 
multiple species together or when all that is known is the class. 

[C] This category represents imports of multiple nonprotected species. 

[End of table] 

In fiscal year 2009, wildlife imports came from a variety of countries 
and were primarily imported for commercial purposes. For example, 
Singapore and Thailand were the leading exporters for fish, Haiti and 
Taiwan for crustaceans, amphibians from Taiwan, mollusks from 
Indonesia and the Philippines, insects from Costa Rica, reptiles from 
Vietnam, corals from Indonesia, mammals from Canada and the 
Netherlands, birds from Senegal, spiders from Ghana, and worms from 
Canada and France. 

Although mammals represent a small percentage of FWS-recorded imports 
of live wildlife excluding imports of fish--ranging from 0.3 percent 
in 2005 to 2.5 percent in 2008--they are commonly associated with the 
spread of zoonotic diseases. The following describes FWS-regulated 
imported mammals and their associated disease risks, according to FWS 
data for fiscal year 2009: 

* Bovines, including bison and water buffalo, with 201,561 imported 
primarily from Canada for commercial purposes. The animal family that 
includes bovines has been found to harbor 15 zoonotic diseases, 
including Ebola and Rift Valley fever. 

* Mice, rats, and gerbils, with 141,060 imported primarily from the 
Netherlands for commercial purposes. The animal family that includes 
these animals has been found to harbor 21 zoonotic diseases. 

* Old world monkeys, with 24,106 imported primarily from China for 
biomedical research. The animal family that includes these animals has 
been found to harbor 13 zoonotic diseases, including yellow fever and 
Marburg disease. 

* Chinchillas, with 4,302 imported primarily from Canada and the 
Netherlands for commercial purposes. The animal family that includes 
chinchillas has been found to harbor 2 zoonotic diseases: rabies and 
monkeypox. 

[End of section] 

Appendix IV: Examples of Recent U.S. Animal Disease Outbreaks Causing 
Animal, Human, and Environmental or Economic Harm: 

Infectious agent: Bovine spongiform; encephalopathy; (mad cow disease); 
United States outbreaks: Three cases of bovine spongiform 
encephalopathy in cattle have been identified from 2003 through 2006, 
one of which was caused by an imported cow; 
Mode of transmission: Transmitted to cattle through contaminated feed 
containing, for example, the spinal cord or brain matter of infected 
cattle. Transmitted to humans through eating the contaminated meat of 
infected cattle; 
Animal and human harm: Bovine spongiform encephalopathy is transmitted 
to humans causing a variant form of Creutzfeldt-Jakob disease; 
From 2003 through 2007, three fatal variant Creutzfeldt-Jakob cases 
occurred in two United Kingdom citizens and one Saudi Arabian citizen 
who were residing in the United States. They were likely exposed to 
bovine spongiform encephalopathy in their native countries; 
Environmental or economic harm: An estimated $11 billion in losses in 
U.S. exports resulted from bovine spongiform encephalopathy-related 
restrictions in the United States. 

Infectious agent: Chytridiomycosis; 
United States outbreaks: May have been introduced through a shipment 
to northern California in the late 1950s or early 1960s; Has been 
linked with serious declines almost everywhere that amphibians are 
present, including North America; 
Mode of transmission: Caused by an aquatic fungal pathogen, 
Batrachochytrium dendrobatidis (Bd); Bd appears to be spreading 
through the international amphibian trade, the international pet 
trade, the bait trade, and inadvertently in produce; 
Animal and human harm: Bd is an emerging infectious disease of 
amphibians, especially frogs; 
Environmental or economic harm: Bd is responsible for a large disease- 
caused loss of biodiversity. 

Infectious agent: Exotic Newcastle disease; 
United States outbreaks: An outbreak of the disease occurred in the 
western United States from September 2002 through September 2003; 
Mode of transmission: Transmitted by infected birds, contaminated 
people, and contaminated equipment to other birds; 
Animal and human harm: The 2002-through-2003 outbreak resulted in 
nearly 4.5 million birds destroyed; Humans can be infected with 
Newcastle virus and infection generally causes conjunctivitis (i.e., 
pink eye). Most often, those affected are workers in the poultry 
industry or laboratory technicians who handle the virus; 
Environmental or economic harm: As a result of the 2002-through-2003 
outbreak, over 50 countries imposed some form of trade restriction 
against United States poultry exports. The outbreak caused an 
estimated $395 million loss in direct and indirect trade. Federal 
dollars allocated to the eradication effort are estimated at $138.9 
million. 

Infectious agent: Highly pathogenic avian influenza; 
United States outbreaks: In February 2004, an outbreak of highly 
pathogenic avian influenza was detected and reported in a flock of 
7,000 chickens in south-central Texas. This was the first outbreak of 
highly pathogenic avian influenza in 20 years; Note: Some strains of 
highly pathogenic avian influenza do not have the same implication for 
human health. The highly pathogenic avian influenza strain in the 
Texas outbreak only affects poultry, not humans; 
Mode of transmission: Transmitted by infected birds; 
Animal and human harm: By mid-2005 in southeast Asia, more than 140 
million birds had died or been destroyed; Despite control measures, 
the disease continues to spread, resulting in animal and human 
fatalities (more than half of the human cases have been fatal). Many 
in the scientific community are concerned about a global pandemic of 
human avian influenza; 
Environmental or economic harm: By mid-2005 in southeast Asia, losses 
to the poultry industry were estimated to be in excess of $10 billion. 

Infectious agent: Viral hemorrhagic septicemia; 
United States outbreaks: First outbreak occurred in 1988 and affected 
marine fish in the Pacific Northwest; Outbreaks of a more virulent 
strain of viral hemorrhagic septicemia began occurring in United 
States waters of the Great Lakes in 2006; 
Mode of transmission: Transmission is by infected fish, tissues from 
infected fish, and water that has contained infected fish; Ballast 
water is considered the most likely original vector; 
Animal and human harm: Viral hemorrhagic septicemia is known to cause 
fish mortality, particularly for rainbow trout, turbot, and herring, 
in short periods of time; APHIS currently lists 28 susceptible species; 
Environmental or economic harm: Although large numbers of fish loss 
have been reported, long-term economic loses are unclear; To meet 
federal and state regulations, aquaculture facilities incur additional 
testing expenses to ensure their fish are healthy. 

Infectious agent: West Nile virus; 
United States outbreaks: Emerged in 1999 and has been found throughout 
the continental United States; 
Mode of transmission: Transmitted by mosquitoes and can cause 
encephalitis in humans; 
Animal and human harm: West Nile virus in the United States has 
infected 29,766 people, resulting in 1,166 fatalities from 1999 
through August 10, 2010; 
Environmental or economic harm: The estimated economic impact of the 
disease in the United States from 1999 through 2007 was $400 million. 

Source: GAO analysis of literature. 

Note: CDC estimates that for every case of zoonotic disease reported 
to CDC, there are likely hundreds to thousands more cases that go 
unreported. For CDC to become aware of a zoonotic disease, the 
following must occur: (1) The infected person has to have contact with 
an animal and know that it was imported; (2) the person has to become 
ill enough to go to a doctor and remember to tell the doctor that he 
was exposed to a certain animal; (3) the doctor has to request a lab 
test, and if a cause of disease is found, the doctor has to know if it 
is a reportable disease in his state; (4) the state has to report the 
findings to CDC in a timely manner so that an investigation can be 
done to determine the source of the infection. 

[End of table] 

[End of section] 

Appendix V: Overview of Federal Agencies' Disease Risk Screening for 
Selected Types of Imported Animals: 

Type of imported animal: Cattle from Canada or Mexico[B]; 
Regulating agency[A]: APHIS; 
Disease testing at quarantine facility: [C]; 
Assessment by U.S. agency of disease presence in exporting country: 
APHIS; 
Health certificate from exporting country: APHIS; 
Visual inspection at U.S. port of entry for disease: APHIS. 

Type of imported animal: Cattle not from Canada or Mexico; 
Regulating agency[A]: APHIS; 
Disease testing at quarantine facility: APHIS; 
Assessment by U.S. agency of disease presence in exporting country: 
APHIS; 
Health certificate from exporting country: APHIS; 
Visual inspection at U.S. port of entry for disease: APHIS[D]. 

Type of imported animal: Canadian horses; 
Regulating agency[A]: APHIS; 
Disease testing at quarantine facility: [C]; 
Assessment by U.S. agency of disease presence in exporting country: 
APHIS; 
Health certificate from exporting country: APHIS; 
Visual inspection at U.S. port of entry for disease: APHIS. 

Type of imported animal: Horses not from Canada; 
Regulating agency[A]: APHIS; 
Disease testing at quarantine facility: APHIS; 
Assessment by U.S. agency of disease presence in exporting country: 
APHIS; 
Health certificate from exporting country: APHIS; 
Visual inspection at U.S. port of entry for disease: APHIS. 

Type of imported animal: Domesticated dogs; 
Regulating agency[A]: APHIS; CDC; 
Disease testing at quarantine facility: APHIS[E]; 
Assessment by U.S. agency of disease presence in exporting country: 
APHIS; CDC; 
Health certificate from exporting country: APHIS[F]; CDC[G]; 
Visual inspection at U.S. port of entry for disease: APHIS[E]; CDC. 

Type of imported animal: Commercial birds not from Canada; 
Regulating agency[A]: APHIS; FWS; 
Disease testing at quarantine facility: APHIS; 
Assessment by U.S. agency of disease presence in exporting country: 
APHIS; 
Health certificate from exporting country: APHIS; 
Visual inspection at U.S. port of entry for disease: APHIS. 

Type of imported animal: Commercial birds from Canada; 
Regulating agency[A]: APHIS; FWS; 
Disease testing at quarantine facility: [C]; 
Assessment by U.S. agency of disease presence in exporting country: 
APHIS; 
Health certificate from exporting country: APHIS; 
Visual inspection at U.S. port of entry for disease: APHIS. 

Type of imported animal: Turtles; 
Regulating agency[A]: APHIS[H]; CDC[I]; FWS; 
Disease testing at quarantine facility: [C]; 
Assessment by U.S. agency of disease presence in exporting country: 
[C]; 
Health certificate from exporting country: [C]; 
Visual inspection at U.S. port of entry for disease: FWS[I]. 

Type of imported animal: Reptiles, not including turtles; 
Regulating agency[A]: FWS; 
Disease testing at quarantine facility: [C]; 
Assessment by U.S. agency of disease presence in exporting country: 
[C]; 
Health certificate from exporting country: [C]; 
Visual inspection at U.S. port of entry for disease: [C]. 

Type of imported animal: Rodents from Africa; 
Regulating agency[A]: CDC; FWS; 
Disease testing at quarantine facility: [C]; 
Assessment by U.S. agency of disease presence in exporting country: 
CDC[K]; 
Health certificate from exporting country: [C]; 
Visual inspection at U.S. port of entry for disease: FWS[L]. 

Type of imported animal: Rodents not from Africa; 
Regulating agency[A]: FWS; 
Disease testing at quarantine facility: [C]; 
Assessment by U.S. agency of disease presence in exporting country: 
[C]; 
Health certificate from exporting country: [C]; 
Visual inspection at U.S. port of entry for disease: [C]. 

Type of imported animal: Amphibians; 
Regulating agency[A]: FWS; 
Disease testing at quarantine facility: [C]; 
Assessment by U.S. agency of disease presence in exporting country: 
[C]; 
Health certificate from exporting country: [C]; 
Visual inspection at U.S. port of entry for disease: [C]. 

Source: APHIS, CDC, and FWS regulations and guidance and discussions 
with agency officials. 

Note: FWS does not screen shipments of live animals for disease risk, 
with the exception of imported salmon. FWS requires that all carriers 
transporting wild mammals and birds to the United States have a 
certificate of veterinary medical inspection signed by a veterinarian. 

[A] CBP does not develop regulations for how to import an animal, so 
it is not included in the list of regulating agencies. 

[B] Feeder cattle from Mexico, which are cattle imported for the 
purpose of feeding for a period of time prior to slaughter, are tested 
for tuberculosis and brucellosis and checked for ticks prior to entry 
into the United States. Breeding cattle are tested for tuberculosis 
and brucellosis and checked for ticks. 

[C] APHIS, FWS, and CDC do not perform this type of screening for this 
imported animal. 

[D] Cattle are visually inspected at the quarantine facility. 

[E] APHIS requires that dogs imported to handle livestock must be 
inspected and quarantined at the ports of entry and tested for 
tapeworm. 

[F] APHIS requires that dogs imported from countries where screwworm 
is thought to exist have a health certificate from a veterinarian from 
the exporting country stating that the dog is free from screwworm. 

[G] CDC generally requires certification of rabies vaccination for 
dogs imported from countries identified by CDC as places where rabies 
is present. 

[H] APHIS does not have any regulations in place to assess the disease 
risk of turtle imports. APHIS prohibits the importation of the 
following types of turtles: leopard tortoise, African spurred 
tortoise, and Bell's hingeback tortoise. 

[I] CDC does not have any regulations in place to assess the disease 
risk of turtle imports. CDC restricts the import of turtles with a 
carapace shell length of 4 inches or less to less than 7; it requires 
a permit for a shipment of more than six turtles that will be used for 
science, exhibition, or education. 

[J] FWS does not screen all shipments of turtles for disease risk. It 
requires 48-hour notification of the shipment and shipment declaration 
forms, which provide a description of the animals in the shipment. FWS 
visually inspects some live animal shipments (e.g., 18 percent in 
fiscal year 2008). The purpose of the inspection is to determine 
whether the animals are on the Lacey Act's list of prohibited 
injurious animals or are prohibited from entry based on the Endangered 
Species Act of 1973 and international agreements to regulate 
threatened or endangered species, such as the Convention on 
International Trade in Endangered Species of Wild Fauna and Flora--as 
well as to assess whether the turtles are in compliance with APHIS and 
CDC regulations. 

[K] In 2003, CDC restricted the importation of rodents from Africa. 

[L] FWS inspects shipments of rodents from Africa to assess whether 
the rodents are in compliance with CDC regulations. 

[End of table] 

[End of section] 

Appendix VI: Experts Responding to Our Survey on Live Animal Imports: 

This appendix provides the affiliations of federal and state 
government, academics, nongovernmental, and industry experts who 
completed one or both rounds of a two-round survey from January 2010 
to May 2010 to identify potential gaps in the current statutory and 
regulatory framework, how well the responsible federal agencies work 
together to meet their responsibilities, and appropriate corrective 
actions. 

* Biological Scientist, Centers for Epidemiology and Animal Health, 
Veterinary Services, U.S. Animal and Plant Health Inspection Service: 

* Senior Advisor for Science and Policy, U.S. Department of Homeland 
Security: 

* State Public Health Veterinarian and Assistant State Epidemiologist, 
Infectious Disease Epidemiology, Office of Public Health, Louisiana 
Department of Health and Hospitals: 

* Director, Veterinary Regulatory Support, Plant Protection and 
Quarantine, U.S. Animal and Plant Health Inspection Service: 

* Veterinary Medical Officer, Western Region Import and Export 
Coordinator, Veterinary Services, U.S. Animal and Plant Health 
Inspection Service: 

* Professor, Department of Veterinary Pathology, College of Veterinary 
Medicine, University of Georgia: 

* Policy Director, Global Invasive Species Programme: 

* Director, Science Center, Natural Resources Defense Council: 

* Virginia M. Ullman Professor, Arizona State University: 

* Executive Vice President and General Director for Living 
Institutions, Wildlife Conservation Society: 

* Director of Regulatory Affairs, Taylor Shellfish Company, Inc. 

* Veterinary Medical Officer, National Wildlife Health Center, U.S. 
Geological Survey: 

* National Director, Veterinary Medicine, PETCO Animal Supplies, Inc. 

* Senior Veterinarian, Los Angeles County Department of Public Health, 
Veterinary Public Health and Rabies Control Program: 

* Associate Vice President, Conservation Medicine, Wildlife Trust: 

* Professor and Director, Southeastern Cooperative Wildlife Disease 
Study, University of Georgia: 

* Chief, Division of Management Authority, International Affairs 
Program, U.S. Fish and Wildlife Service: 

* Special Agent in Charge, Office of Law Enforcement, U.S. Fish and 
Wildlife Service: 

* Professor of Epidemiology, Department of Pathobiological Sciences, 
School of Veterinary Medicine, University of Wisconsin-Madison: 

* Branch Chief, Convention on International Trade in Endangered 
Species Operations, Division of Management Authority, U.S. Fish and 
Wildlife Service: 

* Executive Director, Global Initiative for Food Systems Leadership 
and Professor, School of Public Health and College of Veterinary 
Medicine, University of Minnesota: 

* Director, National Center for Import and Export, Veterinary 
Services, U.S. Animal and Plant Health Inspection Service: 

* Director of International Conservation, Defenders of Wildlife: 

* Senior Wildlife Veterinarian and Supervisor, California Department 
of Fish and Game: 

* Fish and Wildlife Biologist, Branch of Aquatic Invasive Species, 
U.S. Fish and Wildlife Service: 

* Wildlife Health Specialist, Arizona Game and Fish Department: 

* Professor of International Health and of Medicine, Boston University: 

* Public Health Veterinarian, National Association of State Public 
Health Veterinarians: 

* Associate Professor of Biology, and Director, Program in Sustainable 
Development and Conservation Biology, Department of Biology, 
University of Maryland: 

* Branch Chief, Quarantine and Border Health Services Branch, U.S. 
Centers for Disease Control and Prevention: 

* Chief, Branch of Aquatic Invasive Species, U.S. Fish and Wildlife 
Service: 

* Professor, School for Global Animal Health, Executive Director, 
Washington Animal Disease Diagnostic Laboratory, Director, Animal 
Health Research Center, Washington State University College of 
Veterinary Medicine: 

* Professor of Pathology, Western University of Health Sciences 
College of Veterinary Medicine: 

* Vice President of Veterinary Services, Chicago Zoological Society: 

* Branch Chief, Agriculture Production, Office of Health Affairs, U.S. 
Department of Homeland Security: 

* Assistant Director, Live Animal Imports, National Center for Import 
and Export, U.S. Animal and Plant Health Inspection Service: 

* Chairman, Health and Regulatory Committee, American Horse Council: 

* Amphibian and Reptile Coordinator, Association of Fish and Wildlife 
Agencies: 

* Research Branch Chief, Arizona Game and Fish Department: 

* Wildlife Veterinary Specialist, Wildlife Disease Laboratory, 
Michigan Department of Natural Resources and Environment: 

* Vice President, Government Affairs, Association of Zoos and 
Aquariums: 

* Executive Director, Association of American Veterinary Medical 
Colleges: 

* Epidemiologist, (formerly) Johns Hopkins Bloomberg School of Public 
Health, Johns Hopkins University: 

* Operations Specialist, Delta Air Lines, Inc. 

* Manager, Live Animals and Perishables, Special Cargo Standards, 
International Air Transport Association: 

* Coordinator, Wildlife Management Division, Arizona Game and Fish 
Department: 

* Postdoctoral Research Fellow, Center for Forest Sustainability, 
School of Forestry and Wildlife Sciences, Department of Biological 
Sciences, Auburn University: 

* General Manager, Koppert Biological Systems, Inc. 

* Supervisor, Wildlife Health Section, Wildlife Disease Laboratory, 
Michigan Department of Natural Resources: 

* Eastern Region Import Export Coordinator, Veterinary Services, U.S. 
Animal and Plant Health Inspection Service: 

* Assistant Director Zoonotic, Influenza and Vector Borne Disease 
Unit, Bureau of Communicable Disease, New York City Department of 
Health and Mental Hygiene: 

* Assistant Research Professor, Ecology and Evolutionary Biology, 
Brown University: 

* Assistant Director for Field Programs, Global Health Program, 
Wildlife Conservation Society: 

* Outreach Coordinator, Fisheries and Habitat Conservation, Branch of 
Invasive Species, U.S. Fish and Wildlife Service: 

* State Public Health Veterinarian and Section Manager, Zoonoses and 
Special Projects Section, Michigan Department of Community Health: 

* Acting Director Agriculture Policy and Planning, Agriculture 
Programs and Trade Liaison, Office of Field Operations, U. S. Customs 
and Border Protection: 

* Vice President, Conservation and Science, Lincoln Park Zoo: 

* Director, Planning, Finance, and Strategy Staff, Veterinary 
Services, U.S. Animal and Plant Health Inspection Service: 

* Corporate Vice President, Veterinary and Professional Services, 
Charles River Laboratories, Inc. 

* Public Health Veterinarian, Zoonotic and Vector-borne Disease 
Program, Office of Environmental Health and Safety, Washington State 
Department of Health: 

[End of section] 

Appendix VII: GAO Survey Questions and Responses: 

Expert Survey: Live Animal Imports into the United States and the 
Spread of Animal and Zoonotic Diseases: 

We conducted a two-round survey to identify (1) potential gaps in the 
current statutory and regulatory framework that may allow for the 
introduction of and spread of zoonotic and animal diseases, (2) how 
well the responsible federal agencies work together to meet their 
responsibilities, and (3) potential barriers to collaboration. We 
identified potential experts on disease risk posed by live animal 
imports who had primary employment responsibilities related to or 
dependent on live animal imports, authored peer-reviewed papers, 
presented at professional conferences, provided testimony on the 
subject matter to Congress, or were recognized by their peers as 
experts on live animal imports. We then selected experts from federal 
and state government, academia, nongovernmental organizations, and 
industry to obtain a broad spectrum of views. The first round of the 
survey consisted of five open-ended questions (questions that solicit 
additional information) in which experts provided their opinions on 
gaps in the current statutory and regulatory framework, how well the 
responsible federal agencies work together to meet their 
responsibilities, and potential barriers to collaboration. In the 
first round, we received responses from 33 out of the 39 experts 
contacted, resulting in a response rate of about 85 percent. We 
performed a content analysis of the responses to the open-ended 
questions in order to compile a list of gaps in the statutory and 
regulatory framework, corrective actions to address those gaps, the 
effectiveness of federal agencies' collaboration, and barriers to 
federal agencies' collaboration mentioned by the experts. We used this 
list to construct the second round of survey questions. These were 
primarily closed-ended (questions with a set of answers to choose 
from). We expanded our second round of the survey to include 
additional experts recommended by those responding to our first round 
and other experts. Of the 64 experts we contacted, 56 provided 
responses, resulting in a response rate of about 88 percent in the 
second round. The first round of the survey was conducted from January 
through February 2010, and the second round was conducted from April 
through May 2010. While this appendix displays only the quantitative, 
closed-ended responses, we also relied on the responses to the 
qualitative, open-ended questions to inform our findings in this 
report. The views expressed by the experts responding to our surveys 
do not necessarily represent the views of GAO. 

Round One Questions: 

1. What weaknesses or gaps, if any, do you feel exist in the statutory 
and regulatory framework governing live animal imports with respect to 
preventing the introduction of zoonotic and animal diseases? 

2. What corrective actions should be taken to address these weaknesses 
or gaps? 

3. Federal agencies responsible for live animal imports include Animal 
and Plant Health Inspection Service (APHIS), Centers for Disease 
Control and Prevention (CDC), Customs and Border Protection (CBP), and 
Fish and Wildlife Service (FWS). How effectively (or not) do the 
federal agencies collaborate to meet their responsibilities? 

4. What barriers exist for collaboration among federal agencies? 

5. During our site visits with regulatory authorities, we heard about 
their goal to facilitate efficient cargo and passenger import 
processing while preventing prohibited animals and animal products to 
be imported into the United States. What is the best way to ensure 
that statutes and regulations prevent importation of zoonotic and 
animal diseases without impeding commerce and passenger travel? 

6. If you consulted with others within your agency, firm, or 
organization when answering the questions, how many others did you 
consult? 

Your Background: 

7. Please briefly describe your expertise. Include professional 
credentials, membership and roles in professional associations, titles 
of publications, congressional testimonies, primary employment 
responsibilities related to or dependent on live animal imports, etc. 

Round Two Questions and Responses: 

Section 1: Participant Status: 

1. What is your full name? 

2. What is your title? 

3. What is the name of your organization? 

4. What is your telephone number? 

5. What is your e-mail address? 

6. Did you complete a survey in round 1 or are you a new participant 
in Round 2? 

* I completed a survey in Round #1 - Skip to question #8: 

* I am a new participant in Round #2 - Continue to question #7: 

7. What is your background or expertise related to live animal imports? 

Section 2: Animal and Plant Health Inspection Service (APHIS): 

8. Based on your knowledge of APHIS's statutory and regulatory 
framework, do you believe changes Are or Are Not needed to prevent the 
importation of zoonotic and animals diseases? 

Response: Changes are needed; 
Number of responses: 53. 

Response: Changes are not needed, Skip To Question #10; 
Number of responses: 2. 

Response: No response; 
Number of responses: 1. 

9. How much, if at all, do you support or oppose the following 
potential changes for APHIS to prevent the importation of zoonotic and 
animal diseases? 

Potential change: A-APHIS resources should be leveraged with FWS to 
prevent importation of animal diseases; 
Strongly support: 39; 
Somewhat support: 10; 
Neither support nor oppose: 0; 
Somewhat oppose: 1; 
Strongly oppose: 2; 
Don't know: 2; 
No response: 2. 

Potential change: B-APHIS resources should be leveraged with CDC to 
prevent importation of zoonotic diseases; 
Strongly support: 37; 
Somewhat support: 11; 
Neither support nor oppose: 2; 
Somewhat oppose: 0; 
Strongly oppose: 2; 
Don't know: 2; 
No response: 2. 

Potential change: C-APHIS should have the authority to consider 
wildlife disease risk as part of its existing risk assessment 
process[A]; 
Strongly support: 36; 
Somewhat support: 13; 
Neither support nor oppose: 3; 
Somewhat oppose: 1; 
Strongly oppose: 0; 
Don't know: 2; 
No response: 2. 

[A] One expert provided two responses, "Strongly support" and 
"Somewhat support" for question 9C. 

[End of table] 

Section 3: Centers for Disease Control and Prevention (CDC): 

10. Based on your knowledge of CDC's statutory and regulatory 
framework, do you believe changes ARE or ARE NOT needed to prevent the 
importation of zoonotic diseases? 

Response: Changes are needed; 
Number of responses: 50. 

Response: Changes are not needed; Skip To Question #12; 
Number of responses: 5. 

Response: No response; 
Number of responses: 1. 

[End of table] 

11. How much, if at all, do you support or oppose the following 
potential changes for CDC to prevent the importation of zoonotic 
diseases? 

Potential change: A-CDC should have the authority to use pre-import 
screening to mitigate the risk of live animal imports; 
Strongly support: 31; 
Somewhat support: 9; 
Neither support nor oppose: 4; 
Somewhat oppose: 4; 
Strongly oppose: 2; 
Don't know: 1; 
No response: 5. 

Potential change: B-CDC should quarantine high-risk animals to allow 
assessment of the animals' health; 
Strongly support: 25; 
Somewhat support: 12; 
Neither support nor oppose: 5; 
Somewhat oppose: 6; 
Strongly oppose: 3; 
Don't know: 0; 
No response: 5. 

[End of table] 

Section 4: Fish and Wildlife Service (FWS): 

12. Based on your knowledge of FWS's statutory and regulatory 
framework, do you believe changes ARE or ARE NOT needed to prevent the 
importation of zoonotic and animal diseases? 

Response: Changes are needed; 
Number of responses: 52. 

Response: Changes are not needed; Skip To Question #14; 
Number of responses: 3. 

Response: No response; 
Number of responses: 1. 

[End of table] 

13. How much, if at all, do you support or oppose the following 
potential changes for FWS to prevent this importation of zoonotic and 
animal diseases? 

Potential change: A-FWS should have the authority to use pre-import 
screening to mitigate the risk of live animal imports; 
Strongly support: 38; 
Somewhat support: 6; 
Neither support nor oppose: 3; 
Somewhat oppose: 4; 
Strongly oppose: 0; 
Don't know: 2; 
No response: 3. 

Potential change: B-FWS should have the authority to quarantine live 
wildlife after import; 
Strongly support: 32; 
Somewhat support: 10; 
Neither support nor oppose: 3; 
Somewhat oppose: 7; 
Strongly oppose: 0; 
Don't know: 1; 
No response: 3. 

Potential change: C-FWS should classify species that may be carrying 
infectious agents as injurious wildlife; 
Strongly support: 25; 
Somewhat support: 12; 
Neither support nor oppose: 3; 
Somewhat oppose: 9; 
Strongly oppose: 2; 
Don't know: 2; 
No response: 3. 

Potential change: D-FWS should expedite the process for classifying 
species as injurious wildlife; 
Strongly support: 31; 
Somewhat support: 12; 
Neither support nor oppose: 2; 
Somewhat oppose: 3; 
Strongly oppose: 0; 
Don't know: 5; 
No response: 3. 

[End of table] 

Section 5: Interagency Collaboration: 

14. Based on your knowledge of the current statutory and regulatory 
framework, do you believe a centralized agency should be created to 
regulate all live animal imports? 

Response: Yes, a centralized agency should be created; 
Number of responses: 27. 

Response: No, a centralized agency should not be created; Skip To 
Question #16; 
Number of responses: 29. 

Response: No response; 
Number of responses: 0. 

[End of table] 

15. Within which of the following should a centralized agency be 
placed? 

Response: Animal and Plant Health Inspection Service (APHIS); 
Number of responses: 17. 

Response: Customs and Border Protection (CBP); 
Number of responses: 0. 

Response: Centers for Disease Control and Prevention (CDC);
Number of responses: 2. 

Response: Fish and Wildlife Service (FWS); 
Number of responses: 1. 

Response: A new agency created to regulate live animal imports; 
Number of responses: 8. 

Response: No response; 
Number of responses: 28. 

[End of table] 

16. How much, if at all, do you support or oppose the creation of a 
workgroup to help federal agencies collaborate in preventing the 
importation of zoonotic and animal diseases? 

Response: Strongly support; 
Number of responses: 44. 

Response: Somewhat support; 
Number of responses: 8. 

Response: Neither support nor oppose; 
Number of responses: 3. 

Response: Somewhat oppose; 
Number of responses: 0. 

Response: Strongly oppose; 
Number of responses: 0. 

Response: Don't know; 
Number of responses: 0. 

Response: No response; 
Number of responses: 1. 

[End of table] 

17. How important, if at all, is representation from the following 
entities on such a workgroup? 

Entity: A-Academia; 
Very important: 18; 
Moderately important: 20; 
Somewhat important: 13; 
Slightly important: 3; 
Not at all important: 2; 
Don't know: 0; 
No response: 0. 

Entity: B-APHIS; 
Very important: 52; 
Moderately important: 4; 
Somewhat important: 0; 
Slightly important: 0; 
Not at all important: 0; 
Don't know: 0; 
No response: 0. 

Entity: C-Aquaculture; 
Very important: 22; 
Moderately important: 15; 
Somewhat important: 12; 
Slightly important: 7; 
Not at all important: 0; 
Don't know: 0; 
No response: 0. 

Entity: D-Aquariums; 
Very important: 13; 
Moderately important: 16; 
Somewhat important: 19; 
Slightly important: 6; 
Not at all important: 1; 
Don't know: 1; 
No response: 0. 

Entity: E-CDC; 
Very important: 49; 
Moderately important: 5; 
Somewhat important: 1; 
Slightly important: 0; 
Not at all important: 0; 
Don't know: 1; 
No response: 0. 

Entity: F-CBP; 
Very important: 39; 
Moderately important: 6; 
Somewhat important: 8; 
Slightly important: 1; 
Not at all important: 1; 
Don't know: 1; 
No response: 0. 

Entity: G-FWS; 
Very important: 52; 
Moderately important: 4; 
Somewhat important: 0; 
Slightly important: 0; 
Not at all important: 0; 
Don't know: 0; 
No response: 0. 

Entity: H-International Air Transport Association; 
Very important: 16; 
Moderately important: 16; 
Somewhat important: 15; 
Slightly important: 7; 
Not at all important: 0; 
Don't know: 2; 
No response: 0. 

Entity: I-International Civil Aviation Organization; 
Very important: 6; 
Moderately important: 17; 
Somewhat important: 14; 
Slightly important: 9; 
Not at all important: 3; 
Don't know: 7; 
No response: 0. 

Entity: J-Livestock industry; 
Very important: 21; 
Moderately important: 15; 
Somewhat important: 12; 
Slightly important: 7; 
Not at all important: 1; 
Don't know: 0; 
No response: 0. 

Entity: K-National Oceanic and Atmospheric Administration; 
Very important: 20; 
Moderately important: 12; 
Somewhat important: 11; 
Slightly important: 7; 
Not at all important: 3; 
Don't know: 3; 
No response: 0. 

Entity: L-Nonprofit organizations; 
Very important: 8; 
Moderately important: 11; 
Somewhat important: 18; 
Slightly important: 13; 
Not at all important: 3; 
Don't know: 3; 
No response: 0. 

Entity: M-Organizations that use imported live animals for research; 
Very important: 21; 
Moderately important: 11; 
Somewhat important: 18; 
Slightly important: 4; 
Not at all important: 1; 
Don't know: 1; 
No response: 0. 

Entity: N-Pet industry; 
Very important: 24; 
Moderately important: 14; 
Somewhat important: 9; 
Slightly important: 8; 
Not at all important: 0; 
Don't know: 1; 
No response: 0. 

Entity: O-Port authorities; 
Very important: 25; 
Moderately important: 19; 
Somewhat important: 7; 
Slightly important: 2; 
Not at all important: 2; 
Don't know: 1; 
No response: 0. 

Entity: P-Poultry industry; 
Very important: 18; 
Moderately important: 17; 
Somewhat important: 9; 
Slightly important: 10; 
Not at all important: 1; 
Don't know: 1; 
No response: 0. 

Entity: Q-State agricultural agencies; 
Very important: 27; 
Moderately important: 19; 
Somewhat important: 6; 
Slightly important: 2; 
Not at all important: 2; 
Don't know: 0; 
No response: 0. 

Entity: R-State public health agencies; 
Very important: 25; 
Moderately important: 16; 
Somewhat important: 10; 
Slightly important: 2; 
Not at all important: 2; 
Don't know: 1; 
No response: 0. 

Entity: S-State wildlife agencies; 
Very important: 27; 
Moderately important: 18; 
Somewhat important: 6; 
Slightly important: 2; 
Not at all important: 2; 
Don't know: 1; 
No response: 0. 

Entity: T-U.S. Geological Survey; 
Very important: 22; 
Moderately important: 11; 
Somewhat important: 13; 
Slightly important: 3; 
Not at all important: 4; 
Don't know: 3; 
No response: 0. 

Entity: U-World Organisation for Animal Health; 
Very important: 25; 
Moderately important: 17; 
Somewhat important: 5; 
Slightly important: 3; 
Not at all important: 5; 
Don't know: 1; 
No response: 0. 

Entity: V-World Health Organization; 
Very important: 15; 
Moderately important: 24; 
Somewhat important: 8; 
Slightly important: 3; 
Not at all important: 5; 
Don't know: 1; 
No response: 0. 

Entity: W-Zoos; 
Very important: 18; 
Moderately important: 19; 
Somewhat important: 11; 
Slightly important: 7; 
Not at all important: 0; 
Don't know: 1; 
No response: 0. 

[End of table] 

18. What other entities, if any, should be included on such a 
workgroup? 

Answers included American College of Laboratory Animal Medicine; 
American Medical Association; American Veterinary Medical Association; 
Association of Fish and Wildlife Agencies; Council of State and 
Territorial Epidemiologists; county departments of public health; 
Defenders of Wildlife; Food and Agriculture Organization of the United 
Nations; International Union for the Conservation of Nature; National 
Association of State Public Health Veterinarians; National Institutes 
of Health; National Science Foundation; Pet Industry Joint Advisory 
Council; U.S. Agency for International Development; U.S. Coast Guard, 
U. S. Department of Health and Human Services Office of Global Health 
Affairs; U.S. Department of State; The Wildlife Society; Wildlife 
Disease Association; Wildlife Trust. 

19. How important, if at all, are the following activities for a 
workgroup to help federal agencies collaborate in preventing the 
importation of zoonotic and animal diseases? 

Activity: A-Define the mission and scope of work related to live 
animal imports for relevant federal agencies; 
Very important: 44; 
Moderately important: 6; 
Somewhat important: 2; 
Slightly important: 2; 
Not at all important: 2; 
Don't know: 0; 
No response: 0. 

Activity: B-Identify gaps in regulations related to live animal 
imports among relevant federal agencies; 
Very important: 50; 
Moderately important: 3; 
Somewhat important: 1; 
Slightly important: 1; 
Not at all important: 1; 
Don't know: 0; 
No response: 0. 

Activity: C-Identify overlaps in regulations related to live animal 
imports among relevant federal agencies; 
Very important: 41; 
Moderately important: 10; 
Somewhat important: 3; 
Slightly important: 0; 
Not at all important: 1; 
Don't know: 1; 
No response: 0. 

Activity: D-Recommend new legislation to prevent the importation of 
zoonotic and animal diseases; 
Very important: 27; 
Moderately important: 16; 
Somewhat important: 8; 
Slightly important: 4; 
Not at all important: 0; 
Don't know: 1; 
No response: 0. 

Activity: E-Develop a coordinated national strategy to better align 
activities, processes, and resources; 
Very important: 52; 
Moderately important: 4; 
Somewhat important: 0; 
Slightly important: 0; 
Not at all important: 0; 
Don't know: 0; 
No response: 0. 

Activity: F-Develop a risk assessment framework to identify animals, 
diseases, and countries for appropriate action; 
Very important: 41; 
Moderately important: 12; 
Somewhat important: 2; 
Slightly important: 0; 
Not at all important: 0; 
Don't know: 1; 
No response: 0. 

Activity: G-Develop a research plan to help relevant federal agencies 
in assessing disease risks; 
Very important: 21; 
Moderately important: 23; 
Somewhat important: 8; 
Slightly important: 2; 
Not at all important: 1; 
Don't know: 1; 
No response: 0. 

Activity: H-Examine methods to maximize inspection resources such as 
reducing the number of ports of entry; 
Very important: 32; 
Moderately important: 17; 
Somewhat important: 4; 
Slightly important: 2; 
Not at all important: 1; 
Don't know: 0; 
No response: 0. 

Activity: I-Examine challenges for relevant federal agencies 
associated with state regulations; 
Very important: 27; 
Moderately important: 18; 
Somewhat important: 8; 
Slightly important: 3; 
Not at all important: 0; 
Don't know: 0; 
No response: 0. 

Activity: J-Facilitate training for ports of entry staff; 
Very important: 26; 
Moderately important: 19; 
Somewhat important: 4; 
Slightly important: 6; 
Not at all important: 1; 
Don't know: 0; 
No response: 0. 

Activity: K-Develop a plan to leverage existing resources among 
relevant federal agencies (e.g., sharing quarantine facilities, 
training field staff, etc.); 
Very important: 40; 
Moderately important: 10; 
Somewhat important: 4; 
Slightly important: 2; 
Not at all important: 0; 
Don't know: 0; 
No response: 0. 

Activity: L-Designate resources to be shared among relevant federal 
agencies for disease outbreaks; 
Very important: 28; 
Moderately important: 20; 
Somewhat important: 6; 
Slightly important: 0; 
Not at all important: 2; 
Don't know: 0; 
No response: 0. 

Activity: M-Develop a plan to ensure that data on all live animal 
imports is available to relevant federal agencies; 
Very important: 39; 
Moderately important: 12; 
Somewhat important: 4; 
Slightly important: 0; 
Not at all important: 1; 
Don't know: 0; 
No response: 0. 

Activity: N-Establish an agreement between relevant federal agencies 
and international aviation associations to enhance cooperation; 
Very important: 20; 
Moderately important: 19; 
Somewhat important: 14; 
Slightly important: 2; 
Not at all important: 1; 
Don't know: 0; 
No response: 0. 

Activity: O-Develop a process for relevant federal agencies to confer 
with each other when entering into agreements with international; 
Very important: 26; 
Moderately important: 13; 
Somewhat important: 13; 
Slightly important: 1; 
Not at all important: 1; 
Don't know: 2; 
No response: 0. 

Activity: P-Develop a plan for relevant federal agencies to 
collaborate in meeting the obligations of the World Health 
Organization's International Health Regulations; 
Very important: 20; 
Moderately important: 16; 
Somewhat important: 15; 
Slightly important: 1; 
Not at all important: 1; 
Don't know: 3; 
No response: 0. 

Activity: Q-Develop a plan for relevant federal agencies to coordinate 
counter measures against live animal smuggling; 
Very important: 37; 
Moderately important: 10; 
Somewhat important: 6; 
Slightly important: 2; 
Not at all important: 0; 
Don't know: 1; 
No response: 0. 

Activity: R-Develop a plan for identifying and implementing existing 
Memoranda of Understandings among relevant federal agencies; 
Very important: 23; 
Moderately important: 23; 
Somewhat important: 6; 
Slightly important: 3; 
Not at all important: 0; 
Don't know: 1; 
No response: 0. 

Activity: S-Develop public outreach and education programs for those 
likely to come in contact with imported animals to prevent contracting 
or spreading diseases; 
Very important: 26; 
Moderately important: 14; 
Somewhat important: 8; 
Slightly important: 7; 
Not at all important: 0; 
Don't know: 1; 
No response: 0. 

[End of table] 

20. Based upon your knowledge of interagency collaboration at ports of 
entry, do you believe communications among the agencies are adequate? 

Response: Adequate; 
Number of responses: 3. 

Response: Inadequate; 
Number of responses: 53. 

Response: No response; 
Number of responses: 0. 

[End of table] 

21. How important, if at all, are the following activities to improve 
interagency communications? 

Activity: A-Convene regular risk management meetings; 
Very important: 25; 
Moderately important: 14; 
Somewhat important: 10; 
Slightly important: 4; 
Not at all important: 1; 
Don't know: 2; 
No response: 0. 

Activity: B-Integrate outside stakeholders into relevant risk 
management activities; 
Very important: 21; 
Moderately important: 24; 
Somewhat important: 4; 
Slightly important: 5; 
Not at all important: 0; 
Don't know: 2; 
No response: 0. 

Activity: C-Designate a process, including interagency communication, 
for CBP to hold animals at the port until necessary inspections can be 
completed by appropriate federal agencies; 
Very important: 27; 
Moderately important: 14; 
Somewhat important: 8; 
Slightly important: 3; 
Not at all important: 3; 
Don't know: 1; 
No response: 0. 

Activity: D-Establish compatible data systems containing information 
for managing, processing, and analyzing imports among relevant federal 
agencies; 
Very important: 41; 
Moderately important: 10; 
Somewhat important: 4; 
Slightly important: 1; 
Not at all important: 0; 
Don't know: 0; 
No response: 0. 

[End of table] 

22. Based upon your knowledge of interagency collaboration at ports of 
entry, do you believe training among the agencies is adequate or 
inadequate? 

Response: Adequate; 
Number of responses: 8. 

Response: Inadequate; 
Number of responses: 46. 

Response: No response; 
Number of responses: 2. 

[End of table] 

23. How important, if at all, are the following activities to improve 
interagency training? 

Activity: A-Improve cross-training on other federal agencies' 
regulations; 
Very important: 35; 
Moderately important: 9; 
Somewhat important: 6; 
Slightly important: 4; 
Not at all important: 0; 
Don't know: 2; 
No response: 0. 

Activity: B-Improve cross-training on state, regional, and local 
regulations; 
Very important: 27; 
Moderately important: 11; 
Somewhat important: 10; 
Slightly important: 4; 
Not at all important: 3; 
Don't know: 1; 
No response: 0. 

Activity: C-Improve training on zoonotic and animal disease risks; 
Very important: 35; 
Moderately important: 11; 
Somewhat important: 8; 
Slightly important: 0; 
Not at all important: 1; 
Don't know: 1; 
No response: 0. 

Activity: D-Improve training on recognition of zoonotic and animal 
diseases; 
Very important: 38; 
Moderately important: 12; 
Somewhat important: 2; 
Slightly important: 1; 
Not at all important: 2; 
Don't know: 1; 
No response: 0. 

Activity: E-Improve training on animal identification; 
Very important: 29; 
Moderately important: 15; 
Somewhat important: 8; 
Slightly important: 1; 
Not at all important: 1; 
Don't know: 2; 
No response: 0. 

Activity: F-Create liaison positions among the federal agencies to 
coordinate training opportunities; 
Very important: 23; 
Moderately important: 17; 
Somewhat important: 4; 
Slightly important: 7; 
Not at all important: 2; 
Don't know: 3; 
No response: 0. 

[End of table] 

Section 6: Enforcement of Regulations: 

24. How important, if at all, are the following enforcement actions to 
prevent the importation of zoonotic and animal diseases? 

Activity: A-Provide additional FWS port inspectors ; 
Very important: 31; 
Moderately important: 12; 
Somewhat important: 5; 
Slightly important: 3; 
Not at all important: 1; 
Don't know: 4; 
No response: 0. 

Activity: B-Increase importer user fees to be specifically designated 
for enforcement activities ; 
Very important: 34; 
Moderately important: 4; 
Somewhat important: 5; 
Slightly important: 2; 
Not at all important: 6; 
Don't know: 5; 
No response: 0. 

Activity: C-Identify methods to ensure that animals from banned 
countries are not routed through another country prior to importation; 
Very important: 41; 
Moderately important: 8; 
Somewhat important: 1; 
Slightly important: 3; 
Not at all important: 2; 
Don't know: 1; 
No response: 0. 

Activity: D-Increase penalties for live animal smuggling violations ; 
Very important: 40; 
Moderately important: 8; 
Somewhat important: 3; 
Slightly important: 3; 
Not at all important: 0; 
Don't know: 2; 
No response: 0. 

Activity: E-Enforce penalties for live animal smuggling violations ; 
Very important: 42; 
Moderately important: 10; 
Somewhat important: 0; 
Slightly important: 1; 
Not at all important: 0; 
Don't know: 3; 
No response: 0. 

[End of table] 

Section 7: Agency Data Used for Live Animal Imports: 

25. How important, if at all, is making the following data accessible 
on the Web? 

Data: A-FWS's Law Enforcement Management Information System ; 
Very important: 14; 
Moderately important: 18; 
Somewhat important: 5; 
Slightly important: 5; 
Not at all important: 2; 
Don't know: 12; 
No response: 0. 

Data: B-APHIS's Import Tracking System data ; 
Very important: 15; 
Moderately important: 16; 
Somewhat important: 6; 
Slightly important: 5; 
Not at all important: 3; 
Don't know: 11; 
No response: 0. 

[End of table] 

Section 8: Other Comments: 

26. What comments, if any, do you have about the issues discussed in 
this survey? 

27. What other live animal import concerns, if any, do you have that 
we have not discussed? 

Note: We used the responses to questions 26 and 27 to inform our 
findings in this report. 

[End of section] 

Appendix VIII: Comments from the U.S. Department of Agriculture: 

USDA: 
United States Department of Agriculture: 
Office of the Secretary: 
Washington, D.C. 20250: 

October 21, 2010: 

Ms. Lisa Shames, Director: 
Natural Resources and Environment: 
United States Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Dear Ms. Shames: 

The United States Department of Agriculture (USDA) appreciates the 
opportunity to comment on the GAO draft report, "Live Animal Imports: 
Agencies Need Better Collaboration to Reduce the Risk of Animal-
Related Diseases" (11-09). While the report contains individual 
Recommendations for the Secretary of Agriculture, we have globally 
addressed these Recommendations. 

First and foremost, USDA agrees with these recommendations. USDA is 
deeply committed to the protection of American agriculture, as well as 
to the protection of farmed animal health and welfare, and to 
maintaining an effective strategy to prevent, contain or eradicate 
outbreaks of animal diseases. USDA appreciates GAO's emphasis on 
increasing the level of collaboration among federal agencies with 
differing types of oversights for animal importations. 

As the GAO audit pointed out, USDA, as well as some other federal 
agencies, currently has limited statutory authorities regarding the 
importation of animal commodities that are capable of introducing or 
otherwise acting as vectors for important diseases of animals and/or 
humans. Moreover, USDA (and many other government entities) is working 
to find ways to effectively and efficiently carry out our mission 
priorities in light of constrained funding. Such enforcement 
considerations would also necessarily apply to any further authorities 
that may be sought or realized by a Department. USDA believes that a 
key component to successfully leveraging the different Departments' 
strengths, while minimizing the individual limitations of each 
Department, lies in finding new ways to approach these opportunities. 

USDA, therefore, would support the formation of an inter-departmental 
Steering Committee for the oversight of animal importations, whose co-
chairs, representing USDA, Departments of Health and Human Services, 
Homeland Security, and the Interior, would report the Committee's 
findings and progress directly to their respective Secretaries. An 
USDA nominee for this Committee could be determined by November 1, 
2010. If the notion of forming such a Committee received support from 
other government entities, USDA would support convening the Committee 
as soon as possible. Prior to the first meeting, USDA would provide 
input for specific agenda items and would work with other entities to 
create an agenda that focused on the issues of collaboration and 
focused oversight as highlighted in the GAO audit. 

USDA would also work with the other Departments to create a Committee 
charter with a clear mission statement, Committee goals and 
objectives, and progress milestones for increasing the effectiveness 
of animal importation oversights — all of which would be directly 
responsive to GAO's recommendations. 

USDA believes that among other things, such a Committee could examine 
and discuss the specific statutory authorities currently supporting 
the processes in USDA and other Departments by which animals are 
imported to the United States, with the specific goal of identifying 
areas of overlapping, concurrent, or non-existent jurisdictions. In
collaboration with the Committee and other Departments, USDA would 
also seek to determine the need for creating additional authority; 
clarify the scope of existing authority; and implement current 
authority more efficiently through expanded Memoranda of Agreements or 
other inter-departmental cooperative measures. 

As these factors are discussed and refined, the need for streamlining 
or re-directing existing resources, or to acquire additional resource 
allocations, would become clearer. With that added clarity, USDA would 
then formulate a list of action steps which we would submit in a 
report to GAO. This report from USDA would outline the components of a 
successful strategy for addressing GAO's recommendations in a timely 
manner. Once the avenues of increased collaboration have been 
identified, USDA would also communicate these strategies with its 
stakeholders for additional inputs. 

Sincerely, 

Signed by: 

Edward Avalos: 
Under Secretary: 
Marketing and Regulatory Programs: 

[End of section] 

Appendix IX: Comments from the Department of Homeland Security: 

U.S. Department of Homeland Security: 
Washington, DC 20528: 

Ms. Lisa Shames: 
Director, Natural Resources and Environment: 
U.S. Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Dear Ms. Shames: 

Subject: Draft Report GAO-11-09, Live Animal Imports: Agencies Need 
Better Collaboration to Reduce the Risk of Animal-Related Diseases 
(Job Code 361116). 

The Department of Homeland Security (DHS) appreciates the opportunity 
to review and comment on the draft report referenced above. We agree 
with the intent of the two recommendations. 

Recommendation 1: 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 from entering the United States. This strategy 
should help the agencies: 

* 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; 

* Lay out individual agency roles and responsibilities for all live 
animal imports, including how a collaborative effort will be led; 

* Identify resources dedicated to live animal imports and leverage 
these resources to the extent possible to support the agencies' 
efforts; 

* Examine ways to systematically share data on shipments of live 
animal imports that are regulated by more than one agency until ITDS 
is fully operational; and; 

* 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). 

Response: The Department concurs with the intent of GAO's 
recommendation and we will work with the pertinent organizations 
within the Departments of Agriculture, Health and Human Services, and 
Interior to gauge interest in developing a joint strategic 
implementation plan to address preventing the importation of animals 
that may be carrying zoonotic and animal diseases from entering the 
United States. 

Of note, currently the U.S. Customs and Border Protection, Office of 
Field Operations (OFO), Agriculture Programs and Trade Liaison (APTL) 
collaborates continuously with the U.S. Department of Agriculture 
(USDA), Animal and Plant Health Inspection Service (APHIS) to 
facilitate live animal imports. Procedures outlined in USDA's API-US 
Animal Product Manual in Chapter 2, "Procedures" and Chapter 3 "Live 
Animal and Related Materials" for Customs and Border Protection 
Officers (CBPOs) and Customs and Border Protection Agriculture 
Specialists (CBPASs) to make appropriate agency referrals. These 
procedures include referral information (Chapter 2) and tables 
(Chapter 3) to guide CBPASs and CBPOs to the appropriate regulating 
agency for the clearance of dogs, cats, laboratory mammals, 
amphibians, reptiles, fish, monkeys, and other nonhuman primates. The 
referring agencies listed are the Fish and Wildlife Service (FWS), or 
the Center for Disease Control and Prevention (CDC). Also, CBPASs and 
CBPOs refer horses, cattle, sheep, goats, swine, and pet birds 
directly to the APHIS-Veterinary Service (VS) for clearance. 

Section 421 (e) of the Homeland Security Act of 2002 (the Act), 
transferred to the U.S. Department of Homeland Security (DHS) 
functions of APHIS relating to agricultural import and entry 
inspections. Article 2 of the Memorandum of Agreement between the DHS 
and USDA outlines the extent of CBP's role with live animal imports. 
Article 2 (f) states "Referring all live animals, embryos, semen, and 
other viable animal products to USDA" and to "Notify APHIS-VS when 
live animals are present." Additionally CBP, OFO has national bird 
handling standard operating procedures (SOPs). CBP's bird handling 
SOPs provide information to the ports of entry (POEs) and includes, as 
applicable, the CBP Offices of Border Patrol and Air and Marine, and 
list responsibilities for CBP and APHIS. CBP and APHIS have SOPs along 
the Southern Border to facilitate the inspection of feeder cattle. CBP 
and APHIS have guidance for coordinating APHIS-VS and CBP processing 
of live animal importations arriving from Canada at land border POEs. 

Although CBPASs and CBPOs at POEs refer all live animal imports to the 
appropriate regulating agency, they are not solely dedicated to this 
particular function. CBPOs and CBPASs facilitate all cargo and 
commodities for the trade industry into the United States. POEs 
maintain quarantine rooms, personal protective equipment, cages, and 
other quarantine materials for all birds encountered from all 
countries including when the country of origin of the bird is unknown. 
Seized pet birds are held by CBP and turned over to APHIS-VS. 

Recommendation 2: Jointly determine, in collaboration with CBP, the 
data that APHIS, CDC, and FWS will need ITDS to contain, so that 
agencies can effectively oversee all live animal imports. 

Response: CBP concurs with this recommendation and already has work in 
progress to fulfill it. The draft report correctly details the 
creation of the International Trade Data System (ITDS) to streamline 
data requirements across all agencies. The CBP, Office of 
International Trade has been working in conjunction with the Animal 
Plant Health Inspection Service (APHIS), Center for Disease Control 
(CDC), and Fish and Wildlife Service (FWS) to address data needs for 
each of these agencies. The CBP, Office of International Trade has 
already established a mechanism where it collaborates with other 
government agencies on efforts aimed at addressing their data needs 
within the Automated Commercial Environment (ACE). The process 
includes the assignment of an ACE liaison to participating government 
agencies in order to address their data needs. The data elements are 
then evaluated, streamlined, and included in the ITDS Standard Data 
Set (SDS), which serves as a common data dictionary for all government 
agencies participating in the ACE pilot. CBP, APHIS, FWS. and CDC are 
all active members within ITDS and have initiated the first steps of 
data sharing within ACE. The concept of operations plan for the APHIS 
has already been approved by CBP. The FWS have submitted their concept 
of operations plan, which is still under legal review by both 
agencies. Both APHIS and the FWS have had their data needs mapped to 
the ITDS SDS. The CDC has not yet submitted their concept of 
operations to CBP. However, CBP has begun preliminary discussions with 
the CDC involving the integration of their data needs into the SDS. 

Sincerely, 

Signed by: 

Jerald E. Levine: 
Director: 
Departmental GAO-OIG Liaison Office: 

[End of section] 

Appendix X: Comments from the Department of the Interior: 

Note: GAO comments supplementing those in the report text appear at 
the end of this appendix. 

United States Department of the Interior: 
Office Of The Secretary: 
Washington, DC 20240: 

Ms. Lisa Shames: 
Director, Natural Resources and Environment: 
U.S. Government Accountability Office: 
441 G Street, N.W. 
Washington, D.C. 20548: 

Dear Ms. Shames: 

Thank you for providing the Department of the Interior the opportunity 
to review and comment on the draft Government Accountability Office 
Report entitled "Live Animal Imports: Agencies Need Better 
Collaboration to Reduce the Risk of Animal-Related Diseases" (GAO-11-
09). 

The enclosure contains some general and specific comments. The 
Department concurs with the major findings and recommendations 
included in the report. 

If you have any questions, or need additional information, contact 
Kathy Garrity, Fish and Wildlife Service, at (703) 358-2551. 

Sincerely, 

Signed by: 

Thomas L. Strickland: 
Assistant Secretary for Fish and Wildlife and Parks: 

Enclosure: 

[End of letter] 

Enclosure: 

Department of the Interior: 

Comments on the GAO draft report on: 

Live Animal Imports: Agencies Need Better Collaboration to Reduce the 
Risk of Animal-Related Diseases (GAO 11-09): 

General comments: 

No reference has been made in the report to the possible confusion 
that may be caused by multiple agencies having related authorities. 
Does the public know where to find data/information on imports and 
restrictions? Although it was not a central question GAO was asked to 
review, outreach could have been reviewed/analyzed a little more, 
since it could play an important role in reducing risks of animal-
related diseases. [See comment 1] 

Also, no reference is made to any efforts to prevent the introduction 
of diseases in container water. We recommend adding "Federal, state, 
and NGO partners should initiate discussions to address potential 
disease threats posed by container water (e.g. water used to transport 
ornamental fish or other aquatics)." [See comment 2] 

The report should emphasize the National Aquatic Animal Health Plan 
(NAAHP) as a model for Federal cooperation with regard to movement of 
aquatic animal diseases. In the future, the NAAHP will be broadened to 
include amphibians and reptiles. [See comment 3] 

Specific comments: 

"Highlights" Page, 2nd bullet: re: FWS regulation of invasive species. 
The reference to review of a petition on amphibians fails to explain 
why this is relevant (i.e., because it is a petition to restrict 
imports of amphibians (that carry choridfungus.) Also, this is a 
reaction to a petition and really does not demonstrate how FWS is 
being proactive in applying its authority. [See comment 4] 

"Highlights" Page: "In contrast, the U.S. Department of 
Agriculture's..." implies an equality of effort by agencies to prevent 
the movement of diseases in the live animal import trade, but also 
implies equality between the three agencies with regard to
authority. In reality, USDA-APHIS' authority is much broader than that 
of the USFWS; therefore, equality cannot be inferred. We recommend the 
following wording: "USDA's authority is much broader than that of the 
USFWS with regard to movement of aquatic pathogens, and is focused on 
agricultural species. The USFWS' authority is focused on
native aquatic species in the wild. All agencies should work within 
their authorities and collaborate to better prevent the movement of 
aquatic pathogens." [See comment 5] 

Page 3, 1st sentence: "More than 1 billion live animals were legally 
imported into the United States for agriculture, clinical research, 
education and exhibition, and the aquarium and pet industries." 
Suggest adding "and other uses" - There are other possible uses that 
do not need to be mentioned but should at least be acknowledged (e.g., 
furs). [See comment 6] 

Page 4, 2nd bullet: "The Department of the Interior's Fish and 
Wildlife Service (FWS) administers the prohibition against the import 
of live animals..." FWS also has the authority to list dead organisms 
as injurious wildlife, and has done so specifically in the case of 
salmonids to mitigate the risk of disease transmission, the key 
element of the GAO report. This omission occurs elsewhere in the 
report and should be corrected (pages 9 and 20). [See comment 7] 

Page 8: We recognize that CBP provides assistance to FWS in enforcing 
import regulations; however, we believe the responsibilities described 
are overstated. When a live animal import arrives at a port of entry, 
CBP does not hold and refer the import to FWS. FWS is routinely 
notified by the importer/exporter and/or the airline. [See comment 8] 

Page 10, 1st full paragraph: "According to the FWS data system, about 
177 million live animals — nearly all wildlife — were imported under 
FWS regulation in fiscal year 2009". The use of the word "nearly" is 
inaccurate. The FWS regulates all wildlife. [See comment 9] 

Page 13, 4th line: it should say "comprehensive science-based" not 
"comprehensive-based science"? [See comment 10] 

Page 21, 2nd line: Bd pathogen (Batrachockytriurn dendrobatidis) does 
not cause a fungus, it is a fungus. [See comment 11] 

Page 22, middle of 1st paragraph: "FWS is reviewing several proposals 
to...preventing the spread of invasive species, including:... 
developing a risk assessment process with scientifically credible 
procedures; and supporting regulatory and educational approaches." The 
statement assumes our current procedures are not scientifically valid. 
Please revise to state: "FWS is reviewing several proposals 
to...preventing the spread of invasive species, including:...revising 
its risk assessment process; and supporting improved regulatory and 
educational approaches." [See comment 12] 

Page 22, 2nd paragraph: "Experts also identified the need for an 
entity to help the agencies overcome these barriers." The report seems 
to suggest a new entity is needed to help improve coordination, yet we 
already have the National Invasive Species Council and Aquatic 
Nuisance Species Task Force. No mention is made of either of these 
bodies, or why they could not effectively serve this role. (Also 
appears on page 32) [See comments 13 and 14] 

Page 22: Although Agencies Have Collaborated to Meet Common Goals, 
They Face Barriers to Additional Collaboration — This section states 
that CBP usually contacts FWS Inspectors to determine whether a 
particular type of turtle is banned in statute or regulation. This is 
inaccurate and not a function of CBP. FWS is usually notified by the 
importer/exporter or the airline. [See comment 8] 

Page 24: GAO notes that the principal barrier to collaboration is 
agencies' failure to take a broader view of the entire importation 
process. Likewise, GAO statement "...focusing instead on only those 
components of the process each agency controls." is not quite 
accurate, as agency focus is legislatively dictated by authorizations 
(see comment "Highlights Page" above). We suggest that GAO consider 
asking agencies to redouble collaborative efforts within their 
authorities to prevent import and movement of aquatic pathogens. 
[See comment 15] 

Page 30, 1st full paragraph: "While the agencies have worked 
together...they may not be able to determine whether their funding and 
staff are sufficient..." This evaluation has occurred as part of the 
mandate from the Secretary of the Interior for FWS to comprehensively 
review its statutory authorities, regulations, and processes under the 
injurious wildlife provisions of the Lacey Act. Recommendations are 
moving presently through the FWS and DOI approval processes. [See 
comment 16] 

Page 32, last paragraph: GAO asked experts whether a workgroup should 
be created to help federal agencies collaborate. However, there is no 
consideration of whether there may be an existing group that could 
perform this function. Use of an existing body could facilitate 
collaboration and efficiency by avoiding unnecessary proliferation of 
groups. The National Invasive Species Council (NISC) was established 
by Executive Order 13112 (EO) to improve coordination and 
collaboration among federal agencies and with experts and stakeholders 
on invasive species issues, including the risk of animal related 
diseases being introduced by invasive species. The Department of 
Homeland Security and the Department of Health and Human Services are 
members of NISC; while the Department of the Interior and the 
Department of Agriculture are co-chairs of NISC. The HO also 
established the Invasive Species Advisory Committee (ISAC) which 
includes nonfederal experts and stakeholders from across the nation. 
ISAC and NISC may establish subcommittees, workgroups or task teams to 
consider specific issues; and this has occurred to address a number of 
issues. The report should state that, in addition to the option of 
creating a new workgroup, there may be an existing group whose scope 
could be expanded to play this role. [See comment 14] 

Page 55, Appendix V Note at the bottom of the table: indicates that 
FWS only screens shipments of live animals for disease risk for salmon 
and CITES listed species only. This is inaccurate. Our regulations 
also require the trade to provide health certificates for all mammals 
and birds that are wildlife. [See comment 17] 

The following are GAO's comments on the Department of the Interior's 
letter. 

GAO Comments: 

1. In the report, we state that federal agencies face a range of 
barriers when they attempt to collaborate with other agencies and that 
these barriers can confuse and frustrate program customers. In 
addition, as the Department of the Interior notes, this issue was not 
part of our objectives. 

2. Our report does not attempt to describe all of the pathways by 
which live animal imports could introduce diseases into the United 
States. However, we modified the report to include a reference to 
container water in which aquatic animals are transported as a 
potential pathway. 

3. In the report, we state that the National Aquatic Animal Health 
Plan is an example of federal agencies' joint strategies to reduce 
disease risks from live animal imports. We have added language to 
provide more information on this plan's relevant efforts. 

4. We revised the report to reflect this comment by deleting from the 
highlights page the reference to FWS's review of a petition on 
amphibians. 

5. We added language to the highlights page to clarify that FWS was 
directed to review statutory authorities and regulations to address 
existing problems associated with nonnative live animals. 

6. We added language to the report to clarify that imported live 
animals are used for additional purposes. 

7. We modified language in the report to clarify that FWS' authority 
to list organisms as injurious wildlife is not limited to live animals. 

8. We modified the report to attribute a description of CBP's 
processes to CBP officials only. 

9. We modified the report to clarify that FWS regulates all wildlife. 

10. We did not change the language because it is a quote from the 
cited National Academies of Sciences report that we attributed. 

11. We modified the report to clarify that the Bd pathogen is a fungus. 

12. We modified the report to clarify that FWS is revising its risk 
assessment procedures. 

13. The National Invasive Species Council's activities to help federal 
agencies collaborate are described in the report. We added information 
on the Invasive Species Advisory Committee, which works closely with 
the National Invasive Species Council. In addition, we added 
information on the Aquatic Nuisance Species Task Force. 

14. The use of an existing interagency body to serve as a coordinating 
entity to help federal agencies prevent the importation of animals 
that may be carrying zoonotic and animal diseases was not mentioned in 
experts' responses to the first round of our survey, which was the 
basis for our second round of survey questions. Placing a coordinating 
entity for live animal imports within an existing interagency body may 
help in avoiding duplication of effort. We recommended the development 
and implementation of a strategy to help the agencies 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). If the agencies 
determine that it is appropriate to place the coordinating entity for 
live animal imports within an existing interagency body, this response 
would be consistent with our recommendation. 

15. We modified the report to clarify that agencies focus on only 
those components of the process each agency controls under its 
statutory authority. As noted in the report, in January 2010, the 
Secretary of the Interior directed FWS to comprehensively review 
statutory authorities and regulations. 

16. We modified the report to add that an evaluation of the amount of 
FWS's funding and level of staff for live animal imports has occurred. 

17. We modified the report to clarify that FWS requires that all 
carriers transporting wild mammals and birds to the United States have 
a certificate of veterinary medical inspection signed by a 
veterinarian. 

[End of section] 

Appendix XI: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Lisa Shames, (202) 512-3841 or shamesl@gao.gov: 

Staff Acknowledgments: 

In addition to the individual named above, Thomas M. Cook, Assistant 
Director; Kevin S. Bray; Gary T. Brown; Elizabeth Curda; Mary Denigan- 
Macauley; Elizabeth Dunn; Jeanette Jacobs; Mitchell Karpman; Diane G. 
LoFaro; Terry Richardson; Cynthia Saunders; Carol Herrnstadt Shulman; 
Kathryn A. Smith; Kiki Theodoropoulos; and Megan M. Taylor made key 
contributions to this report. 

[End of section] 

Related GAO Products: 

National Security: Key Challenges and Solutions to Strengthen 
Interagency Collaboration. [hyperlink, 
http://www.gao.gov/products/GAO-10-822T]. Washington, D.C.: June 9, 
2010. 

Language Access: Selected Agencies Can Improve Services to Limited 
English Proficient Persons. [hyperlink, 
http://www.gao.gov/products/GAO-10-91]. Washington, D.C.: April 26, 
2010. 

Biosurveillance: Developing a Collaboration Strategy Is Essential to 
Fostering Interagency Data and Resource Sharing. [hyperlink, 
http://www.gao.gov/products/GAO-10-171]. Washington, D.C.: December 
18, 2009. 

Food Safety: Agencies Need to Address Gaps in Enforcement and 
Collaboration to Enhance Safety of Imported Food. [hyperlink, 
http://www.gao.gov/products/GAO-09-873]. Washington, D.C.: September 
15, 2009. 

Seafood Fraud: FDA Program Changes and Better Collaboration among Key 
Federal Agencies Could Improve Detection and Prevention. [hyperlink, 
http://www.gao.gov/products/GAO-09-258]. Washington, D.C.: February 
19, 2009. 

Veterinarian Workforce: Actions Are Needed to Ensure Sufficient 
Capacity for Protecting Public and Animal Health. [hyperlink, 
http://www.gao.gov/products/GAO-09-178]. Washington, D.C.: February 4, 
2009. 

Natural Resource Management: Opportunities Exist to Enhance Federal 
Participation in Collaborative Efforts to Reduce Conflicts and Improve 
Natural Resource Conditions. [hyperlink, 
http://www.gao.gov/products/GAO-08-262]. Washington, D.C.: February 
12, 2008. 

National Animal Identification System: USDA Needs to Resolve Several 
Key Implementation Issues to Achieve Rapid and Effective Disease 
Traceback. [hyperlink, http://www.gao.gov/products/GAO-07-592]. 
Washington, D.C.: July 6, 2007. 

Avian Influenza: USDA Has Taken Important Steps to Prepare for 
Outbreaks, but Better Planning Could Improve Response. [hyperlink, 
http://www.gao.gov/products/GAO-07-652]. Washington, D.C.: June 11, 
2007. 

Homeland Security: Management and Coordination Problems Increase the 
Vulnerability of U.S. Agriculture to Foreign Pests and Disease. 
[hyperlink, http://www.gao.gov/products/GAO-06-644]. Washington, D.C.: 
May 19, 2006. 

Results-Oriented Government: Practices That Can Help Enhance and 
Sustain Collaboration among Federal Agencies. [hyperlink, 
http://www.gao.gov/products/GAO-06-15]. Washington, D.C.: October 21, 
2005. 

Managing for Results: Barriers to Interagency Coordination. 
[hyperlink, http://www.gao.gov/products/GAO/GGD-00-106]. Washington, 
D.C.: March 29, 2000. 

Agency Performance Plans: Examples of Practices That Can Improve 
Usefulness to Decisionmakers. [hyperlink, 
http://www.gao.gov/products/GAO/GGD/AIMD-99-69]. Washington, D.C.: 
February 26, 1999. 

Agencies' Annual Performance Plans Under the Results Act: An 
Assessment Guide to Facilitate Congressional Decisionmaking. 
[hyperlink, http://www.gao.gov/products/GAO/GGD/AIMD-10.1.188]. 
Washington, D.C.: February 1998. 

Wildlife Protection: Fish and Wildlife Service's Inspection Program 
Needs Strengthening. [hyperlink, 
http://www.gao.gov/products/GAO/RCED-95-8]. Washington, D.C.: December 
29, 1994. 

[End of section] 

Footnotes: 

[1] GAO, Results-Oriented Government: Practices That Can Help Enhance 
and Sustain Collaboration among Federal Agencies, [hyperlink, 
http://www.gao.gov/products/GAO-06-15] (Washington, D.C.: Oct. 21, 
2005). 

[2] GAO, Avian Influenza: USDA Has Taken Important Steps to Prepare 
for Outbreaks, but Better Planning Could Improve Response, [hyperlink, 
http://www.gao.gov/products/GAO-07-652] (Washington, D.C.: June 11, 
2007). 

[3] Other federal agencies also have specific responsibilities. For 
example, under the Marine Mammal Protection Act, the Department of 
Commerce's National Marine Fisheries Service administers prohibitions 
on the importation of certain marine mammals. 

[4] Invasive species may prey upon, displace, or otherwise harm native 
species. Some invasive species also alter ecosystem processes, 
transport disease, interfere with crop production, or cause disease in 
animals or humans. 

[5] According to APHIS and FWS officials, the two data systems may 
overlap because the agencies regulate some of the same species, such 
as birds and certain fish. As such, the total number of imported 
animals is not the sum of each agency's total number of reported 
animals. 

[6] GAO, Managing for Results: Barriers to Interagency Coordination, 
[hyperlink, http://www.gao.gov/products/GAO/GGD-00-106] (Washington, 
D.C.: Mar. 29, 2000). 

[7] [hyperlink, http://www.gao.gov/products/GAO-06-15]. 

[8] American Veterinary Medical Association, One Health: A New 
Professional Imperative (2008). 

[9] Exec. Order No. 13,112, 64 Fed. Reg. 6183(Feb. 3, 1999). 

[10] National Research Council of the National Academies, Committee on 
Assessing the Nation's Framework for Addressing Animal Diseases, 
Animal Health at the Crossroads: Preventing, Detecting, and Diagnosing 
Animal Diseases (Washington, D.C.: 2005). 

[11] Defenders of Wildlife, Broken Screens: The Regulation of Live 
Animal Imports in the United States (Washington, D.C.: 2007). 

[12] B. I. Pavlin, L. M. Schloegel, and P. Daszak, "Risk of Importing 
Zoonotic Diseases through Wildlife Trade, United States," Emerging 
Infectious Diseases, vol. 15, no. 11 (November 2009). 

[13] U.S. Department of Agriculture, Office of Inspector General, 
Audit Report: USDA's Controls Over Animal Import Centers, Report No. 
33601-11-Ch (Washington, D.C.: August 2010). 

[14] U.S. Department of Agriculture, Office of Inspector General, 
Midwest Region, Audit Report: USDA's Controls Over the Importation and 
Movement of Live Animals, Report No. 50601-0012-Ch (Washington, D.C.: 
March 2008). 

[15] U.S. Department of Agriculture, Animal and Plant Health 
Inspection Service, VS2015: A Strategic Look at the Future of APHIS' 
Veterinary Services, (October 2008). 

[16] FWS clarified the number of species listed as injurious under the 
Lacey Act as at least 231 species, including 100 species of walking 
catfish, 60 species of flying fox or fruit bats, 28 species of 
snakehead fish, and 19 species of mongoose. 

[17] On March 23, 2010, the House Committee on Natural Resources' 
Subcommittee on National Parks, Forests and Public Lands and 
Subcommittee on Insular Affairs, Oceans and Wildlife held a joint 
hearing, "How to Manage Large Constrictor Snakes And Other Invasive 
Species." 

[18] [hyperlink, http://www.gao.gov/products/GAO/GGD-00-106]. 

[19] The Department of Health and Human Services is currently 
reviewing public comments on its strategic plan. 

[20] [hyperlink, http://www.gao.gov/products/GAO-06-15]. 

[21] [hyperlink, http://www.gao.gov/products/GAO-06-15]. 

[22] National Aquatic Animal Health Task Force, National Aquatic 
Animal Health Plan (August 2008). 

[23] This plan was developed by a task force commissioned by the Joint 
Subcommittee on Aquaculture, which was authorized by the National 
Aquaculture Act of 1980. Its mission is to increase the overall 
effectiveness and productivity of federal aquaculture research, 
transfer, and assistance programs. 

[24] According to the task force, aquatic nuisance species are aquatic 
and terrestrial organisms, introduced into new habitats throughout the 
United States and other areas of the world, that produce harmful 
impacts on aquatic natural resources in these ecosystems and on the 
human use of these resources. 

[25] Pub .L. No. 101-646 104 Stat. 2761. 

[26] [hyperlink, http://www.gao.gov/products/GAO-06-15]. 

[27] GAO, National Security: Key Challenges and Solutions to 
Strengthen Interagency Collaboration, [hyperlink, 
http://www.gao.gov/products/GAO-10-822T] (Washington, D.C.: June 9, 
2010). 

[28] According to the Department of the Interior, such an evaluation 
has occurred at the direction of the Secretary of the Interior. FWS 
was directed to comprehensively review its statutory authorities, 
regulations, and processes under the injurious wildlife provisions of 
the Lacey Act, and recommendations are moving presently through the 
FWS and department approval processes. 

[29] [hyperlink, http://www.gao.gov/products/GAO-06-15]. 

[30] [hyperlink, http://www.gao.gov/products/GAO-06-15]. 

[31] Section 405 of the Security and Accountability for Every Port Act 
of 2006 (SAFE Port Act), Pub. L. No. 109-347, 120 Stat. 1884, requires 
the Secretary of the Treasury to oversee the establishment of a 
comprehensive information system, and requires a report to be 
submitted to the Committee on Finance, United States Senate, and 
Committee on Ways and Means, House of Representatives, each fiscal 
year. The most recent report was submitted in September 2009. 

[32] GAO, Managing for Results: Enhancing Agency Use of Performance 
Information for Management Decision Making, [hyperlink, 
http://www.gao.gov/products/GAO-05-927] (Washington, D.C.: September 
2005). 

[33] APHIS, Veterinary Services Strategic Plan, FY06-FY11. 

[34] CBP, Strategic Plan FY2009-2014 (Washington, D.C.: July 2009) and 
CBP, Field Operations Strategic Plan FY2007-2011 (Washington, D.C.: 
September 2006). 

[35] CDC, FY2008 Centers for Disease Control and Prevention Annual 
Performance Report. 

[36] FWS, Office of Law Enforcement Strategic Plan 2006-2010 (December 
2005). 

[37] Imported live bats do not have a specific regulation. However, 
CDC regulates bats as a vector for infectious diseases. CDC defines a 
vector as an animal that conveys or is capable of conveying infectious 
agents from a person or animal to another person or animal. 

[End of section] 

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