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United States Government Accountability Office: GAO: 

Testimony Before the Subcommittee on Horticulture and Organic 
Agriculture, Committee on Agriculture, House of Representatives: 

For Release on Delivery: 
Expected at 10:00 a.m. EDT: 
Wednesday, October 3, 2007: 

Agricultural Quarantine Inspection Program: Management Problems May 
Increase Vulnerability of U.S. Agriculture to Foreign Pests and 
Diseases: 

Statement of Lisa Shames: 
Director: 
Natural Resources and Environment

GAO-08-96T: 

GAO Highlights:

Highlights of GAO-08-96T, a testimony before the Subcommittee on 
Horticulture and Organic Agriculture, Committee on Agriculture House of 
Representatives.

Why GAO Did This Study:

U.S. agriculture generates over $1 trillion in economic activity 
annually, but concerns exist about its vulnerability to foreign pests 
and diseases. Under the agricultural quarantine inspection (AQI) 
program, passengers and cargo are inspected at U.S. ports of entry to 
intercept prohibited material and pests. The Homeland Security Act of 
2002 transferred responsibility for inspections from the U.S. 
Department of Agriculture’s (USDA) Animal and Plant Health Inspection 
Service (APHIS) to the Department of Homeland Security’s (DHS) Customs 
and Border Protection (CBP). APHIS retained some AQI-related 
responsibilities such as policy setting and training.

This testimony is based on issued GAO reports and discusses (1) steps 
DHS and USDA took that were intended to strengthen the AQI program, (2) 
views of agriculture specialists of their work experience since the 
transfer, (3) management problems. As part of these reports, GAO 
surveyed a representative sample of agriculture specialists on their 
work experiences, analyzed inspection and interception data, and 
interviewed agency officials.   

What GAO Found:

CBP and APHIS have taken steps intended to strengthen the AQI program 
since transfer of inspection responsibilities from USDA to DHS in March 
2003. Specifically, CBP and APHIS have expanded the hours and developed 
a national standard for agriculture training; given agricultural 
specialists access to a computer system that is to better target 
inspections at ports; and established a joint review process for 
assessing compliance with the AQI program on a port-by-port basis. In 
addition, CBP has created new agricultural liaison positions at the 
field office level to advise regional port directors on agricultural 
issues. We have not assessed the implementation and effectiveness of 
these actions. 

However, GAO’s survey of CBP agriculture specialists found that many 
believed the agriculture inspection mission had been compromised by the 
transfer. Although 86 percent of agriculture specialists reported 
feeling very well or somewhat prepared for their duties, 59 and 60 
percent of specialists answered that they were conducting fewer 
inspections and interceptions, respectively, of prohibited agricultural 
items since the transfer. When asked what is going well with respect to 
their work, agricultural specialists identified working relationships 
(18 percent), nothing (13 percent), salary and benefits (10 percent), 
training (10 percent), and general job satisfaction (6 percent). When 
asked what areas should be changed or improved, they identified working 
relationships (29 percent), priority given to the agriculture mission 
(29 percent), problems with the CBP chain of command (28 percent), 
training (19 percent), and inadequate equipment and supplies (17 
percent). Based on private and public sector experiences with mergers, 
these morale issues are not unexpected because employees often worry 
about their place in the new organization.

CBP must address several management problems to reduce the 
vulnerability of U.S. agriculture to foreign pests and diseases. 
Specifically, as of May 2006, CBP had not used available inspection and 
interception data to evaluate the effectiveness of the AQI program. CBP 
also had not developed sufficient performance measures to manage and 
evaluate the AQI program. CBP’s measures focused on only two pathways 
by which foreign pests and diseases may enter the country and pose a 
threat to U.S. agriculture. However, in early 2007, CBP initiated new 
performance measures to track interceptions of pests and quarantine 
materials at ports of entry. We have not assessed the effectiveness of 
these measures. In addition, CBP has allowed the agricultural canine 
program to deteriorate, including reductions in the number of canine 
teams and their proficiency. Lastly, CBP had not developed a risk-based 
staffing model for determining where to assign agricultural 
specialists. Without such a model, CBP did not know whether it had an 
appropriate number of agriculture specialists at each port. Subsequent 
to our review, CBP developed a model. As of mid-August 2007, CBP had 
2,116 agriculture specialists on staff, compared with 3,154 specialists 
needed according to the staffing model.

What GAO Recommends:

GAO previously recommended, in part, that DHS and USDA adopt meaningful 
performance measures for assessing the AQI programs’ effectiveness and 
develop a risk based staffing model.  The agencies generally concurred 
with these recommendations.

To view the full product, including the scope and methodology, click on 
[hyperlink, http://GAO-08-96T]. For more information, contact Lisa 
Shames, (202) 512-3841 or shamesl@gao.gov.

[End of section] 

Mr. Chairman and Members of the Subcommittee: We are pleased to be here 
to discuss our work on the agricultural quarantine inspection (AQI) 
program. Under the AQI program, international passengers and cargo are 
inspected at U.S. ports of entry to seize prohibited material and 
intercept foreign agricultural pests. The AQI program is the first line 
of defense for agriculture, which is the largest industry and employer 
in the United States, generating more than $1 trillion in economic 
activity annually. The entry of foreign pests and diseases can harm 
this important sector of our economy, the environment, plant and animal 
health, the food supply, and public health. The U.S. Department of 
Agriculture (USDA) estimates that foreign pests and diseases cost the 
American economy tens of billions of dollars annually in lower crop 
values, eradication programs, and emergency payments to farmers. The 
terrorist attacks of September 11, 2001 heightened concerns about 
agriculture’s vulnerability to terrorism, including the deliberate 
introduction of livestock, poultry, and crop diseases, such as foot-and-
mouth disease or avian influenza. 

The Homeland Security Act of 2002 transferred responsibility for 
agricultural quarantine inspections from USDA to the Department of 
Homeland Security’s (DHS) Customs and Border Protection (CBP) effective 
in March 2003, but left certain other agricultural quarantine 
responsibilities with USDA’s Animal and Plant Health Inspection Service 
(APHIS). APHIS’s responsibilities are to set agriculture inspection 
policy, provide related training, and collect AQI user fees. Beginning 
in March 2003, more than 1,800 agriculture specialists who had formerly 
reported to USDA became CBP employees, as CBP incorporated the 
protection of U.S. agriculture into its primary anti-terrorism mission. 
In addition to protecting U.S. agriculture and other functions, CBP’s 
mission is to detect and prevent terrorists and their weapons from 
entering the United States, interdict illegal drugs and other 
contraband, and apprehend individuals who are attempting to enter the 
United States illegally. CBP faces a daunting task in protecting U.S. 
agriculture from accidental or deliberate introduction of diseases or 
pests, while attending to these missions. 

After examining concerns that the transfer of agricultural inspections 
to CBP could shift the focus away from agriculture to CBP’s other 
mission priorities, we reported in May 2006 on the coordination between 
USDA and DHS and made several recommendations to help ensure that U.S. 
agriculture is protected from accidentally or intentionally introduced 
pests and diseases. [Footnote 1] USDA and DHS generally agreed with the 
report’s recommendations. In preparing this report, we surveyed a 
representative sample of CBP’s agriculture specialists on their work 
experiences before and after the transfer and included the responses to 
the survey’s 31 multiple-choice questions in the report.[ Footnote 2] 
The survey also asked two open-ended questions: (1) What is going well 
with respect to your work as an agriculture specialist? and (2) What 
would you like to see changed or improved with respect to your work as 
an agriculture specialist? In November 2006, we separately reported on 
the common themes in the narrative responses. [Footnote 3] My testimony 
today is based on these two reviews. We conducted the reviews from 
April 2005 through October 2006 in accordance with generally accepted 
government auditing standards. 

This morning I will focus on three key findings: 

* CBP and APHIS have taken steps intended to strengthen the AQI program 
since the transfer of inspection responsibilities from USDA to DHS 
following passage of the Homeland Security Act of 2002. CBP and APHIS 
have expanded the hours of agricultural training for CBP officers and 
developed a national standard for this training; given agriculture 
specialists access to CBP’s Automated Targeting System to focus 
inspections on higher-risk passengers and cargo; and established a 
joint review process for assessing compliance with the AQI program on a 
port-by-port basis. Lastly, CBP has created new agricultural liaison 
positions at the field office level to advise regional port directors 
on agricultural issues. We have not assessed the implementation and 
effectiveness of these actions.

* Our survey of CBP agriculture specialists found that many believe the 
agriculture inspection mission has been compromised by the transfer. 
Although 86 percent of agriculture specialists reported feeling very 
well prepared or somewhat prepared for their duties, 59 and 60 percent 
of specialists answered that they were conducting fewer inspections and 
interceptions, respectively, of prohibited agricultural items since the 
transfer. When asked what is going well with respect to their work, 
agriculture specialists identified working relationships (18 percent), 
nothing (13 percent), salary and benefits (10 percent), training (10 
percent), and general job satisfaction (6 percent). When asked what 
areas should be changed or improved, they identified working 
relationships (29 percent), priority given to the agriculture mission 
(29 percent), problems with the CBP chain of command (28 percent), 
training (19 percent), and inadequate equipment and supplies (17 
percent). Agriculture specialists typically provided more examples or 
went into greater detail in answering these questions and submitted 185 
pages of comments about what needs improvement—roughly 4 times more 
than their responses about what was going well. Based on private and 
public sector experiences with mergers, these morale issues are not 
unexpected because employees often worry about their place in the new 
organization. 

* CBP must address several management challenges to reduce the 
vulnerability of U.S. agriculture to foreign pests and diseases. 
Specifically, as of our May 2006 report, CBP had not used available 
inspection and interception data to evaluate the effectiveness of the 
AQI program, although the agency told us it has subsequently taken some 
steps—such as publishing monthly reports on inspections, arrivals, and 
seizures of various prohibited items, including agricultural quarantine 
material and pest interceptions—that we have not evaluated. Moreover, 
at the time of our May 2006 review, CBP had not developed sufficient 
performance measures to manage and evaluate the AQI program. CBP’s 
measures focused only on two pathways—the percentage of (1) 
international air passengers and (2) border vehicle passengers that 
comply with AQI regulations—by which foreign pests and diseases may 
enter the country, but did not consider other important pathways such 
as commercial aircraft, vessels, and truck cargo that may pose a risk 
to U.S. agriculture. In early 2007, a joint team from CBP and APHIS 
agreed to implement additional performance measures for AQI activities 
in all major pathways at ports of entry. Some of these measures were 
implemented in fiscal year 2007; others are planned for fiscal years 
2008 and 2009. However, we have not evaluated the adequacy of these new 
measures for assessing the AQI program’s effectiveness at intercepting 
foreign pests and diseases. In addition, CBP has allowed the 
agriculture canine program to deteriorate, with fewer canine teams and 
declining proficiency scores. In the past, these dogs have been a key 
tool for targeting passengers and cargo for detailed inspections. 
Lastly, CBP does not have the agriculture specialists needed to perform 
its AQI responsibilities based on its staffing model. Specifically, as 
of mid-August 2007, CBP said it had 2,116 agriculture specialists on 
staff, compared to 3,154 specialists needed, according to the model. 

CBP and APHIS Have Taken Steps Intended to Strengthen the AQI Program: 

CBP and APHIS have taken four major steps intended to strengthen the 
AQI program since the transfer of responsibilities following passage of 
the Homeland Security Act of 2002. To date, we have not done work to 
assess the implementation and effectiveness of these actions. 

First, CBP and APHIS expanded the hours of training on agricultural 
issues for CBP officers, whose primary duty is customs and immigration 
inspection, and for CBP agriculture specialists, whose primary duty is 
agricultural inspection. Specifically, newly hired CBP officers receive 
16 hours of training on agricultural issues, whereas before the 
transfer to CBP, customs inspectors received 4 hours of agricultural 
training, and immigration inspectors received 2 hours. CBP and APHIS 
also expanded agriculture training for CBP officers at their respective 
ports of entry to help them make better-informed decisions on 
agricultural items at high-volume border traffic areas. Additionally, 
CBP and APHIS have standardized the in-port training program and have 
developed a national standard for agriculture specialists with a 
checklist of activities for agriculture specialists to master. These 
activities are structured into an 8-week module on passenger inspection 
procedures and a 10-week module on cargo inspection procedures. Based 
on our survey of agriculture specialists, we estimate that 75 percent 
of specialists hired by CBP believe that they received sufficient 
training (on the job and at the Professional Development Center) to 
enable them to perform their agriculture inspection duties. [Footnote 
4] 

Second, CBP and APHIS have taken steps designed to better target 
shipments and passengers that potentially present a high risk to U.S. 
agriculture. Specifically, some CBP agriculture specialists received 
training and were given access to CBP’s Automated Targeting System, a 
computer system that, among other things, is designed to focus limited 
inspection resources on higher-risk passengers and cargo and facilitate 
expedited clearance or entry for low-risk passengers and cargo. This 
system gives agriculture specialists detailed information from cargo 
manifests and other documents that shipping companies are required to 
submit before the ship arrives in a port to help them select high-risk 
cargo for inspection. CBP and APHIS headquarters personnel also use 
this information to identify companies that had previously violated 
U.S. quarantine laws. For example, according to a senior APHIS 
official, the two agencies used this system to help identify companies 
that have used seafood containers to smuggle uncooked poultry products 
from Asia, which are currently banned because of concerns over avian 
influenza. 

Third, CBP and APHIS established a formal assessment process intended 
to ensure that ports of entry carry out agricultural inspections in 
accordance with the agricultural quarantine inspection program’s 
regulations, policies, and procedures. The process, called Joint Agency 
Quality Assurance Reviews, covers topics such as (1) CBP coordination 
with other federal agencies; (2) agriculture specialist training; (3) 
specialist access to regulatory manuals; and (4) specialist adherence 
to processes for handling violations at the port, inspecting passenger 
baggage and vehicles, and intercepting, seizing, and disposing of 
confiscated materials. The reviews address best practices and 
deficiencies at each port and make recommendations for corrective 
actions to be implemented within 6 weeks. For example, regarding best 
practices, a review of two ports found that the placement of CBP, 
APHIS, and Food and Drug Administration staff in the same facility 
enhanced their coordination. This review also lauded their targeting of 
non-agricultural products that are packed with materials, such as wood, 
that may harbor pests or diseases that could pose a risk to U.S. 
agriculture. Regarding deficiencies, this review found that the number 
of CBP agriculture specialists in each port was insufficient, and that 
the specialists at one of the ports were conducting superficial 
inspections of commodities that should have been inspected more 
intensely. According to CBP, the agency took actions to correct these 
deficiencies, although we have not evaluated those actions. In 
September 2007, CBP said that the joint review team had conducted 13 
reviews in fiscal years 2004 through 2006, and 7 reviews were completed 
or underway for fiscal year 2007. Seven additional reviews are planned 
for fiscal year 2008. 

Lastly, in May 2005, CBP required each director in its 20 district 
field offices to appoint an agriculture liaison, with background and 
experience as an agriculture specialist, to provide CBP field office 
directors with agriculture-related input for operational decisions and 
agriculture specialists with senior-level leadership. The agriculture 
liaisons are to, among other things, advise the director of the field 
office on agricultural functions; provide oversight for data 
management, statistical analysis, and risk management; and coordinate 
agriculture inspection alerts. CBP officials told us that all district 
field offices had established the liaison position as of January 2006. 
Since the creation of the position, agriculture liaisons have 
facilitated the dissemination of urgent alerts from APHIS to CBP. They 
also provide information back to APHIS. For example, following a large 
increase in the discovery of plant pests at a port in November 2005, 
the designated agriculture liaison sent notice to APHIS, which then 
issued alerts to other ports. APHIS and CBP subsequently identified 
this agriculture liaison as a contact for providing technical advice 
for inspecting and identifying this type of plant pest. 

Many Agriculture Specialists Believe that the Agricultural Mission Has 
Been Compromised: 

In fiscal year 2006, we surveyed a representative sample of CBP 
agriculture specialists regarding their experiences and opinions since 
the transfer of the AQI program from APHIS to CBP. [Footnote 5] In 
general, the views expressed by these specialists indicate that they 
believe that the agricultural inspection mission has been compromised. 
We note that morale issues are not unexpected in a merger such as the 
integration of the AQI mission and staff into CBP’s primary anti-
terrorism mission. GAO has previously reported on lessons learned from 
major private and public sector experiences with mergers that DHS could 
use when combining its various components into a unified department. 
[Footnote 6] Among other things, productivity and effectiveness often 
decline in the period following a merger, in part because employees 
often worry about their place in the new organization. 

Nonetheless, based on the survey results, while 86 percent of 
specialists reported feeling very well or somewhat prepared for their 
duties as an agriculture specialist, many believed that the agriculture 
mission had been compromised by the transfer. Specifically,

* 59 percent of experienced specialists indicated that they are doing 
either somewhat or many fewer inspections since the transfer, and 60 
percent indicated that they are doing somewhat or many fewer 
interceptions; 

* 63 percent of agriculture specialists believed their port did not 
have enough specialists to carry out agriculture-related duties; 

* Agriculture specialists reported that they spent 62 percent of their 
time on agriculture inspections, whereas 35 percent of their time was 
spent on non-agricultural functions such as customs and immigration 
inspections. 

In addition, there appear to be morale issues based on the responses to 
two open-ended questions: (1) What is going well with respect to your 
work as an agriculture specialist? and (2) What would you like to see 
changed or improved with respect to your work as an agriculture 
specialist? Notably, the question about what needs improving generated 
a total of 185 pages of comments—roughly 4 times more than that 
generated by the responses to our question on what was going well. 
Further, “Nothing is going well” was the second-most frequent response 
to the question on what is going well. 

We identified common themes in the agriculture specialists’ responses 
to our first question about what is going well with respect to their 
work as an agriculture specialist. The five most common themes were: 

* Working relationships. An estimated 18 percent of agriculture 
specialists cited the working relationship among agriculture 
specialists and CBP officers and management as positive. These 
specialists cited increasing respect and interest by non-specialists in 
the agriculture mission, and the attentiveness of CBP management to 
agriculture specialists’ concerns; 

* Nothing. An estimated 13 percent of agriculture specialists reported 
that nothing is going well with their work. For example, some 
respondents noted that the agriculture inspection mission has been 
compromised under CBP and that agriculture specialists are no longer 
important or respected by management; 

* Salary and Benefits. An estimated 10 percent of agriculture 
specialists expressed positive comments about their salary and 
benefits, with some citing increased pay under CBP, a flexible work 
schedule, increased overtime pay, and retirement benefits as reasons 
for their views; 

* Training. An estimated 8 percent of agriculture specialists 
identified elements of classroom and on-the-job training as going well. 
Some observed that new hires are well trained and that agriculture-
related classroom training at the Professional Development Center in 
Frederick, Maryland, is adequate for their duties; 

* General job satisfaction. An estimated 6 percent of agriculture 
specialists were generally satisfied with their jobs, reporting, among 
other things, that they were satisfied in their working relationships 
with CBP management and coworkers and that they believed in the 
importance of their work in protecting U.S. agriculture from foreign 
pests and diseases. 

In contrast, agriculture specialists wrote nearly 4 times as much in 
response to our question about what they would like to see changed or 
improved with respect to their work as agriculture specialists. In 
addition, larger proportions of specialists identified each of the top 
five themes. 

* Declining mission. An estimated 29 percent of agriculture specialists 
were concerned that the agriculture mission is declining because CBP 
has not given it adequate priority. Some respondents cited the increase 
in the number of cargo items and flights that are not inspected because 
of staff shortages, scheduling decisions by CBP port management, and 
the release of prohibited or restricted products by CBP officers; 

* Working relationships. An estimated 29 percent of the specialists 
expressed concern about their working relationships with CBP officers 
and management. Some wrote that CBP officers at their ports view the 
agriculture mission as less important than CBP’s other priorities, such 
as counternarcotics and anti-terrorism activities. Others noted that 
CBP management is not interested in, and does not support, agriculture 
inspections; 

* CBP chain of command. An estimated 28 percent of agriculture 
specialists identified problems with the CBP chain of command that 
impede timely actions involving high-risk interceptions, such as a lack 
of managers with an agriculture background and the agency’s rigid chain-
of-command structure. For example, agriculture specialists wrote that 
requests for information from USDA pest identification experts must be 
passed up the CBP chain of command before they can be conveyed to 
USDA;  

* Training. An estimated 19 percent of agriculture specialists believed 
that training in the classroom and on the job is inadequate. For 
example, some respondents expressed concern about a lack of courses on 
DHS’s targeting and database systems, which some agriculture 
specialists use to target high-risk shipments and passengers. Also, 
some agriculture specialists wrote that on-the-job training at their 
ports is poor, and that CBP officers do not have adequate agriculture 
training to recognize when to refer items to agriculture specialists 
for inspection;  

* Lack of equipment. An estimated 17 percent of agriculture specialists 
were concerned about a lack of equipment and supplies. Some respondents 
wrote that the process for purchasing items under CBP results in delays 
in acquiring supplies and that there is a shortage of agriculture-
specific supplies, such as vials, gloves, and laboratory equipment.  

These themes are consistent with responses to relevant multiple-choice 
questions in the survey. For example, in response to one of these 
questions, 61 percent of agriculture specialists believed their work 
was not respected by CBP officers, and 64 percent believed their work 
was not respected by CBP management. 

Management Problems May Leave U.S. Agriculture Vulnerable to Foreign 
Pests and Diseases:  

Although CBP and APHIS have taken a number of actions intended to 
strengthen the AQI program since its transfer to CBP, several 
management problems remain that may leave U.S. agriculture vulnerable 
to foreign pests and diseases. Most importantly, CBP has not used 
available data to evaluate the effectiveness of the program. These data 
are especially important in light of many agriculture specialists’ 
views that the agricultural mission has been compromised and can help 
CBP determine necessary actions to close any performance gaps. 
Moreover, at the time of our May 2006 review, CBP had not developed 
sufficient performance measures to manage and evaluate the AQI program, 
and the agency had allowed the agricultural canine program to 
deteriorate. Furthermore, based on its staffing model, CBP does not 
have the agriculture specialists needed to perform its AQI 
responsibilities.  

CBP has not used available data to monitor changes in the frequency 
with which prohibited agricultural materials and reportable pests are 
intercepted during inspection activities. CBP agriculture specialists 
record monthly data in the Work Accomplishment Data System for each 
port of entry, including (1) arrivals of passengers and cargo to the 
United States via airplane, ship, or vehicle; (2) agricultural 
inspections of arriving passengers and cargo; and (3) inspection 
outcomes, i.e., seizures or detections of prohibited (quarantined) 
agricultural materials and reportable pests. As of our May 2006 report, 
CBP had not used these data to evaluate the effectiveness of the AQI 
program.  

For example, our analysis of the data for the 42 months before and 31 
months after the transfer of responsibilities from APHIS to CBP shows 
that average inspection and interception rates have changed 
significantly in some geographical regions of the United States, with 
rates increasing in some regions and decreasing in others. (Appendixes 
I and II provide more information on average inspection and 
interception rates before and after the transfer from APHIS to CBP.) 
Specifically, average inspection rates declined significantly in the 
Baltimore, Boston, Miami, and San Francisco district field offices, and 
in preclearance locations in Canada, the Caribbean, and Ireland. 
Inspection rates increased significantly in seven other 
districts—Buffalo, El Paso, Laredo, San Diego, Seattle, Tampa, and 
Tucson. In addition, the average rate of interceptions decreased 
significantly at ports in six district field offices—El Paso, New 
Orleans, New York, San Juan, Tampa, and Tucson—while average 
interception rates have increased significantly at ports in the 
Baltimore, Boston, Detroit, Portland, and Seattle districts.  

Of particular note are three districts that have experienced a 
significant increase in their rate of inspections and a significant 
decrease in their interception rates since the transfer. Specifically, 
since the transfer, the Tampa, El Paso, and Tucson districts appear to 
be more efficient at inspecting (e.g., inspecting a greater proportion 
of arriving passengers or cargo) but less effective at interceptions 
(e.g., intercepting fewer prohibited agricultural items per 
inspection). Also of concern are three districts—San Juan, New Orleans, 
and New York—that are inspecting at about the same rate, but 
intercepting less, since the transfer.  

When we showed the results of our analysis to senior CBP officials, 
they were unable to explain these changes or determine whether the 
current rates were appropriate relative to the risks, staffing levels, 
and staff expertise associated with individual districts or ports of 
entry. These officials also noted that CBP has had problems 
interpreting APHIS data reports because CBP lacked staff with expertise 
in agriculture and APHIS’s data systems in some district offices. As of 
our May 2006 report, CBP had not yet completed or implemented its plan 
to add agriculture-related data to its system for monitoring customs 
inspections. However, in September 2007, CBP said it had taken steps to 
use these data to evaluate the program’s effectiveness. For example, 
CBP publishes a monthly report that includes analysis of efficiency 
inspections, arrivals, exams, and seizures of prohibited items, 
including agricultural quarantine material and pest interceptions, for 
each pathway. CBP also conducts a mid-year analysis of APHIS and CBP 
data to assess agricultural inspection efficiency at ports of entry. 
While these appear to be positive steps, we have not assessed their 
adequacy to measure the AQI program’s effectiveness. 

A second management problem for the AQI program is an incomplete set of 
performance measures to balance multiple responsibilities and 
demonstrate results. As of our May 2006 report, CBP had not developed 
and implemented its own performance measures for the program. Instead, 
according to CBP officials, CBP carried over two measures that APHIS 
had used to assess the AQI program before the transfer: the percentages 
of international air passengers and border vehicle passengers that 
comply with program regulations. However, these measures addressed only 
two pathways for agricultural pests, neglecting other pathways such as 
commercial aircraft, vessels, and truck cargo. Further, these 
performance measures did not provide information about changes in 
inspection and interception rates, which could help assess the 
efficiency and effectiveness of agriculture inspections in different 
regions of the country or at individual ports of entry. They also did 
not address the AQI program’s expanded mission—to prevent agro-
terrorism while facilitating the flow of legitimate trade and travel. 
In early 2007, a joint team from CBP and APHIS agreed to implement 
additional performance measures for AQI activities in all major 
pathways at ports of entry. Specifically, CBP said that in fiscal year 
2007 it implemented measures for the percentages of land border, air, 
and maritime regulated cargo and shipments in compliance with AQI 
regulations. Furthermore, the agency plans to add additional 
performance measures such as percentage of passengers, vehicles, or 
mail in compliance in fiscal years 2008 and 2009. However, we have not 
evaluated the adequacy of these new performance measures for assessing 
the AQI program’s effectiveness at intercepting foreign pests and 
diseases.  

Third, the number and proficiency of canine teams decreased 
substantially between the time of the transfer, March 2003, and the 
time of our review, May 2006. In the past, these dogs have been a key 
tool for targeting passengers and cargo for detailed inspections. 
Specifically, APHIS had approximately 140 canine teams nationwide at 
the time of the transfer, but CBP had only 80 such teams at the time of 
our review. With regard to proficiency, 60 percent of the 43 
agriculture canine teams tested by APHIS in 2005 failed proficiency 
tests. These tests require the dog to respond correctly in a 
controlled, simulated work environment and ensure that dogs are working 
effectively to catch potential prohibited agricultural material. In 
general, canine specialists we interviewed expressed concern that the 
proficiency of their dogs was deteriorating due to a lack of working 
time. That is, the dogs were sidelined while the specialists were 
assigned to other duties. In addition, based on our survey results, 46 
percent of canine specialists said they were directed to perform duties 
outside their primary canine duties daily or several times a week. 

Furthermore, 65 percent of canine specialists indicated that they 
sometimes or never had funding for training supplies. Another major 
change to the canine program, following the transfer, was CBP’s 
elimination of all canine management positions.  

Finally, based on its staffing model, CBP lacks adequate numbers of 
agriculture specialists to accomplish the agricultural mission. The 
Homeland Security Act authorized the transfer of up to 3,200 AQI 
personnel from USDA to DHS. In March 2003, APHIS transferred a total of 
1,871 agriculture specialist positions, including 317 vacancies, to CBP 
and distributed those positions across CBP’s 20 district field offices, 
encompassing 139 ports of entry. Because of the vacancies, CBP lacked 
adequate numbers of agriculture specialists from the beginning and had 
little assurance that appropriate numbers of specialists were staffed 
at each port of entry. Although CBP has made some progress in hiring 
agriculture specialists since the transfer, we previously reported that 
CBP lacked a staffing model to ensure that more than 630 newly hired 
agriculture specialists were assigned to the ports with the greatest 
need, and to ensure that each port had at least some experienced 
specialists. Accordingly, in May 2006 we recommended that APHIS and CBP 
work together to develop a national staffing model to ensure that 
agriculture staffing levels at each port are sufficient. Subsequently, 
CBP developed a staffing model for its ports of entry and provided GAO 
with its results. Specifically, as of mid-August 2007, CBP said it had 
2,116 agriculture specialists on staff, compared to 3,154 such 
specialists needed according to the model. 

Conclusions:  

The global marketplace of agricultural trade and international travel 
has increased the number of pathways for the movement and introduction 
into the United States of foreign and invasive agricultural pests and 
diseases such as foot-and-mouth disease and avian influenza. Given the 
importance of agriculture to the U.S. economy, ensuring the 
effectiveness of federal programs to prevent accidental or deliberate 
introduction of potentially destructive organisms is critical. 
Accordingly, effective management of the AQI program is necessary to 
ensure that agriculture issues receive appropriate attention. Although 
we have reported that CBP and APHIS have taken steps to strengthen 
agricultural quarantine inspections, many agriculture specialists 
believe that the agricultural mission has been compromised. While 
morale issues, such as the ones we identified, are to be expected in 
the merger establishing DHS, CBP had not used key data to evaluate the 
program’s effectiveness and could not explain significant increases and 
decreases in inspections and interceptions. In addition, CBP had not 
developed performance measures to demonstrate that it is balancing its 
multiple mission responsibilities, and it does not have sufficient 
agriculture specialists based on its staffing model. Until the 
integration of agriculture issues into CBP’s overall anti-terrorism 
mission is more fully achieved, U.S. agriculture may be left vulnerable 
to the threat of foreign pests and diseases.  

Mr. Chairman, this concludes my prepared statement. I would be happy to 
respond to any questions that you or Members of the Subcommittee may 
have at this time. 

Contact and Staff Acknowledgments:  

Contact points for our Offices of Congressional Relations and Public 
Affairs may be found on the last page of this statement. For further 
information about this testimony, please contact Lisa Shames at (202) 
512-3841 or shamesl@gao.gov. Key contributors to this testimony were 
James Jones, Jr., Assistant Director, and Terrance Horner, Jr. Josey 
Ballenger, Kevin Bray, Chad M. Gorman, Lynn Musser, Omari Norman, 
Alison O’Neill, and Steve C. Rossman also made important 
contributions.  

[End of section]  

Appendix I: Average Inspection Rates Before and After the Transfer From 
APHIS to CBP:  

Table 1: Average Inspection Rates before and after the Transfer from 
APHIS to CBP:  

District field office: Atlanta; 
Average inspection rate before (October 1999-February 2003): 9.7; 
Average inspection rate after (March 2003-September 2005): 8.8; 
Difference[a]: -0.9; 
Statistical significance[b]: No.  

District field office: Baltimore; 
Average inspection rate before (October 1999-February 2003): 18.2; 
Average inspection rate after (March 2003-September 2005): 10.0; 
Difference[a]: -8.2; 
Statistical significance[b]: Yes.  

District field office: Boston; 
Average inspection rate before (October 1999-February 2003): 30.9; 
Average inspection rate after (March 2003-September 2005): 13.0; 
Difference[a]: -17.9; 
Statistical significance[b]: Yes.  

District field office: Buffalo; 
Average inspection rate before (October 1999-February 2003): 0.1; 
Average inspection rate after (March 2003-September 2005): 0.5; 
Difference[a]: 0.3; 
Statistical significance[b]: Yes.  

District field office: Chicago; 
Average inspection rate before (October 1999-February 2003): 18.0; 
Average inspection rate after (March 2003-September 2005): 18.5; 
Difference[a]: 0.5; 
Statistical significance[b]: No.  

District field office: Detroit; 
Average inspection rate before (October 1999-February 2003): 3.1; 
Average inspection rate after (March 2003-September 2005): 2.9; 
Difference[a]: -0.2; 
Statistical significance[b]: No.  

District field office: El Paso; 
Average inspection rate before (October 1999-February 2003): 2.9; 
Average inspection rate after (March 2003-September 2005): 4.4; 
Difference[a]: 1.5; 
Statistical significance[b]: Yes.  

District field office: Houston; 
Average inspection rate before (October 1999-February 2003): 13.2; 
Average inspection rate after (March 2003-September 2005): 12.1; 
Difference[a]: -1.1; 
Statistical significance[b]: No.  

District field office: Laredo; 
Average inspection rate before (October 1999-February 2003): 7.7; 
Average inspection rate after (March 2003-September 2005): 8.8; 
Difference[a]: 1.1; 
Statistical significance[b]: Yes.  

District field office: Los Angeles; Average inspection rate before 
(October 1999-February 2003): 12.5; Average inspection rate after 
(March 2003-September 2005): 10.4; Difference[a]: -2.1; 
Statistical significance[b]: No.  

District field office: Miami; 
Average inspection rate before (October 1999-February 2003): 35.8; 
Average inspection rate after (March 2003-September 2005): 23.1; 
Difference[a]: -12.7; 
Statistical significance[b]: Yes.  

District field office: New Orleans; Average inspection rate before 
(October 1999-February 2003): 37.6; Average inspection rate after 
(March 2003-September 2005): 41.8; Difference[a]: 4.3; 
Statistical significance[b]: No.  

District field office: New York; 
Average inspection rate before (October 1999-February 2003): 12.0; 
Average inspection rate after (March 2003-September 2005): 11.8; 
Difference[a]: -0.2; 
Statistical significance[b]: No.  

District field office: Preclearance[c]; Average inspection rate before 
(October 1999-February 2003): 7.8; Average inspection rate after (March 
2003-September 2005): 3.4; Difference[a]: -4.4; 
Statistical significance[b]: Yes.  

District field office: Portland; 
Average inspection rate before (October 1999-February 2003): 13.0; 
Average inspection rate after (March 2003-September 2005): 12.6; 
Difference[a]: -0.4; 
Statistical significance[b]: No.  

District field office: San Diego; 
Average inspection rate before (October 1999-February 2003): 12.6; 
Average inspection rate after (March 2003-September 2005): 16.3; 
Difference[a]: 3.6; 
Statistical significance[b]: Yes.  

District field office: San Francisco; Average inspection rate before 
(October 1999-February 2003): 40.4; Average inspection rate after 
(March 2003-September 2005): 19.0; Difference[a]: -21.4; 
Statistical significance[b]: Yes.  

District field office: San Juan; 
Average inspection rate before (October 1999-February 2003): 62.4; 
Average inspection rate after (March 2003-September 2005): 57.6; 
Difference[a]: -4.8; 
Statistical significance[b]: No.  

District field office: Seattle; 
Average inspection rate before (October 1999-February 2003): 2.3; 
Average inspection rate after (March 2003-September 2005): 3.1; 
Difference[a]: 0.8; 
Statistical significance[b]: Yes.  

District field office: Tampa; 
Average inspection rate before (October 1999-February 2003): 19.6; 
Average inspection rate after (March 2003-September 2005): 30.7; 
Difference[a]: 11.1; 
Statistical significance[b]: Yes.  

District field office: Tucson; 
Average inspection rate before (October 1999-February 2003): 2.6; 
Average inspection rate after (March 2003-September 2005): 4.0; 
Difference[a]: 1.4; 
Statistical significance[b]: Yes.  

Source: GAO calculations of APHIS’s Work Accomplishment Data System, 
fiscal years 2000 through 2005.  

[a] Because of rounding, values in the difference column may not equal 
the difference between rounded inspection rates.  

[b] Statistical significance for each field office was calculated at 
the 99.75 percent confidence level so that the confidence level of all 
21 statistical significance outcomes, collectively, is about 95 
percent.  

[c] Preclearance inspections were conducted at 14 locations in Canada, 
the Caribbean, and Ireland. Individuals arriving in the U.S. from those 
locations did not undergo another inspection upon arrival in the United 
States. According to CBP, preclearance inspections were done only as a 
pilot and not as an ongoing program within the agency. 

End of table]  

[End of section]  

Appendix II: Average Interception Rates Before and After the Transfer 
From APHIS to CBP:  

Table 2: Average Interception Rates before and after the Transfer from 
APHIS to CBP:  

District field office: Atlanta; 
Average interception rate before (October 1999-February 2003): 10.7; 
Average interception rate after (March 2003-September 2005): 11.5; 
Difference[a]: 0.8; 
Statistical significance[b]: No.  

District field office: Baltimore; 
Average interception rate before (October 1999-February 2003): 7.6; 
Average interception rate after (March 2003-September 2005): 10.4; 
Difference[a]: 2.8; 
Statistical significance[b]: Yes.  

District field office: Boston; 
Average interception rate before (October 1999-February 2003): 3.9; 
Average interception rate after (March 2003-September 2005): 12.4; 
Difference[a]: 8.5; 
Statistical significance[b]: Yes.  

District field office: Buffalo; 
Average interception rate before (October 1999-February 2003): 15.4; 
Average interception rate after (March 2003-September 2005): 30.2; 
Difference[a]: 14.8; 
Statistical significance[b]: No.  

District field office: Chicago; 
Average interception rate before (October 1999-February 2003): 6.8; 
Average interception rate after (March 2003-September 2005): 5.6; 
Difference[a]: -1.3; 
Statistical significance[b]: No.  

District field office: Detroit; 
Average interception rate before (October 1999-February 2003): 7.7; 
Average interception rate after (March 2003-September 2005): 20.7; 
Difference[a]: 13.0; 
Statistical significance[b]: Yes.  

District field office: El Paso; 
Average interception rate before (October 1999-February 2003): 9.4; 
Average interception rate after (March 2003-September 2005): 5.7; 
Difference[a]: -3.7; 
Statistical significance[b]: Yes.  

District field office: Houston; 
Average interception rate before (October 1999-February 2003): 7.9; 
Average interception rate after (March 2003-September 2005): 8.4; 
Difference[a]: 0.4; 
Statistical significance[b]: No.  

District field office: Laredo; 
Average interception rate before (October 1999-February 2003): 4.4; 
Average interception rate after (March 2003-September 2005): 3.9; 
Difference[a]: -0.5; 
Statistical significance[b]: No.  

District field office: Los Angeles; Average interception rate before 
(October 1999-February 2003): 7.4; Average interception rate after 
(March 2003-September 2005): 8.7; Difference[a]: 1.3; 
Statistical significance[b]: No.  

District field office: Miami; 
Average interception rate before (October 1999-February 2003): 5.3; 
Average interception rate after (March 2003-September 2005): 5.8; 
Difference[a]: 0.4; 
Statistical significance[b]: No.  

District field office: New Orleans; Average interception rate before 
(October 1999-February 2003): 5.9; Average interception rate after 
(March 2003-September 2005): 3.5; Difference[a]: -2.4; 
Statistical significance[b]: Yes.  

District field office: New York; 
Average interception rate before (October 1999-February 2003): 18.1; 
Average interception rate after (March 2003-September 2005): 10.2; 
Difference[a]: -7.9; 
Statistical significance[b]: Yes.  

District field office: Preclearance[c]; Average interception rate 
before (October 1999-February 2003): 10.1; Average interception rate 
after (March 2003-September 2005): 24.4; Difference[a]: 14.2; 
Statistical significance[b]: Yes.  

District field office: Portland; 
Average interception rate before (October 1999-February 2003): 9.6; 
Average interception rate after (March 2003-September 2005): 14.9; 
Difference[a]: 5.3; 
Statistical significance[b]: Yes.  

District field office: San Diego; 
Average interception rate before (October 1999-February 2003): 1.3; 
Average interception rate after (March 2003-September 2005): 1.4; 
Difference[a]: 0.2; 
Statistical significance[b]: No.  

District field office: San Francisco; Average interception rate before 
(October 1999-February 2003): 10.5; Average interception rate after 
(March 2003-September 2005): 10.6; Difference[a]: 0.1; 
Statistical significance[b]: No.  

District field office: San Juan; 
Average interception rate before (October 1999-February 2003): 6.1; 
Average interception rate after (March 2003-September 2005): 3.5; 
Difference[a]: -2.5; 
Statistical significance[b]: Yes.  

District field office: Seattle; 
Average interception rate before (October 1999-February 2003): 30.1; 
Average interception rate after (March 2003-September 2005): 46.5; 
Difference[a]: 16.4; 
Statistical significance[b]: Yes.  

District field office: Tampa; 
Average interception rate before (October 1999-February 2003): 8.3; 
Average interception rate after (March 2003-September 2005): 3.0; 
Difference[a]: -5.2; 
Statistical significance[b]: Yes.  

District field office: Tucson; 
Average interception rate before (October 1999-February 2003): 9.0; 
Average interception rate after (March 2003-September 2005): 7.0; 
Difference[a]: -2.0; 
Statistical significance[b]: Yes.  

Source: GAO calculations of APHIS’s Work Accomplishment Data System, 
fiscal years 2000 through 2005.  

[a] Because of rounding, values in the difference column may not equal 
the difference between rounded inspection rates.  

[b] Statistical significance for each field office was calculated at 
the 99.75 percent confidence level so that the confidence level of all 
21 statistical significance outcomes, collectively, is about 95 
percent.  

[c] Preclearance inspections were conducted at 14 locations in Canada, 
the Caribbean, and Ireland. Individuals arriving in the U.S. from those 
locations did not undergo another inspection upon arrival in the United 
States. According to CBP, preclearance inspections were done only as a 
pilot and not as an ongoing program within the agency. 

End of table]  

[End of section]  

Related GAO Products:  

Department of Homeland Security: Progress Report on Implementation of 
Mission and Management Functions. GAO-07-1240T. Washington, D.C.: 
September 18, 2007.  

Department of Homeland Security: Progress Report on Implementation of 
Mission and Management Functions. GAO-07-454. Washington, D.C.: August 
17, 2007.  

Customs Revenue: Customs and Border Protection Needs to Improve 
Workforce Planning and Accountability. GAO-07-529. Washington, D.C.: 
April 12, 2007.  

Homeland Security: Agriculture Specialists’ Views of Their Work 
Experiences after Transfer to DHS. GAO-07-209R. Washington, D.C.: 
November 14, 2006.  

Invasive Forest Pests: Recent Infestations and Continued 
Vulnerabilities at Ports of Entry Place U.S. Forests at Risk. GAO-06-
871T. Washington, D.C.: June 21, 2006.  

Homeland Security: Management and Coordination Problems Increase the 
Vulnerability of U.S. Agriculture to Foreign Pests and Disease. GAO-06-
644. Washington, D.C.: May 19, 2006.  

Homeland Security: Much Is Being Done to Protect Agriculture from a 
Terrorist Attack, but Important Challenges Remain. GAO-05-214. 
Washington, D.C.: March 8, 2005.  

Results-Oriented Cultures: Implementation Steps to Assist Mergers and 
Organizational Transformations. GAO-03-669. Washington, D.C.: July 2, 
2003.  

Mergers and Transformation: Lessons Learned for a Department of 
Homeland Security and Other Federal Agencies. GAO-03-293SP. Washington, 
D.C.: November 14, 2002.  

Homeland Security: Critical Design and Implementation Issues. GAO-02-
957T. Washington, D.C.: July 17, 2002. 

[End of section]  

Footnotes:  

[1] GAO, Homeland Security: Management and Coordination Problems 
Increase the Vulnerability of U.S. Agriculture to Foreign Pests and 
Disease, GAO-06-644 (Washington, D.C.: May 19, 2006).  

[2] Specifically, we drew a random probability sample of 831 
agriculture specialists from the approximately 1,800 specialists 
(current as of Oct. 14, 2005) in CBP. In general, strata were defined 
by the number of specialists at the respective ports. We conducted a 
web-based survey of all specialists in the sample. Each sampled 
specialist was subsequently weighted in the analysis to account 
statistically for all specialists in the population. Thus, the 
percentages given for each question or theme can be generalized to the 
entire population of CBP agriculture specialists and are estimates (at 
the 95 percent confidence level). We received a response rate of 76 
percent.  

[3] GAO, Homeland Security: Agriculture Specialists’ Views of Their 
Work Experiences After Transfer to DHS, GAO-07-209R (Washington, D.C.: 
Nov. 14, 2006). 

[4] The full survey results are available in appendix II of GAO-06-644. 

[5] The survey was available from November 15, 2005, until January 9, 
2006.  

[6] GAO, Mergers and Transformation: Lessons Learned for a Department 
of Homeland Security and Other Federal Agencies, GAO-03-293SP 
(Washington, D.C.: Nov. 14, 2002) and Results-Oriented Cultures: 
Implementation Steps to Assist Mergers and Organizational 
Transformations, GAO-03-669 (Washington, D.C.: July 2, 2003). 

[End of section] 

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