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(Updated September 2012)
The food and agriculture industry in the United States is not only key to the public health and welfare of this nation but is an important force in the economic, social and political fabric, as well. Farming and ranching are the foundations of our $1 trillion food and fiber business with nearly $60 billion in annual exports. This vast industry is essential to the economic health of virtually every community. It generates almost 15 percent of the total economic activity in the nation, as well as providing almost 18 percent of the country’s jobs.
Since the September 11, 2001 terrorist attacks, we are more keenly aware of the need to protect the integrity and safety of our agriculture and food infrastructure. Historically, our food safety, plant protection and animal health regulatory systems have assumed the accidental contamination of food or inadvertent introduction of animal disease or plant pest. The prospect of an intentional, or terrorist, attack on our food and agriculture industry raises grave concerns that present challenges for producers and policy makers alike.
The “farm to table” food supply chain is a complex system that includes millions of acres of cropland, millions of livestock, thousands of feedlots, processing plants, warehouses, research facilities, and packaging and distribution networks that bring food from around the nation and the world to neighborhood markets and restaurants across the nation.
Components of the farm to table continuum include:
From a security standpoint, there are an array of sectors ranging from farms with relatively open croplands to highly secure food and dairy processing facilities. At the retail end, small neighborhood bodegas and cafes operate in markets with large supermarket chains and nationally franchised restaurants. Continuous changes in the way that food is produced, distributed, and consumed present new challenges for ensuring its safety and security.
The President’s National Homeland Security Strategy recognizes the importance of securing the nation’s food supply and designated agriculture as a “critical infrastructure.” The threat of a terrorist attack on the food and agriculture industries is likely to involve the contamination of resources rather than the destruction of infrastructure. However, the diverse and widespread nature of the industry makes it extremely difficult to identify and secure every facility that might be a potential target. In the case of food, for example, introduction of minute levels of certain hazardous agents could cause widespread harm, including serious economic and social disruption. Local, state and federal partners as well as the industry itself have already taken important steps to help protect the food and agriculture industry from terrorist attack. Greater linkage at all levels of government and the private sector of resources, expertise, and initiatives is needed to achieve shared security and emergency preparedness objectives.
American agriculture and the rights of property owners to live and work on their land is a national security concern. When farmers and ranchers are threatened by transnational criminal organizations based in a foreign country that conduct repeated operations and trafficking across the private property and land that is cultivated to provide the food and fiber our industry and consumers depend upon, the federal government must act to protect and defend the people and its inhabitants.
NASDA seeks tangible resolution of these matters with the following policy principles to help guide the association and lawmakers in their efforts to secure the United States borders and rural lands across this country:
The federal government should ensure adequate infrastructure is in place along the border to facilitate the legal movement of people and goods at our international ports of entry.
The Administration has emphasized that states play a key role in homeland security and provide the first line of defense in protecting critical infrastructure, health, and safety. Protecting the nation’s food and agriculture industry demands the coordinated effort of public, private and university partners in the same way that all of these stakeholders have cooperated for decades on issues of food safety, animal health and plant protection. In the area of food safety, for example, the statistics are surprising: while this is the shared responsibility of all partners, an estimated 80% of all food safety inspections are conducted by state and local agencies.
While these existing programs should serve as a basis for efforts needed to enhance security, there are limitations and gaps. Notably, current systems were developed primarily to prevent the accidental introduction of pathogens, pests and diseases and the assistance of public security partners is not fully developed.
Accordingly, the roles and responsibilities of each stakeholder must be more carefully defined, understood, and supported. NASDA calls on each of these partners to collaborate to establish clear roles under the general policy that:
An emerging area of concern is the increased complexity of federal responsibility for preventing, detecting and responding to emergencies. The new Department of Homeland Security has important new mandates and has been charged with overseeing the response to any event deemed to be the act of terrorism. In this context, the agency has taken over responsibility for administering port and border security activities, and certain staff and responsibilities from USDA have been transferred to DHS.
NASDA remains concerned that the emphasis on homeland security in border protection not overshadow the need to remain vigilant in protecting the food and agriculture industry from the introduction of pests and disease at the border. NASDA strongly believes that prevention of animal and plant bioterrorism and provision of security for the nation’s food supply must be considered a critical priority of the new agency. NASDA urges the DHS to reconsider the de-emphasis of agriculture inspections at medium and large ports of entry and the elimination of agriculture inspections at small ports of entry. NASDA requests that legacy agriculture inspectors, with the proven education, skills and experience in cargo and baggage agriculture inspection, be immediately reassigned as CBP Agriculture Specialists and that the CBP Officer positions be open to all legacy customs, immigration and agriculture inspectors.
At the core of efforts to enhance our food and agriculture preparedness and response capabilities will be the establishment of a well coordinated and efficient communication strategy that links all stakeholders and allows for the rapid dissemination of: specific threat alerts from intelligence partners; incident notifications from field staff; industry or others; routine surveillance information from inspections, laboratory analyses and other local and state sources; and other information deemed critical to preventing illness, death or serious economic harm to the industry from a terrorist attack at any juncture from farm to fork.
At present, there are serious impediments to establishing such a system. These include:
Immediately, USDA, FDA and DHS should facilitate states in obtaining adequate security clearances for key state personnel to access and communicate critical information from the USDA Emergency Management Operations Center as well as critical plant and animal health and food security information. Federal agencies should review currently classified information and make determinations about whether it needs to remain classified for security purposes. The results of state and local inspections and laboratory analyses found to be consistent with federal requirements should be recognized as equivalent to federal inspections and analyses. Development of rapid communications and incident notification systems should have top priority and include both public and private sector decision-makers.
As a part of the solution, the development of a national Agriculture Information Sharing and Analysis Center (AGISAC) has been recommended to provide a central mechanism of reporting and analysis of agriculturally related incidences. An AGISAC would not replace existing data management systems, but would integrate information related to reportable animal diseases, food safety, agricultural chemicals, animal feed and other vulnerable agriculture targets and reach virtually every local state and federal partner. A privately organized Food and Agricultural ISAC has been established, and NASDA urges that government agencies seek ways to partner in this effort.
NASDA supports the development of an integrated national food and agriculture protection strategy that draws on the strengths of all stakeholders. Efforts to establish an integrated food safety system were begun almost decade ago, and the threats of an intentional attack on food and agriculture are placing increasing demands on states to develop strategies for protecting the food and agriculture industry in the absence of a uniform national policy.
In general, the strategy should assume that an intentional attack is more likely to involve the contamination of food or the introduction of plant and animal diseases, rather than the physical destruction of agricultural assets. Moreover, it must be flexible enough to address the diversity of sectors. Finally, components must be cost effective and based on a scientific risk assessment of their value. In addition, the development of a National Food and Agriculture Protection System should:
NASDA strongly believes that the implementation of new policies and protocols by the food and agriculture industry under the new protection strategy must be accomplished in a way that is helpful to industry and will not create unnecessary financial or operational burdens. In addition to assuring that all measures are evaluated as to cost and effectiveness, and as circumstances warrant, new measures should be phased-in for adoption and federal funding made available to support the proposed measures.
Through a cooperative agreement with USDA APHIS, NASDA completed an assessment of the capabilities of the United States and state governments, foreign governments and the livestock industry to protect this nation’s livestock and human health from animal disease. The report considered the growing threat of terrorism and made more than 150 recommendations to strengthen domestic detection and surveillance, exclusion of disease, international information and response. The Animal Health Safeguarding Review was completed in 2001, and recommendations remain timely, in particular the need for a National Surveillance System and National Response Plan, improved and expanded research, and increased funding. NASDA believes that the recommendations of the Review must be prioritized and efforts redoubled to implement key actions within the context of developing a security strategy.
Furthermore, the existing NASDA policies with respect to Animal Health Protection and Disease Control, Food Regulation and Nutrition, and Plant Health should also be carefully considered and serve as a basis for additional action in this area. Actions should be considered on a priority basis to enhance the nation’s overall level of preparedness and response to food, plant protection and animal health threats.
Finally, NASDA fully supports the development of a national critical infrastructure protection plan that includes the food and agriculture sector and urges DHS to utilize the expertise of NASDA members to ensure national strategies adequately address food and agricultural considerations. NASDA urges DHS to call on state and local agriculture and food officials to participate in the development of national strategies.
Threat and Vulnerability Assessments
The assessment of terrorist threats to food and agriculture and evaluation of the industry’s vulnerabilities will form the basis for developing a preparedness and response strategy for the nation’s food and agriculture industry. The challenge is to determine the likelihood of various forms of attack and identify on a priority basis the gaps in the existing systems. With this information, we can develop cost-effective measures to enhance our ability to prevent an attack, detect an attack at the earliest possible time, respond to protect both the public health and industry and recover from an attack by restoring public confidence and the economic viability of affected sectors.
NASDA urges USDA, FDA, DHS, and other federal partners to complete assessments as rapidly as possible and share information relevant to the development of specific state preparedness strategies. Such information sharing is imperative as states develop and refine individual State Homeland Security Strategies (SHSS) and will be important for the seamless integration of state plans into the National Homeland Security Strategy.
To enhance state efforts to develop a well-coordinated integrated strategy for all stakeholders, uniform security standards should be developed. NASDA urges USDA, FDA and other federal partners to join with the state partners in developing standards:
Exclude Foreign Animal and Plant Diseases and Contaminated Food Products
Increased trade in food and animal and plant stocks likewise adds challenges to ensure that imports do not include pests or diseases harmful to US agriculture. The increasing ease of global trade and travel raises concerns for the introduction—intentional or accidental—of pathogens, disease or pests.
Existing systems to exclude animal and plant diseases and contaminated food have been called into question in the wake of rising terrorist threats. Because it is virtually impossible to ensure the safety and security oversight at the port of entry for all imports arriving into the United States, NASDA urges USDA and FDA to consider a new model: certifying the equivalency of safety and security systems employed by our trading partners. While this is employed already by USDA in meat and poultry inspection, this concept needs to be greatly expanded to help reduce the risk of an intentional attack via imported food, plant or animal products.
The need for an ability to track crops, livestock and food products from farm to table cannot be overstated in terms of protecting public health and preserving the economic viability of the food and agriculture industry. Consumer and market demands have already begun driving trends to greater accountability and traceability. Increasing threats from a food safety and animal health perspective alone would be sufficient argument in favor of developing comprehensive product identification and tracking systems. Last summer Canada was, and now the United States is, under a global microscope as we struggle to trace the source of a cow infected with BSE as well as other animals associated with that cow. The specter of terrorist attacks makes the development and implementation of such systems even more imperative. If we require more than a few hours to locate all products associated with a terrorist incident, we risk a massive loss of consumer confidence in the nation’s food and agriculture system. That could have far costlier consequences than the immediate cost of the incident. NASDA strongly urges the immediate development and implementation of a uniform farm animal identification and tracking system. NASDA further urges the consideration of systems that make possible the identification and tracking of farm products from farm to table.
Risk Reduction Strategies
Industry should be encouraged in every possible way to adopt cost effective measures that address identified vulnerabilities and wherever possible reduce the risk of a broad range of possible hazards (i.e., “all hazards” prevention). NASDA urges the establishment of financial or other incentives to reduce the cost of capital or other investments by food and agriculture businesses. Particularly important are the immediate establishment of incentives to develop uniform identification and tracking systems to provide timely traceback of all livestock, consumer foods and food products.
Priority should be given to investments that will enhance prevention, such as good on-farm biosecurity, and to investments that address prevention or response to all hazards.
National Surveillance System
There also exists a very real possibility that we will face threats that will not be immediately apparent, and because of the lag in identifying and responding, will have more widespread and harmful impact on our food and agricultural industries. New systems that are capable of providing ongoing surveillance, early detection and effective response must be designed to maximize the limited resources available at all levels of government and to leverage private capacity that exists throughout the food and agriculture industry.
While the U.S. has historically enjoyed strong, well-functioning food safety, animal health and plant protection systems new threats have changed the nature of the surveillance and inspection that will be required in the future.
Existing systems should form the basis for actions now required to provide protection against intentional attacks against any of the sectors. However, resources are needed to enhance routine monitoring of the domestic food system at all points from farm to table, including the monitoring of plant and animal health. NASDA urges a comprehensive review of existing staffing levels of food, milk and horticulture inspectors and veterinarians and animal health technicians at the federal, state and local levels. Staffing increases should be prioritized based risk assessment. Systems for improved sharing of surveillance information must be developed and implemented.
The current capacity for rapidly and accurately diagnosing diseases used as weapons is limited and would certainly be overwhelmed by the volume of demand for testing services in the face of an outbreak. Just as the nationwide public health laboratory infrastructure was hard pressed to support investigations in the face of the recent Anthrax attacks, the intentional introduction of certain animal or plant diseases into the United States would result in massive needs for diagnostic testing, even in states without confirmed cases.
There are at the national level efforts to coordinate and enhance local efforts. One example of this kind of program is the proposed National Animal Health Laboratory Network (NAHLN). Similar efforts are being made to establish an integrated nationwide system of food laboratories through the formation of the Counter Terrorism Food Emergency Response Network (FERN) by the federal Food and Drug Administration. Adequate qualified laboratory testing capacity has proven time and again to be a critical component in dealing with disease outbreaks.
Despite progress in these areas, resources are needed immediately to support development of enhanced veterinary diagnostic laboratory capacity, food and milk safety testing, and plant inspection to support the development of an enhanced surveillance network.
The accidental introduction of disease or illness has historically resulted in incidents limited in scope, number of individuals affected and geographic area involved. The intentional introduction of disease has the potential to extend impacts over a wide area and involve a much larger population—either directly or indirectly through fear and other social disruption.
Systems designed to respond to incidents today need to be flexible and scalable—able to adjust to rapidly changing circumstances and expanding scope. NASDA urges all partners to join in the development of systems that seamlessly augment prevention and surveillance resources. Response will also require the coordinated communications systems in place to enhance overall preparedness. Response efforts for all agricultural emergencies are now addressed through the Incident Command System (ICS). It is imperative that standardized training and exercises be provided for all state and local officials that would be expected to participate in response activities.
Once a response has been initiated, NASDA further urges all partners to develop mechanisms for ensuring that placement and release of control measures are targeted as specifically as possible.. The ongoing viability of the food and agriculture industry will depend on its ability to restore operations to near normalcy as soon as possible. The release of quarantined product or animals for example should take place as soon as possible to aid in the recovery phase.
Rapid recovery will be critical to ensuring the ongoing viability of food and agriculture businesses affected by an incident. Recovery can be facilitated by:
Managing the short- and long-term consequences of terrorism is among the responsibilities of state and local government supplemented by the resources of the federal government. Issues related to activities such as initial response, animal quarantines, security in communities following an event, and short- and long-term recovery are some of the many responsibilities faced by state and local officials.
To date, federal support for state departments of agriculture has been very limited. Modest USDA support was provided to enhance animal and plant laboratories and to begin work on projects including rapid notification and other systems. While billions of dollars in funding was provided through CDC to state health departments for uses including food security, cost share mechanisms and other barriers have all but excluded agriculture departments from receiving funds.
NASDA urges that immediate support be provided to departments of agriculture to enhance bioterrorism preparedness and response capacity across the nation. Further, funding is needed immediately for research in all critical aspects, and funds must be targeted not just to traditional defense research laboratories, but to institutions with expertise in food and agriculture issues.
NASDA urges that all federal homeland security funding, including funds earmarked for local jurisdictions, be distributed through the states and territories in order to enhance regional response capabilities within the states and territories and to advance the comprehensive homeland security strategy of each state and territory. Federal funds and technical assistance should be provided for the completion of state and local risk and threat assessments.
The Food and Agriculture Protection Strategy
Based on identified risks and vulnerabilities Congress should guide funding decisions. Federal funds are specifically needed to enhance or improve:
Funding to state and local agricultural and food agencies needs to be dedicated on a long term basis through a predictable, multi-year mechanism to maximize the ability of local and state governments to plan for necessary program enhancements. Developing enhanced agriculture and food protection capacities requires a long-term commitment from the federal government to state and local agencies.
The food and agriculture industry has made significant investment in security where there has been a demonstrated need to reduce product loss due to theft or to ensure the safety of crops, food or livestock. Universal tamper resistant and tamper evident packaging was introduced after the famous Tylenol incident, and current domestic and international market trends are having an increasing impact on product identification and traceback.
But market forces alone are not likely to provide sufficient incentive for the investment in new security equipment and systems. Consequently, NASDA recommends that government partners cooperatively work to explore options for supporting and encouraging further investment. Additional issues that need to be considered include: