A new Governmental Accountability Office (GAO) report looks at the U.S. Department of Agriculture's process for evaluating the animal health systems of countries with a confirmed case of foot and mouth disease (FMD) that are seeking to export beef products to the U.S. and how this process could be improved.
FMD is a virus that causes painful lesions, making it difficult for livestock to stand or eat and greatly reducing meat and milk production. No FMD cases have been recorded in the U.S. since 1929. Federal regulations restrict fresh beef imports from countries where the disease is present because the disease may survive in untreated, uncooked beef and can be costly to control and eliminate. According to USDA, an outbreak of FMD could cause grave damage to the U.S. beef industry, which had a retail value of $95 billion in 2014.
The process USDA's Animal & Plant Health Inspection Service (APHIS) uses to evaluate foreign countries seeking to export beef to the U.S. includes gathering and evaluating information about a country's animal health system, usually performing one or more country site visits to substantiate the information and address any concerns and conducting a risk analysis to estimate the potential risk to U.S. livestock posed by the importation of the country's beef.
GAO said APHIS could strengthen its evaluation of foreign animal health systems by improving transparency to stakeholders, including the public, on how it determines whether the prohibition on a country's beef may be safely lifted; the agency could accomplish this by better documenting its actions during three phases of the evaluation process: (1) its analysis of information gathered from foreign countries and other sources, (2) in-country site visits and (3) risk analyses. Existing guidance is not adequate to ensure that such documentation will occur, GAO said.
APHIS does not have a systematic means of storing, organizing and managing the information gathered during an animal health system evaluation. “We found that documentation submitted by foreign officials, information collected during site visits and written communications with foreign officials were stored on a centralized database, but the information was not systematically organized,” GAO said.
One of the criticisms from the National Cattlemen's Beef Assn. (NCBA) was its inability to replicate the process APHIS used in approving Brazil — which has had a recent case of FMD — to import its beef to the U.S. GAO cited as an example that an official from NCBA said the association's staff attempted to replicate the Brazil evaluation, “but the lack of organization in APHIS documents made it difficult for them to understand how the information APHIS gathered had been used to support the final risk analysis report.”
According to the NCBA official, "it took almost one year to receive the relevant documents regarding the Brazil (14 states) evaluation, and as of October 2016, the association had yet to receive documents relevant to the Northern Argentina evaluation,” GAO said in its report. "In both cases, (NCBA) did not receive the documents before the public comment period had expired for the proposed rules to lift the import prohibition on beef from those regions. The official told us that as a result, the association was not able to submit fully informed comments on the proposed rules."
Without sufficient guidance instructing staff to document such items, GAO said it is unclear: (1) how APHIS verifies country information and assesses its reliability, (2) how problems identified are ultimately addressed to APHIS's satisfaction and (3) what methodologies, sources, assumptions and uncertainties may influence its risk analysis.
GAO is making three recommendations, including that USDA clarify its guidance on how staff should document the analysis of a foreign country's animal health system and the results of in-country visits to verify information.
During GAO's review, APHIS acknowledged the weaknesses in its guidance and formed a team to begin work to address the issues. By completing this effort, APHIS may be better able to ensure that it has assessed risks fairly and consistently across countries and over time and that the process is transparent to the public and other stakeholders.