Agrosecurity and homeland security directives

Agrosecurity is simply security for agriculture, which in this paper will focus on CAFOs. Agrosecurity encompasses biosecurity which is a collection of management practices designed to minimize the potential for accidental or intentional introduction or spread of an animal disease. Additional aspects include enhancing the security of the agricultural operation to prevent hostile acts of a terrorist or criminal nature. The most effective agrosecurity will prevent or minimize impact from both natural and intentional disasters in the agricultural sector.

Typical biosecurity plans protect animals against the introduction of disease and concentrate on implementation of safe animal care practices such as quarantine of animals upon arrival at the facility, segregation of sick animals, proper hygiene for caregivers, and proper disinfection. There may be restrictions on outside activities of employees; for instance, many swine operations do not allow employees to raise or care for animals susceptible to FADs apart from their employment. Premises security refers to inhibiting or controlling criminal activity whether it is vandalism, theft, or terrorism, by restricting access to the operations. Close coordination with local law enforcement is important. To this end, the Department of Homeland Security (DHS) and the Federal Bureau of Investigation (FBI) have jointly sponsored two International Symposia on Agroterrorism, the first in May 2005 and the second in September 2006.

Homeland Security Presidential Directives (HSPD) provide the authority for homeland security planning and several have been directed at protection of agriculture and the nation's food supply and are briefly introduced below.

HSPD-3 deals with communication of risk, which largely determines allocation of resources. Application for agriculture is uncertain. HSPD-4 discusses a National Strategy to Combat Weapons of Mass Destruction. The introduction of a FAD would qualify as a weapon of mass destruction (WMD), not necessarily threatening human lives but impacting property, the US economy, and disrupting the food supply and confidence in the government. An identifiable need under this directive is better intelligence and communication of that information to those working with agriculture and the food industry. In the event that there is no current perceived threat, whether at the local, state, or national level, that should be communicated as well. HSPD-5 addresses management of domestic incidents. This directive requires that all incident commands use the same structure and protocols (National Incident Management System (NIMS)). It is a step toward better communication between sectors but Buck et al. (Reference Buck, Trainor and Aguirre2006) deem it inadequate to handle emergencies when those involved do not report to the same command structure and many may lack NIMS/incident command system (ICS) training. HSPD-7 discusses critical infrastructure identification, prioritization, and protection. The agriculture and food sector has been included in national and many state infrastructure protection plans. Agriculture fits because of the threat to the economy (>$1 trillion per year) and the number of jobs involved (18 percent of domestic employment) (USDA-ERS, 2007). Although HSPD-7 lists agriculture as critical infrastructure, there is no mandate for funding.

HSPD-8 addresses national preparedness. The intent of the directive is to strengthen preparedness and improve response, with the federal government assisting state and local governments. HSPD-8 is a companion to HSPD-5. Among the goals are improved training and preparedness for those first on the scene after an incident. For animal agriculture that includes CAFO workers, management, veterinarians, consulting veterinarians, state and federal FAD diagnosticians (FADDs) and others called upon to respond to the event. The goal of the directive is to expand existing capabilities and not merely improve existing resources. The USDA Animal and Plant Health Inspection Service (APHIS) has sponsored several exercises to address the goals of HSPD-8. Jurisdictions are encouraged to expand proficiency through local and regional efforts and expansion of mutual aid agreements. The Homeland Security Exercise and Evaluation Program (HSEEP), http://hseep.dhs.gov/, provides accessible and consistent authority for evaluation and training.

HSPD-9 deals with defense of United States food and agriculture. Released in January 2004, the importance of food and agriculture was recognized and efforts initiated to truly improve protection for this vital sector of the economy. A strike on the food and agriculture sector could have tremendous economic and psychological impact and could significantly alter the standard of living. National compliance will require involvement by industry at all levels, by local, regional, state, multi-state, and national governmental entities and nongovernmental organizations (NGOs). A clear understanding of the potential threats, industry and facility vulnerabilities, and capabilities must continue to be developed.

HSPD-10 covers biodefense for the 21st century. This directive targets human biothreat agents more than agricultural, yet in some cases the two cannot be distinguished. Furthermore, the principles for dealing with one are often very similar to those for the other. The vulnerability of the agriculture and food sectors is recognized, but many of the details still beg resolution. The concern that an incident may create cascading international effects is applicable to the food and agriculture sectors.

Seldom are HSPD-3 and -4 considered as applying to the agriculture and food safety sector, but with the listing of agriculture as critical infrastructure under HSPD-7, it seems apparent that risk communication and development of a strategy to thwart the introduction of a FAD is as applicable as any other WMD.

The nature of the threats to livestock

Agriculture is a $1.2 trillion per year industry accounting for 18 percent of domestic employment and 11 percent of the gross domestic product (Monke, Reference Monke2006). Animal agriculture is a major component of the economy for the Southern High Plains including southeastern Colorado, eastern New Mexico, southwestern Kansas, western Oklahoma, and the Texas Panhandle, accounting for an economic impact of over $20 billion per year in the Texas Panhandle alone. At the national level animal agriculture represents $123 billion per year for 2006 (USDA-ERS, 2007). Economists may use various multipliers to indicate economic impact which will yield an even greater number. Concern for the health of the industry extends beyond the owner/operators of the CAFOs to all who are knowledgeable about the agricultural contribution to the economy.

Data from the 2001 foot and mouth disease (FMD) outbreak in the United Kingdom illustrate the potential economic impact of FADs. This outbreak was estimated to have a total cost of $20 billion, with expenditures directly associated with disposal of more than 6 million diseased animals exceeding $6 billion (presumably including indemnification, cost of depopulation and disposal, and cost of cleaning and disinfection) (AVMA, 2007). Another report estimated that up to 10 million sheep, pigs, and cows were slaughtered and the loss to the food and agriculture sector was about $5 billion (Carlton, Reference Carlton2007). Taylor and Tricker (Reference Taylor and Tricker2006) report over 4 million animals culled at a cost of more than $8 billion. The Department for Environment, Food and Rural Affairs (DEFRA, 2002) reports slaughter of more than 4 million animals with 3 million in England of which 83 percent were sheep and 14 percent cattle. Compensation for slaughtered animals was £1.1 billion (approximately $2.2 billion), which, though not explicitly stated, does not include costs for destroying and disposing of animals or cleaning and disinfection of equipment and premises. The higher monetary estimates likely include economic multipliers to include directly impacted and indirectly impacted businesses including tourism.

A clear understanding of the potential threats is necessary to take effective preventative action. The threats may be either intentional or accidental. The major concern for livestock producers is introduction of a highly infectious FAD such as FMD. To date there has not been a documented case of intentional introduction of FMD but the cost of the outbreak is dependent upon motive only to the degree that the distribution of disease may be different. With markets becoming increasingly global, the likelihood of either type of introduction cannot be discounted. FMD is not considered zoonotic (transmissible to humans), so the impact of the disease is primarily economic and not related to human health.

Use of biological agents against animal agricultural interests has very limited historical precedent (Ackerman and Giroux, Reference Ackerman and Giroux2006). Germany, during World War I, introduced anthrax and glanders into draft animals supplied to the allies from the United States (NEWS & TERRORISM, Reference Monke2005), and infected Romanian sheep bound for Russia in 1916, and reindeer in Norway (Cain, Reference Cain2001; Wheelis et al., Reference Wheelis, Casagrande and Madden2002). During World War II Japan is alleged to have used anthrax and rinderpest against Russia and Mongolia in 1940, and plague-infected fleas in Manchuria. Terrorists have used biological weapons including the unsuccessful 1993 attempt by the Aum Shinrikyo cult to use anthrax and botulinum toxin in Tokyo, while the followers of Baghwan Shree Rajneesh in 1984 sickened over 700 Oregonians by poisoning salad bars with Salmonella to rig an election (Carus, Reference Carus2001). Carus also mentions the introduction, by desperate New Zealand farmers, of rabbit calicivirus disease in 1997. This is not a case of terrorism, but of the illegal introduction of an agent for supposedly beneficial purposes. Documented terrorist attacks directed at animals have not occurred although some opposed to use of animals for scientific studies or in production agriculture have carried out strikes against people involved or have released animals from shelter facilities. However, biological weapons directed at agriculture are well suited to the type of asymmetric warfare perpetrated by non-state terrorist groups: they are inexpensive, may cause significant damage before detection, are readily available, and generally are safe for humans to handle.

The mechanism and venue for introduction of a FAD depend largely upon the perpetrator involved and the goals of that person and associates. Some entities, such as sovereign nations, might desire the cover of plausible deniability, others may not care, and others, such as terrorist groups seeking public attention, will definitely want to take credit. Likely, all would have goals of wreaking economic havoc and destroying confidence in the safety and ready availability of food.

To gain a perspective on the threat, it is useful to develop an understanding of the potential magnitude of damages, both direct and indirect. The long-standing US policy for handling the introduction of FMD has been ‘stamping out’ (NAHEMS, 2005). The intent of the policy is to limit disease spread, destroy all infected or exposed animals, and verify absence of disease as quickly as possible to regain FMD-free trading status as determined by the World Organization for Animal Health (OIE, Office International des Epizooties). Breeze (Reference Breeze2004) rightly suggests that current policies play into the hands of terrorists seeking to generate a lack of confidence in our government. He expands in a subsequent article (Breeze, Reference Breeze2006) in which he makes several suggestions to mitigate the consequences of an attack upon the food animal sector. Breeze maintains that by stipulating policies that will overwhelm resources and create a public debacle, the OIE and the USDA have inadvertently created a climate in which terrorists might reasonably consider use of biological agents against animal enterprises. The purpose of an attack upon the animal agriculture sector will be to generate disgust and horror as massive numbers of animals are depopulated and destroyed. Confidence in the nation's food supply will be undermined. Gary Weber, formerly with National Cattlemen's Beef Association, said at the 2006 FMD Summit (Larson and Loneragan, Reference Larson and Loneragan2007) that a one percent decline in the market for beef equates to a $100 million loss.

During the United States' last experience with FMD in 1929, ‘stamping out’ was effective. Since then animal production agriculture has changed significantly. CAFOs have become the norm, making available to producers significant economies of scale and contributing to the reduction of the percentage of family income spent on food to less than about 10 percent (USDA-ERS, 2006). However, large feeding operations mean that the problems associated with ‘stamping out’ are large as well.

It is not possible to depopulate and dispose of carcasses for a large cattle feeding operation within anything approaching stated requirements. The current National Animal Health Emergency Management System Guidelines (NAHEMS) require animals to be depopulated and carcasses disposed of within 72 h (NAHEMS Guidelines, September 2005, draft). At a recent exercise in the Texas Panhandle, an earth-moving contractor indicated that if all the contractors in the region responded it would take 11 days to dig the hole needed to dispose of carcasses for a single 70,000 head feedlot. Regions of the High Plains may have several even larger feedlots within any given 10 km (6.2 miles) infection zone. The Guidelines make provision for several methods of depopulation, but the ability to depopulate a number of very large feedlots within the permitted time frame is doubtful using even the most aggressive techniques. Carcass disposal by approved means is not possible. By adhering to outdated disposal requirements, the potential for a public relations nightmare plays into the hands of terrorists much as suggested by Breeze (Reference Breeze2004). Of course, massive numbers of dead animals will be a problem regardless of requirements for disposal, so one may question the need for massive depopulation.

Determining the probable threats involves understanding the likely sources of disease introduction, the geographic locations in which there is a reservoir of disease, who may want to attack, the objectives of the attack, and the resources available to potential attackers.

FADs are important even if terrorism is not a consideration. They are generally highly infectious and have the capacity to significantly impact the agricultural economy. Some diseases may also be zoonotic. Most western nations have implemented tighter security at their borders since the war on terror began, but many observers argue the current precautions are insufficient. To some extent adequate security will always depend upon the diligence of the receiving operation. Management must know the origin of all shipments and have a clear understanding of the shipper's credibility. Based upon historical evidence, an accidental introduction of a FAD is the most likely source of infection, so the greatest level of resources should focus upon minimizing that risk.

Psychological impact is seldom the first consideration in discussions of FAD, but many working on the United Kingdom, 2001, FMD epidemic reported that the visual impact of attempts at carcass destruction adversely affected public support of the eradication effort and increased economic devastation in the tourism industry. If large numbers of jobs are lost, mass migrations could occur, creating serious infrastructure problems for receiving communities and lost tax revenues for areas losing people. In the later part of the 20th century, extending into the beginning of the 21st century, Americans have become accustomed to a plentiful and cheap food supply. If a FAD outbreak is widespread, that would change. Although Americans would not starve, food would be less available and prices would increase.

Threat assessment and evaluation

Historically, threat assessment and evaluation have been the responsibility of intelligence, military, and law enforcement agencies. While continuation of this paradigm seems appropriate when evaluating threats involving nuclear, radiological, or some explosive devices, it seems less fitting for weapons of convenience, such as certain biological or chemical agents (especially those widely used in agricultural operations), targeted at the civilian population or agricultural production. USDA and state agricultural agencies have gathered intelligence through inspections for years. If those at the production stage of agriculture can now become a more significant part of the intelligence network, the nation not only may avert the introduction of an infectious disease, but possibly could also realize multiple benefits by thwarting the repeat of an incident like the 1995 bombing of the Alfred P. Murrah Federal Building in Oklahoma City. In that case the purchase of large quantities of fertilizer containing ammonium nitrate used in the truck bomb should have triggered an alert. In the past, war was waged by sovereign governments which directed armies to war against opposing armies. Today the threat is much different and requires the vigilance of all. We do not expect to see military personnel protecting our swine operations, poultry barns, dairies, or feedlots. Owners, operators, employees, and observant neighbors will do that by diligent community policing activities in conjunction with local law enforcement. In view of this proposed shift in protection mentality, the agricultural industries must be apprised of increased threats to their respective sectors; those facilities must be the first line of defense. Furthermore, it is all the more difficult to make appropriate preparations for threats that remain undefined. Although one can easily recognize the validity of a threat to agriculture, allocation of resources for preparedness requires a comprehensive risk analysis across all sectors. It is not possible to complete such analysis without adequate threat evaluation.

Response

Effective response to the threat depends greatly upon good understanding of the threat. Some appear to deny the possibility of any attack upon agriculture and alarmists may exaggerate the threats and vulnerabilities. The problem is, at least partially, the lack of intelligence available to professionals involved in response planning, especially in the agriculture sector. Looking at FMD outbreaks around the world, it seems one must at least concede the possibility of introduction without respect to intent. Given that, it seems vital that planning proceed with the purpose of minimizing possible disease spread regardless of method of introduction. Response to the threat requires full consideration of possible sources of introduction, possible motives for introduction, and possible venues of introduction of a FAD.

Responding to an attack is different from responding to a threat. Different action is required at this point, and, for the most part, the time for planning has past. Response to a threat involved planning, taking action to minimize vulnerability and impact, and preparing for an attack. Upon attack, people have to begin doing things and it is necessary that someone be in charge and that others know who that is and how they are to respond.

Biosecurity in various operations

Preparedness for FMD

A much better understanding of the mechanics for transmission of FMD and other infectious diseases can provide vital insight to guide better preparedness. Often when no other route of exposure can be identified, it is presumed that contagion was by infected aerosol. That may be true, indeed references supporting this were mentioned previously, but some environments are not well suited to FMD viability in aerosol form. In the Texas High Plains, summer temperatures in the open often exceed 100 F or 38°C with relative humidity much less than 10 percent. FMD requires relative humidity in the 50 percent or above range to remain viable and prefers cooler temperatures. Does this mean that infection cannot happen during the summer in the Texas Panhandle? What implications does it have for disease management? Some working on epidemiological models do not include aerosol infection because they deem it unlikely, yet the Scudamore (Reference Scudamore2002) report from the UK epidemic attributes some infection to aerosol.

Poulin and Christianson (Reference Poulin and Christianson2006) report an on-farm eradication of FMD in China without resorting to mass depopulation or culling; only pigs with clinical signs were destroyed. Admittedly, the study was not in a region classified by OIE as FMD free and the herd was relatively small compared to US commercial swine operations. That does not necessarily negate the observation that such a strategy would be less expensive and likely perceived by the public as humane. There are practical policy considerations, but the significant question is what would be necessary for the US to develop a policy around similar practices?

We need more and better modeling of disease spread. The epidemiological models today concentrate on spread from one facility to another. Many of these models are accepted as very good representations of what is likely to happen. However, modeling of what happens within a facility is lacking. That is important because if it is possible to manage the disease such that a whole operation need not dispose of animals to halt spread, the government and industry can save billions of dollars. Until better tools exist, such management is not a reasonable option.

We need better tools, instruments, and procedures for early and accurate diagnosis of infection. Current procedures require a worker to see an animal with clinical signs. By the time the animal is obviously ill, it may have been producing and shedding the virus for several days, likely infecting many others. Samplers capable of capturing the microorganisms passively from the environment could provide a trigger for close inspection. Such devices might collect aerosols or feed and water samples. USDA and industry are very concerned about the potential for false positives, so protocols must be developed and implemented to eliminate market responses to passive testing. For beef cattle and dairy operations, testing of new animals upon arrival at the feedlot could be included in current intake processing of the animals. A rapid PCR (Polymerase Chain Reaction) or ELISA (Enzyme-Linked Immuno-Sorbent Assay) test of the animals could identify infected animals so they can be quarantined and not enter the herd. Much of this technology is currently available or could be quickly, but current USDA philosophy appears to be an impediment.

Work at the lowest levels is needed to develop procedures and protocols consistent with state and national plans and to educate communities including producers, county officials, state officials,and other stakeholders. Each community requires different education. State officials understand the potential threat diseases but may need particulars on industry practices in a region. Producers know how their operations work but may lack adequate and up to date information about disease responses. As an example, in a relatively recent table top exercise, two of the more knowledgeable producers were still operating under the outdated assumption that an infected facility would be out of service for 3–5 years. It should be obvious how detrimental such perceptions can be.

Everyone who needs to respond must have at least some familiarity with the NIMS. Producers probably do not need comprehensive knowledge and probably will never be ICs for a fully staffed incident command post (ICP) but they do need to know the lines of communication and the subsections with which they are most likely to interface.

Exercises, previously mentioned, are part of continuing education, the value of which cannot be overstated. In 2002 the Texas Animal Health Commission (TAHC) conducted the Panhandle Exercise, which was a table top. By July 2006 when the Governors Division of Emergency Management (GDEM) conducted a WMD exercise, including a FAD, only four of the group from 2002 were still available to participate. The turnover rate requires an almost continuous education and exercise regimen to maintain a reasonable level of preparedness. One of the problems with the UK response to FMD in 2001 was lack of exercise of existing plans (Taylor and Tricker, Reference Taylor and Tricker2006).

Assessments must be conducted and the results communicated. In addition to the threat and vulnerability assessments already discussed, assessments of preparedness and interoperable communications are also essential. Interoperable communication is often associated with compatible radio frequencies but really is much more. A common language and command structure are essential. Standardization of definitions and connotations of vocabulary, at the least within the context of planning and response, is vitally important.

Hardening of targets

The concept of hardening targets simply means implementing policies and procedures that either make the target less attractive to attack or raises the cost of the attack. It may not be possible to defend a target fully but hardening may reduce the likelihood of an attack.

Best management practices can reduce animal exposures to points of contamination or infected animals. Swine operations already have strong biosecurity on premises and many dairies quarantine animals upon receipt. Few beef cattle operations currently quarantine new arrivals, but implementing segregation with no nose to nose contact with resident stock for 21 days will reduce potential for infection. Some would argue that this is not appropriate for a highly infectious FAD; however, when one recognizes the logistical problems of depopulating 500,000 animals and disposing of the carcasses, three things become obvious: (1) a more thorough understanding of factors affecting disease transmission is vital, (2) any steps which may slow disease progression must be at least considered, and (3) the problem requires potentially unorthodox solutions.

Just as neighborhood watch programs have been effective against crime, citizen watches can be effective in protecting agriculture. Kansas and New Mexico have implemented AGROGUARD programs, similar to the familiar neighborhood watch but adapted for rural agricultural areas, http://nabc.ksu.edu/assets/uploads/Agrobrochure.pdf. The sheriff in Randall County, Texas recently adopted the program using county rather than state or federal dollars.

Good communication with the media can be helpful. Make local and regional newspapers, radio stations, and television stations aware of preparations by local, regional, state, and federal agencies. Properly reported activities are an excellent technique for hardening targets.

Dual use solutions

Dual use or dual benefit solutions are important for at least a couple of reasons. First, the overall cost of preparing the nation to defend against all possible terrorist attacks means that some things just cannot be considered. Zhuang and Bier (Reference Zhuang and Bier2007) used game theory to optimize investment in disaster preparedness, considering both natural disasters and terrorist activity. Even a moderately fair representation of their results goes well beyond the scope of this work, but their observations include the following two points. (1) The defender must evaluate the cost effectiveness of any strategy designed to dissuade the attacker. (2) Counter terrorism intelligence is valuable in assessing the attacker's response to defensive investments. This work calls into question DHS priorities for hardening multiple terrorist targets at the expense of disaster preparedness. The authors suggest that all hazards approaches are an acceptable alternative. Their paper does not reflect upon the possibility that some hardening efforts and improved intelligence might have already changed the playing field and they do disclaim use of their model for actual numerical rankings of investment. The question which they raise and which we must soon answer is how should we most wisely spend our finite resources to both prepare both for disaster and defend against aggression? The more we can dovetail those activities, the easier the question will be to answer.

PAWG

A working group of academics, industry representatives (all major species groups in the Texas Panhandle), and local government officials has been developing a regional response which integrates into the state and national plans. The plan primarily concentrates on application to the most prevalent operations in our region: beef feeder cattle, dairy, and swine but has application to other operations such as cow-calf, stocker, and sheep and goats. The plan essentials are widely transferable throughout the Great Plains but could also have application anywhere large feeding operations occur. Some animal agriculture enterprises have well developed internal biosecurity plans; however, it is not uncommon to neglect parameters outside the operations control such as the impact of stop movement orders on grain supplies or essential personnel. The working group has progressed through education of participants to plan development to plan testing with regional table top and functional exercises, during which the value of novel approaches was recognized warranting further discussion. The best plans return rewards even if there is never a FAD epidemic. Good biosecurity is always valuable.

Representatives of West Texas A&M University (WTAMU), Texas Cooperative Extension (TCE) Amarillo, Texas Agricultural Experiment Station (TAES) Amarillo, Texas Veterinary Medical Diagnostic Laboratory (TVMDL) Amarillo (a NAHLN laboratory), TAHC, and the Texas Cattle Feeders Association (TCFA) combined in November 2005 to form the PAWG. The group has grown to include representatives from emergency management, law enforcement, environmental regulators, state health services, USDA Agricultural Research Service (USDA-ARS), local and county government, the regional COGs, Texas Pork Producers Association (TPPA), Texas Association of Dairymen (TAD), Texas Sheep and Goat Raisers Association (TSGRA), Texas GDEM, and several TCE State Extension Agents. The working group serves as the AVWG for the Texas Panhandle and works on preparation of response and training materials for use by operators and responders.

PAWG has experienced several successes. Through a joint initiative of the PREMAC and PAWG, the Randall County Sheriff modified and adopted the AGROGUARD program. In March 2006 the Texas Panhandle had the largest one day wildfire in the history of the United States, burning 930,000 acres of grassland. The networking provided through the initial PAWG meetings facilitated the response effort. This working relationship has continued and grown through successful participation in a large regional table top exercise conducted for the PREMAC by the NERRTC, a division of the Texas Engineering Extension Service (TEEX) in July 2006. NERRTC also provided a series of training programs for participants and conducted a complementary functional exercise in August 2006. The TAHC, with funds from USDA-APHIS, sponsored Operation Palo Duro conducted by staff from CNA Corp. in February 2007. That exercise tested policy at the highest levels of state and federal government, with government and industry representatives from four states participating. Essential ingredients for any effective response include clear and open communication and a high degree of trust. PAWG participants are working hard to strengthen those attributes. The exercise served to illustrate the difficulties inherent in indemnification for large number of animals and the nearly impossible logistics of depopulating large herds and disposing of carcasses. Another lesson learned is the importance of strong industry involvement and support.

National policy

Discussions at the close of the FMD Summit (Larson and Loneragan, 2006) bemoaned the lack of transparency by USDA. For those with access, the NAHEMS Guidelines and other documents clearly articulate many of the policies. A major problem is that many documents remain in draft form and are not easily available. The policies articulated are not well known. This hinders planning and preparation at the local and regional levels where first response will necessarily begin. The guiding documents should move to final form and adoption, or officials responsible should convey the reasons for non-formalization to those concerned with responding to a FAD event. In other words, if plans are to remain in draft, say so and explain why.

The issue of depopulation requires much more thought. During the final reporting at a recent FMD exercise, the finance section chief reported that after one week approximately $130 million had been expended. One of the participants immediately asked if that included indemnification, to which the response was affirmative. Considering that two feedlots with over 140,000 head were far along in the process of depopulation, the $130 million lacks credibility. Using a common and reasonable estimate of $1000 per head, the cost of indemnification alone would exceed $140 million. If other facilities considered as infected premises in the exercise were included, cost for indemnification alone would exceed $300 million. Additional direct costs would include depopulation and carcass disposal, clean up and disinfection, and the supplies, salaries, and wages associated with those tasks. And those are only some of the direct expenses. ‘Stamping out’ has been the US policy for almost 80 years and should not be abandoned without careful consideration, but one has to wonder if the United States can afford it. The concerns raised by Breeze (Reference Breeze2004) certainly resonate.

Indemnification raises many questions. Is it right to pay only for animals which must be taken? In one sense, there must be reimbursement for a taking (Article V, Amendments, United States Constitution), but what about requiring disposal of milk because of movement restrictions? How different is that than killing uninfected animals to stop disease spread? What happens to the downstream industries? The cattle feeder may receive payment for animals destroyed, but what happens to those in all the support industries such as haulers, the packing plants, the wholesalers, and the retailers? The legal ramifications of this question go far beyond the scope of this paper or the qualifications of the author, however, it may be that no agency of the executive branch can answer this; it may require legislative or judicial action.

Vaccination policy is not as undefined as many think. As indicated earlier, it is an option of last resort for use only when officials cannot stop disease spread by other means, most notably depopulation. The time frames for determination of the specific virus subtype and activation of the appropriate vaccine do not favor use in situations where disease spread can be halted relatively quickly.

Business continuity is a major concern for all industry components. It is quite possible that infection in only one sector will stop movements and disrupt business for all sectors. For instance, infection at beef feeding operations will initiate a stop movement that will affect milk shipments and the transport of pigs and hogs. Everyone seems to understand this. The difficult problem, which remains, is how to get movement of essential items restarted without increasing the threat of disease spread. As part of the decision support, sound epidemiology will be required and without it everything will remain at a standstill or revolt will ensue.

CAFO security

CAFO security for all hazards requires valid threat assessment. To achieve this, interaction with agencies with access to intelligence including the FBI, Central Intelligence Agency (CIA), state and local law enforcement (although local law enforcement may also wish they had better access) is essential. Each CAFO should have a vulnerability assessment by someone familiar with the industry but probably not with the particular facility (to avoid bias). It is incumbent upon the CAFO to address as many of the vulnerabilities as feasible. Identifying collateral benefits for proposed CAFO actions will increase feasibility and likelihood of adoption. Management practices that reduce potential for transmission of infectious disease merit strong consideration.

While biosecurity is standard and strong in some sectors of the food animal industry, such as pig production, it is significantly less stringent in others. Some of the deficiency in operation biosecurity may result from a lack of understanding about risk by managers and veterinarians. Recently the Dean of Veterinary Medicine at the University of Pennsylvania recommended changes in the curriculum for veterinarians, in particular those planning to enter food animal practices (Kelly, Reference Kelly2007). Kelly suggests that food animal veterinarians need to work with others in farm operation to improve understanding of risk management, to develop the ability to monitor large herds and immediately recognize when things go wrong, and devise and implement revised biosecurity protocols. All of these suggestions will be effective in improving herd health whether by eliminating potential for destructive terrorist activity or restricting exposure of healthy animals to microbes carried by other animals or fomites.

A balancing act

The spectrum of possibilities for terrorist aggression is far too great for the intelligence, policing, and defense sectors of government to handle totally. Our citizenry must be involved. Risk analysis cannot definitively tell us for which disaster we should prepare (Ryan, Reference Ryan2005; Zhuang and Bier, Reference Zhuang and Bier2007), but the process is essential for informed and responsible decisions. Ryan emphasized the importance of dealing with real versus perceived risks to ensure that we work with the important issues and not just the politically sensitive ones. Good risk analysis must ask difficult questions. It must ascertain the importance of threats other than those to human life and help determine whether all resources should concentrate on stopping human deaths at the expense of all other sectors. There is also a need to consider the costs associated with recovery.

Balancing preparation for a variety of natural and unnatural disasters requires consideration of several issues. These include the amount of damage we can endure, the economic impact, and the shock factor. Risk analysis can help answer some of these questions, but the philosophical issues depend upon the ethos of the nation. Those doing the risk analysis need better intelligence to proceed (Ryan, Reference Ryan2005). Perhaps the methods of game theory can augment risk analysis. The issues of agrosecurity, identification of food production and agriculture as critical infrastructure, and general concern about our response to terrorism raise serious questions. In particular, an important question is how significant agriculture and food production are considered to be compared to other infrastructure.

Policy, regulation, or law defines some participants in agrosecurity. For an FMD epidemic, USDA APHIS Veterinary Services (VS) is responsible for making decisions regarding interstate commerce, the movement of animals, depopulation, and vaccination. The Foreign Animal Disease Diagnostic Laboratory (FADDL) at Plum Island, New York, will perform the first confirmatory tests. The often repeated question is Why? The process is cumbersome although the results are very accurate. The issue here is balancing the speed of more rapid testing and the concern for the economic devastation that could result from a false positive. Breeze (Reference Breeze2006) appropriately decries the tardiness in understanding the disease situation due to current policies and dependence upon outmoded technology and communication. Rather than continue a system of slow precise diagnosis, it would be advantageous to find a way to deal with false positives.

The National Animal Health Laboratory Network (NAHLN), which currently has 48 labs and will ultimately have 55, can begin testing once Plum Island FADDL confirms the initial diagnosis. Presumably, this transfer of testing will be to the lab nearest the disease outbreak. The National Guard Civil Support Teams (CST) can complement the capability of the NAHLN. Each CST has mobile PCR and BSL-3 (Biological Safety Level-3) capability which suits the units for deployment to actual facilities. An example in which the CSTs can be used to good advantage surfaced during Operation Palo Duro. In the exercise swine were not infected and one of the operations needed to move animals to another facility. To gain authorization for movement it was necessary to collect samples from a random group of animals and submit for testing. This appeared to be a very worthwhile use of the CST. Currently the CSTs are not part of the animal health response plans and are not part of the NAHLN, but they can perform this mission and should be included after proper certification.

State animal health agencies routinely deal with even epidemic size infections within their boundaries and have plans already in place. Whether they take the lead or follow USDA, they are always a critical player.

Law enforcement is included in most, if not all, plans. Depending upon the nature of the incident the FBI may have the lead or it may fall to state and local agencies. Primary responsibility generally includes enforcement of legal actions such as stop movement orders and investigation of illegal and/or terrorist activity.

Existing plans identify other agencies at the federal, state, and local levels. Others who have an interest should also be involved. The problem is too big for official personnel to handle alone. Further, response must include industry representatives who are the ones with the best understanding of their operations and needs for business continuity and rapid recovery. Most importantly, it is necessary to develop relationships among participants early and to maintain them by regular communication and readiness exercises.