CBP and APHIS Adopt Joint Task Force Action Plans to Improve Agriculture Inspection

Task Force Reviews Agricultural Inspection's Transfer to CBP

In April 2007 APHIS and CBP established a joint task force and undertook a review to identify the ,strengths and weaknesses of the agricultural safeguarding program and to evaluate the impact of the government restructuring on the agriculture mission. (In 2003, the port of entry agricultural inspection function, along with certain APHIS employees, were transferred from APHIS to CBP.)

Task force considered quality reviews and legislative concerns. The task force looked at data from internal quality assurance reviews and reports of the respective Offices of the Inspector General and the Government Accountability Office. The group also evaluated stakeholder concerns as expressed in correspondence and at a stakeholder listening session conducted in May 2007, and evaluated documents indicating support for various pieces of legislation introduced to return the agriculture function to USDA from CBP.

Need to Raise Priority of Agricultural Mission, Improve Capabilities, Etc.

According to the summary, the task force report focused on raising the priority of the agriculture mission within CBP; developing strategies to improve capability to prevent the introduction and establishment of exotic plant pests and foreign animal diseases; and integrating agriculture into the primary CBP mission of preventing terrorists and terrorist weapons from entering the U.S.

Impact of CBP's focus on terrorism. During the May stakeholder listening session, it was acknowledged that terrorism was a dangerous threat that needed the utmost attention from U.S. border security personnel. However it was recognized that in relation to the concentrated focus on this threat, the agriculture mission loses a degree of significance as priorities are established in CBP. The summary states that as a result, the ability of CBP to fully implement agriculture priorities is hindered.

CBP & APHIS Adopt Action Plans to Improve CBP Agriculture Inspection

The task force identified key issues and developed action plans for improving agriculture inspections which both agencies adopted in June 2007. The following are highlights of task force's summary of the action plans (partial list):

Structure/Leadership: According to the summary, the strongest and clearest of the stakeholder concerns was that the agricultural mission was being lost or subordinated to the primary mission of CBP and a more robust chain of command with an agricultural presence at every management level was urged. Among other things, the task force recommended that CBP evaluate and implement a CBP agricultural management structure at ports of entry, including assistant port directors for agriculture at all major ports to direct and evaluate agricultural operations by FY09.

Regulatory Enforcement: The task force noted that the transition of CBP occurred only 6 months after APHIS had introduced revised guidelines on civil penalties and trained the entire workforce in their use. Because the program had been completely revamped just prior to the reorganization, it was not fully entrenched when the transition occurred. This may have resulted in uneven guidance and a lack of clear commitment to the new system. Among other things, the plan calls for an evaluation of the current Agricultural Quarantine and Inspection (AQI) penalty guidelines.

Pest Identification: CBP and APHIS need a joint comprehensive plan to establish standards of service in pest identification, training, and discard authority. For example, in certain port locations, APHIS identifier's schedules do not coincide with all peak cargo times, and timely identifications are not always possible because identifier resources are limited. Among other things, the plan calls for the development and implementation of a pest identification and detection liaison position to support and coordinate training and discard authorities.

Information Management: The summary stated that CBP and APHIS need to develop a coordinated and comprehensive process to identify essential and common data elements since, among other reasons, data sharing and electronic communications between CBP and APHIS are unreliable due to incompatibility of systems or other technology issues. In addition, data collection processes at many ports lack consistency, coordination and priority. The task force will convene a joint agency working group to develop a short-term plan (to be completed within 90 days of approval of the action plan) and a long-term strategic plan (to be completed 180 days after action plan approval) that addresses the IT systems, data management and analysis issues stated in the findings.

Joint Agency Planning: While there have been some success stories related to planning, including training and budget, planning is, by and large, an ad hoc effort that leads to uneven results. Both agencies would benefit from having a permanent, flexible, core planning mechanism to help align the vision, goals, and mission delivery in the two agencies.

Resources: Among other things, the task force found that CBP should utilize a risk-based staffing model when determining deployment of agricultural staff. CBP should also ensure that the necessary equipment and supplies and facilities are procured and made available in order to support the agriculture mission.

Outreach and Communication: There is a need for access to CBP officials by stakeholders to allow them to voice their concerns. There is also an identified need for better communication and information sharing between CBP and APHIS. Among other things, specific actions to take include: (1) including agriculture outreach in joint CBP and APHIS strategic plan development; and (2) at the port level, providing regular and recurring invitations to observe CBP's agriculture operations to various stakeholder groups.

Emergency Response: The summary stated that APHIS and CBP need to develop a comprehensive plan to identify and deploy trained and certified personnel in response to the broad range of domestic/agro-bio terrorist event emergencies.

Training: CBP and APHIS need to continue to review and improve the agriculture-related training programs used by CBP. From the Joint Agency Quality Assurance Program (JAQAP) reviews, several "best practices" have been identified and should be reviewed for expansion at a national level.

(See ITT's Online Archives or 09/20/07 news, 07092045 2, for previous BP summary on the APHIS-CBP joint task force report.)

APHIS-CBP joint task force report summary (June 2007) available at http://www.cbp.gov/linkhandler/cgov/import/communications_to_trade/aphis_cbp.ctt/aphis_cbp.doc