Agency Planning to Ensure Continuity of Essential Veterinary Functions during a Pandemic Is Incomplete
FEMA's pandemic guidance assists agencies in identifying special considerations for maintaining essential functions and services during a pandemic outbreak that may cause absenteeism to reach 40 percent.
For example, the guidance directs agencies to identify in their pandemic plans how operations will be sustained until normal business activity can be reconstituted, which may be longer than the 30 days usually planned for other types of emergencies. Agency plans are also to identify the essential functions that must be continued on-site and those that can be conducted from a remote location. They also should take into consideration the need for logistical support, services, and infrastructure that help an agency achieve and maintain essential functions and services. To account for the expected high rate of absenteeism at the peak of a pandemic, FEMA guidance also directs agencies to identify at least three people who can carry out each responsibility and identify how the agency will continue to operate if leadership and essential staff are unavailable. Finally, agencies are directed to test their pandemic plans, including the impacts of reduced staffing on facilities and essential functions and services.APHIS has developed pandemic plans for its headquarters, regional offices, and three laboratories that employ veterinarians, but these plans are missing elements in FEMA's guidance and are not well-organized. For example, they do not explain how animal care, disease investigation, and other essential functions and services would continue if leadership and essential staff are unavailable. Moreover, pieces of these pandemic plans are spread throughout a large number of documents and are not well linked. For example, APHIS officials provided us with an undated pandemic plan that they told us was an appendix to the headquarters continuity of operations plan.
But this continuity of operations plan made no reference to such an appendix, and officials were never able to provide us with a document that made reference to such an appendix. USDA recently hired a new emergency preparedness director to revise APHIS's pandemic plans, among other things. The director told us that APHIS recognizes the importance of easily locating the plans and quickly implementing them in the event of a pandemic, and he acknowledged that the current documents are not an effective plan. APHIS is now combining its plans into one comprehensive document that will cover APHIS headquarters, regional offices, and laboratories. In addition, the director told us the new plan, to be completed by early 2009, will better adhere to FEMA guidance.FSIS has developed a pandemic plan that addresses many of the elements in FEMA's guidance, but it lacks some crucial details. Importantly, the plan takes into account the work that veterinarians do at private slaughter plants. However, it does not address the logistics of how FSIS will work with industry to ensure veterinarians and other employees are available in the event of a pandemic so that food production can continue. FSIS officials told us that they have discussed this logistic with industry and expect, based on these discussions, that some plants would not be able to operate during a pandemic, as a result of FSIS or plant personnel absenteeism. The agency would maintain close communication with industry during a pandemic in order to determine how best to allocate available veterinarians and other FSIS inspection personnel so that slaughter plants could continue to operate. Veterinarians would be allocated to plants based on considerations such as the location of the outbreak and the type of slaughter plant affected. For instance, poultry plants may receive priority consideration because birds can only be slaughtered at a very specific weight. That is, the equipment for processing birds is designed for birds of a very specific size, and industry would not be able to process them if they were permitted to grow too large.
However, such logisitcs are absent from FSIS’s plan, effectively postponing any decisions until the middle of a crisis. Similarly, the plan does not mention how FSIS would work with APHIS, even though the agencies have formally agreed to jointly plan for critical activities related to surveillance of animal diseases. In addition, the plan does not consider the impact of local quarantines on access to plants.ARS has developed pandemic plans for all of its 12 laboratories where veterinarians work. We reviewed plans for the two laboratories that employ the most veterinarians: the Southeast Poultry Research Laboratory and the National Animal Disease Center (NADC). These plans are important because they spell out the site-specific details needed to ensure that essential functions at each laboratory can continue. However, the plans lack crucial details, such as how the laboratories will continue operations if absenteeism reaches 40 percent. Specifically, neither of the plans take into account how the laboratories would continue to conduct essential functions and services if leadership and essential staff are unavailable. Agency officials told us they would temporarily suspend projects to account for increased absenteeism, but there is no mention of this in the plans; nor is there mention of how the agency will select projects for suspension or what would trigger suspension. Ensuring a sufficient veterinarian workforce at these laboratories during a pandemic is important because veterinarians carry out critical research and must be available to ensure the proper care of research animals. In addition, NADC is part of a USDA research complex that is transitioning to joint ARS and APHIS support services, including veterinary care for research animals. However, ARS and APHIS have yet to jointly plan for continuity of operations for any type of emergency.
FDA has also developed a pandemic plan, but it is high-level plan that does not address several of FEMA's elements, leaving it unclear if consideration has been given to how veterinarians would carry out any essential functions and services during a pandemic.
For example, it does not identify which essential functions—whether they be the responsibility of the veterinarian or others—must be performed on-site and which can be performed remotely. Nor does it explain how veterinarians, or others, will continue operations if absenteeism reaches 40 percent by, for example, delegating authority to three individuals capable of carrying out each of the agency's essential functions. The plan omits other important details, such as contact information for individuals who could assume authority should essential staff and leadership become unavailable. FDA officials told us they will take these gaps into consideration when they update their plan in 2009.The Army is still in the process of getting its pandemic plan approved and, therefore, we have not evaluated it. According to Army officials, the agency has developed a pandemic plan that has been validated by the U.S. Army Northern Command, but it has not yet been formally referred for approval to the Army's senior leadership, and it does not contain details of how essential functions would continue. According to DOD officials, subordinate divisions within the Army intend to develop detailed plans, but the division responsible for veterinary services (Veterinary Command) has yet to do so. However, DOD officials told us that the Army has been instrumental in helping the United States plan for an outbreak of highly pathogenic avian influenza in birds. Controlling the outbreak in birds reduces the opportunity for the virus to mutate into a strain that could cause a pandemic in humans.
FEMA guidance also directs agencies to test how well their pandemic plans might maintain essential functions and services given reduced staffing levels. FSIS and FDA are the only agencies we reviewed that have done so. In March 2007, FSIS conducted a “tabletop” pandemic exercise where key personnel discuss simulated scenarios in an informal setting in order to test their plans, policies, and procedures. In a summary report, FSIS officials noted that, among other things, additional exercises were needed to improve coordination with industry. FSIS subsequently conducted a similar tabletop exercise with industry in November 2008, but the summary report on lessons learned has yet to be published. FDA conducted an operational exercise in October 2008—a drill to test how well it could continue operations under a staffing shortage. As part of this exercise, FDA tested its ability to reassign tasks, but it is not clear if tasks performed by veterinarians were among those reassigned. FDA officials told us that they plan to issue a report with lessons learned from the exercise in early 2009 and will incorporate that information into FDA's pandemic plan. ARS and APHIS have not tested their plans to see how well their agencies might maintain essential functions and services in the event of reduced staffing levels, but officials told us they intend to do so.