54 



where the pest is not yet well estabUshed," quoting specifically 

 from the OTA report. 



We do not currently attempt to prevent introduction of all pest 

 species that are already established here, for a number of reasons. 

 Our exclusion policies and decisions must comply with existing 

 internationsd trade agreements, and also must be in accord with 

 science-based risk information. 



OTA acknowledges that complete exclusion of pests from the U.S 

 by our agency probably is infeasible. However, the report also as- 

 serts that the overall success of APHIS' efforts to exclude pests is 

 difficult to evaluate, in part, because the agency lacks adequate 

 performance measures. That problem is being addressed specifi- 

 cally and hopefully is to be corrected through one of the pilot 

 projects of the Government Performance and Results Act of 1993. 

 The goal of the project is to enable APHIS to better articulate de- 

 sired AQI program outcomes and to measure whether those desired 

 outcomes are, in fact, being achieved. 



We are also responding to the identified need for improvement 

 in the U.S. system of monitoring agricultural diseases and pests 

 through the National Animal Health Monitoring System and the 

 Cooperative Agricultural Pest Survey Program which we have in 

 place. 



The OTA notes that biological control agents that are not mi- 

 crobes are exempt from FIFRA and fall under APHIS' jurisdiction. 

 APHIS has not yet promulgated regulations specifically for such 

 agents and instead imposes a permitting requirement developed for 

 plant pests under the existing authority. APHIS is reviewing bio- 

 logical control organisms that are non-indigenous on the basis of 

 their potential for plant pest risk. We intend to have permitting re- 

 quirements commensurate with the level of risk presented by the 

 organism of interest. 



The OTA report points out several perceived weaknesses in the 

 APHIS risk assessment and analysis process. APHIS has sought 

 and continues to work to modify these procedures. With respect to 

 APHIS' requirement for demonstrated risks before preventing im- 

 ports, APHIS, as a matter of principle, does not require regulations 

 unless a justification can be demonstrated. 



Although we applaud and value the OTA study, there are several 

 items that we believe should be brought to the Committee's atten- 

 tion. The study did not cover organisms such as those causing ani- 

 mal diseases, especially those including transmissible diseases from 

 animals to humans. In response, APHIS would like to make clear 

 that control and exclusion of these organisms have constituted 

 major technical, scientific and regulatory successes of this century. 

 APHIS' Veterinary Services Program that produced these successes 

 could offer working models, expertise, suggestions and hard-earned 

 lessons on quarantine, inspection and testing procedures. 



We also are concerned about comparing genetically-engineered 

 organisms with non-indigenous species. The act of genetic modifica- 

 tion with modern molecular techniques does not by itself render an 

 organism non-indigenous. 



When developing and implementing programs to protect agri- 

 culture and our natural resources, funding and resources, person- 

 nel, and so forth, are usually big questions relative to that. Public 



