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GAO-26-108488, COVID-19: Federal Efforts and Stakeholder Views on Expediting the Transportation of Personal Protective Equipment (full report, 2026-09-14)

Summary

Government Accountability Office report GAO-26-108488, dated September 2026, on how federal agencies expedited the transportation of personal protective equipment during the COVID-19 pandemic. From March through June 2020, FEMA's Project Airbridge paid for 437 flights carrying approximately 1.2 billion PPE items, mainly gloves, masks and gowns, from overseas. The Department of Transportation used its legal authorities to expedite air shipments, and the Federal Aviation Administration let some passenger airlines carry cargo in aircraft cabins. GAO interviewed 21 stakeholders from transportation, health care distribution and port authorities, many of whom said a larger federal role was unnecessary or could have had negative consequences. The review was required by Public Law 118-159.

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“GAO-26-108488, COVID-19: Federal Efforts and Stakeholder Views on Expediting the Transportation of Personal Protective Equipment (full report, 2026-09-14).” Original at www.gao.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gao-26-108488-covid-19-federal-efforts-and-stakeholder-views-on-expedi-201557d0b8/, SHA-256 c8fc69f6533b954de236aa0e25553fc50c5258d0ec674a8d26f194d37d73e917.

Full text

                 United States Government Accountability Office
                 Report to Congressional Committees




                 COVID-19
September 2026




                 Federal Efforts and
                 Stakeholder Views on
                 Expediting the
                 Transportation of
                 Personal Protective
                 Equipment




GAO-26-108488
                                COVID-19

    Highlights                  Federal Efforts and Stakeholder Views on Expediting the
                                Transportation of Personal Protective Equipment
       GAO-26-108488            September 2026

A report to congressional committees
Contact: Elizabeth Repko at RepkoE@gao.gov

What GAO Found                                                                        Why GAO Did This Study
Personal protective equipment (PPE)—such as masks and gloves—helps                    During the COVID-19 pandemic,
minimize exposure to hazards, including illnesses. In response to the COVID-19        significant challenges, including global
pandemic (March 2020–May 2023), the Federal Emergency Management                      demand and supply chain issues, made
Agency (FEMA) and the Department of Transportation (DOT) expedited the                it difficult to quickly access PPE. Delays
transportation of PPE by air and helped mitigate supply chain challenges.             in the transportation of PPE may have
                                                                                      contributed to the spread of COVID-19,
•   FEMA. From March through June 2020, FEMA conducted Project Airbridge,             which killed nearly 1.2 million people in
    in which FEMA paid for the air transportation of PPE from overseas to the         the U.S. as of June 1, 2024.
    U.S. to reduce shipment times. FEMA funded 437 flights to transport
                                                                                      Public Law 118-159 includes a
    approximately 1.2 billion PPE items, primarily gloves, masks, and gowns.
                                                                                      provision for GAO to review the
•   DOT. DOT used selected legal authorities to help expedite the transportation      expedited transportation of PPE during
    of PPE by air and to provide transportation industry stakeholders with            the COVID-19 pandemic. This report
    regulatory relief that could have expedited the transportation of PPE. For        describes, among other things, (1) how
    example, DOT’s Federal Aviation Administration issued exemptions from             DOT and other relevant federal
    certain regulations during the COVID-19 pandemic to allow certain                 agencies expedited the transportation of
                                                                                      PPE during the pandemic, including
    passenger air carriers to transport cargo in the passenger cabins of aircraft.
                                                                                      using selected legal authorities to do so;
DOT and other federal agencies also coordinated with transportation industry          and (2) selected industry stakeholder
stakeholders specifically to mitigate supply chain issues and keep goods moving       perspectives on methods used to
during the pandemic, which may have expedited the transportation of PPE.              expedite the transportation of PPE
                                                                                      during the COVID-19 pandemic,
Boxes of Personal Protective Equipment Transported in the Passenger Cabin of an       including their views on whether an
Aircraft During the COVID-19 Pandemic                                                 increased federal role was needed.
                                                                                      GAO reviewed documentation and
                                                                                      interviewed officials from five federal
                                                                                      agencies that played a role in
                                                                                      expediting the transportation of PPE:
                                                                                      DOT, FEMA, Health and Human
                                                                                      Services (HHS), the Department of
                                                                                      Defense, and the Federal Maritime
                                                                                      Commission. GAO also reviewed
                                                                                      relevant statutes, regulations, and
                                                                                      executive orders and analyzed available
                                                                                      data from FEMA and HHS that
                                                                                      described the amount and type of PPE
                                                                                      that these agencies transported during
Stakeholders GAO interviewed shared perspectives on methods to expedite the           the COVID-19 pandemic.
transportation of PPE used during the COVID-19 pandemic, and many said that
an increased federal role was unnecessary or could have had negative                  GAO interviewed a nongeneralizable
consequences. For example, two stakeholders cited the use of “peel piles” to          sample of 21 stakeholders representing
designate areas at ports for containers from specific shippers as a method used       three groups relevant to the
                                                                                      transportation of PPE: transportation
to expedite goods during the pandemic, including PPE. Many stakeholders said
                                                                                      industries, health care distributors, and
they did not think more federal involvement was needed in expediting the
                                                                                      port authorities. GAO selected these
transportation of PPE during the pandemic, or that increased federal involvement      stakeholders based on factors including
could have had negative consequences. For example, stakeholders said that             geographic diversity, involvement in
federal involvement in prioritizing a container on a ship could have caused delays    federal efforts to expedite the
at ports. Furthermore, several of these stakeholders stated that the private sector   transportation of PPE, or market share
and industry partners were better suited to take the lead in expediting the           of their respective industry.
transportation of goods through the supply chain.

                                                                               United States Government Accountability Office
Contents


Letter                                                                               1
              Background                                                             4
              FEMA and DOT Expedited the Transportation of PPE Primarily by
                Air, with Support from Other Federal Agencies                      11
              Stakeholders Identified Methods Used to Expedite the
                Transportation of PPE; Many Said an Increased Federal Role
                Was Not Needed                                                     26
              Agency Comments                                                      31

Appendix I    Analysis of U.S. Census Bureau Trade Statistics                      32



Appendix II   GAO Contact and Staff Acknowledgments                                34



Tables
              Table 1: Dollar Value of Personal Protective Equipment (PPE)
                      Imported During the COVID-19 Pandemic, 2020 – 2022             6
              Table 2: Personal Protective Equipment (PPE) Items Imported by
                      FEMA Project Airbridge, March–June 2020                      13
              Table 3: Selected DOT Legal Authorities That Could Help
                      Expedite the Transportation of Personal Protective
                      Equipment (PPE)                                              16


Figures
              Figure 1: Value of Personal Protective Equipment (PPE) Imported
                       from 2018 Through 2024                                        5
              Figure 2: Examples of Challenges at Ports Related to
                       Transporting Goods During the COVID-19 Pandemic               8
              Figure 3: Selected Federal Roles in Transporting Personal
                       Protective Equipment (PPE) Through the Supply Chain
                       During the COVID-19 Pandemic                                12
              Figure 4: Boxes of Personal Protective Equipment Transported in
                       the Passenger Cabin of an Aircraft During the COVID-19
                       Pandemic                                                    19




              Page i                                             GAO-26-108488 COVID-19
 Abbreviations

 DOD               Department of Defense
 DOT               Department of Transportation
 DPA               Defense Production Act of 1950, as amended
 FAA               Federal Aviation Administration
 FEMA              Federal Emergency Management Agency
 FMCSA             Federal Motor Carrier Safety Administration
 FRA               Federal Railroad Administration
 HHS               Department of Health and Human Services
 MARAD             Maritime Administration
 PPE               personal protective equipment




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Page ii                                                          GAO-26-108488 COVID-19
                       Letter




441 G St. N.W.
Washington, DC 20548




                       September 14, 2026

                       The Honorable Ted Cruz
                       Chairman
                       The Honorable Maria Cantwell
                       Ranking Member
                       Committee on Commerce, Science, and Transportation
                       United States Senate

                       The Honorable Sam Graves
                       Chairman
                       The Honorable Rick Larsen
                       Ranking Member
                       Committee on Transportation and Infrastructure
                       House of Representatives

                       During the COVID-19 pandemic, a range of challenges—including global
                       demand, supply chain issues, and limited domestic production—made it
                       difficult to quickly access personal protective equipment (PPE). 1 PPE—
                       such as face shields, masks, respirators, gowns, and gloves—helps
                       minimize exposure to hazards, including illnesses. Even when PPE could
                       be manufactured and purchased, delays in shipping often prevented
                       medical professionals and others from receiving it quickly. These
                       transportation delays may have contributed to the spread of COVID-19,
                       which killed nearly 1.2 million people in the U.S. as of June 1, 2024,
                       according to the Centers for Disease Control and Prevention.

                       During the pandemic, federal agencies, including the Department of
                       Transportation (DOT) and the Federal Emergency Management Agency
                       (FEMA), as well as the transportation industry, took actions to help
                       expedite the transportation of PPE. For the purposes of this report, we
                       define “expediting” the transportation of a good as reducing the amount of
                       time the good spends in transit using various methods, such as
                       prioritizing the transportation of that good over other goods.

                       The Servicemember Quality of Life Improvement and National Defense
                       Authorization Act for Fiscal Year 2025 includes a provision for GAO to

                       1For the purposes of this report, we date the pandemic’s onset to March 11, 2020, when
                       the World Health Organization declared the COVID-19 outbreak to be a global pandemic.
                       The public health emergency declared by the Secretary of Health and Human Services for
                       COVID-19 ended on May 11, 2023.



                       Page 1                                                         GAO-26-108488 COVID-19
review the roles that DOT and other relevant federal agencies played in
expediting the transportation of PPE and how relevant stakeholders
interacted during the COVID-19 pandemic to transport PPE, among other
things. 2 In this report, we describe

1. how DOT and other relevant federal agencies expedited the
   transportation of PPE during the COVID-19 pandemic, including using
   selected legal authorities to do so; and
2. selected industry stakeholder perspectives on methods used to
   expedite the transportation of PPE during the COVID-19 pandemic,
   including their views on whether an increased federal role was
   needed.

To describe how DOT and other relevant federal agencies expedited the
transportation of PPE during the COVID-19 pandemic, we selected five
federal agencies that played a role in doing so: DOT, FEMA, the
Department of Defense (DOD), the Federal Maritime Commission, and
the Department of Health and Human Services (HHS). 3 We also selected
seven relevant offices and operating administrations within DOT: the
Federal Aviation Administration (FAA); the Federal Motor Carrier Safety
Administration (FMCSA); the Federal Highway Administration; the
Maritime Administration (MARAD); the Federal Railroad Administration
(FRA); the Office of the Assistant Secretary for Aviation and International
Affairs; and the Office of Intelligence, Security, and Emergency
Response. 4 We reviewed relevant statutes, regulations, executive orders,
and agency documentation. We also interviewed officials from these
selected agencies, offices, and operating administrations regarding their
roles and responsibilities related to transporting PPE; their legal
authorities that could be used to help expedite the transportation of PPE;
and whether they used those legal authorities during the pandemic.

In addition, we analyzed available data from FEMA and HHS that
described the amount and type of PPE that these federal agencies

2See Pub. L. No. 118-159, § 3522, 138 Stat. 1773, 2311 (2024).

3Through our review of GAO, Congressional Research Service, and Office of Inspector
General reports and discussions with federal agencies and industry stakeholders, we
identified these agencies as having a role in administrative or logistical efforts to expedite
the transportation of PPE during COVID-19.
4We identified these operating administrations and Secretarial offices as relevant to our
review based on discussions with DOT and our review of DOT documentation. We refer to
DOT Secretarial offices as DOT offices in this report.




Page 2                                                              GAO-26-108488 COVID-19
transported during the COVID-19 pandemic. Because there is no single
source of data describing the total amount of PPE that federal agencies
transported, we obtained these data to provide examples of selected
federal agencies’ efforts. To assess the reliability of these data, we
interviewed agency officials about their data collection and quality control
practices. We determined that these data were sufficiently reliable for our
purpose of describing the amount of PPE that selected federal agencies
transported during the pandemic.

We also analyzed U.S. Census Bureau trade statistics from January 2018
through December 2024 to describe the amount and type of PPE
imported during the COVID-19 pandemic. We chose this period to
examine how imports changed after the pandemic compared with what
they were before, for context. To assess the reliability of these data, we
reviewed relevant documentation and conducted electronic data testing.
We determined that these data were sufficiently reliable for our purposes
of describing the amount of PPE imported during the pandemic. See
appendix I for more information on how we analyzed these data.

To describe industry stakeholder perspectives on methods used to
expedite the transportation of PPE during the COVID-19 pandemic,
including their views on whether an increased federal role was needed,
we interviewed a nongeneralizable sample of 21 stakeholders. 5 These
selected stakeholders represented three groups relevant to the
transportation of PPE: transportation industries, health care distributors,
and port authorities. 6 We interviewed representatives from these groups
about a range of topics, such as their role in transporting and expediting
PPE during the COVID-19 pandemic, how they coordinated with different
stakeholders and federal agencies to do so, and challenges they
experienced. We used a range of criteria to select industry stakeholders
to interview, such as geographic diversity, involvement in federal efforts to
expedite PPE, or market share of their respective industry. In addition, in


5For reporting purposes, we used the following indefinite quantifiers to describe collective
responses from our interviewees: “some” is three to five, “several” is six to 10, and “many”
is 11 or more.
6To represent transportation industries, we selected 1) two motor carriers, 2) three
terminal operators, 3) one air cargo handler, 4) two rail carriers, 5) four sea vessel
operators, and 6) one integrated express carrier. Integrated express carriers operate air
and ground transportation and provide “door-to-door” service (e.g., FedEx and UPS). In
addition, we selected three port authorities, two health care distributors, and three industry
associations—one representing rail carriers, one representing health care distributors, and
one representing air cargo carriers.




Page 3                                                             GAO-26-108488 COVID-19
                         September 2025, we conducted site visits to Seattle and Los Angeles to
                         meet with selected port authorities and terminal operators.

                         We conducted this performance audit from May 2025 through September
                         2026 in accordance with generally accepted government auditing
                         standards. Those standards require that we plan and perform the audit to
                         obtain sufficient, appropriate evidence to provide a reasonable basis for
                         our findings and conclusions based on our audit objectives. We believe
                         that the evidence obtained provides a reasonable basis for our findings
                         and conclusions based on our audit objectives.

Background
PPE Imports During the   According to U.S. Census Bureau trade statistics, the U.S. imported
COVID-19 Pandemic        approximately $108 billion in PPE from January 2018 through December
                         2024; of this, $65 billion was imported during the pandemic (January
                         2020 through December 2022) (see fig. 1). 7 Nearly 40 percent of PPE
                         imported into the U.S. during the pandemic—approximately $25 billion in
                         PPE—was imported through West Coast ports. 8 Approximately $19
                         billion, or about 30 percent, of PPE imported during the COVID-19
                         pandemic was imported through the Los Angeles district (including the
                         ports of Los Angeles and Long Beach). 9




                         7U.S. Census Bureau trade statistics—a widely used source analyzing U.S. international
                         trade—do not contain precise data on import values of products related to COVID-19. As
                         a result, we estimated the import value of all product types and categories within those
                         types, using the Harmonized Tariff Schedule of the U.S. statistical reporting numbers and
                         associated product groupings listed by the U.S. International Trade Commission. See U.S.
                         International Trade Commission, COVID-19 Related Goods: U.S. Imports and Tariffs
                         (Updated), Investigation No. 332-576, USITC Publication 5073 (Washington, D.C.: June
                         2020). We adjusted all import values for inflation, using monthly import price indices from
                         the Bureau of Labor Statistics to identify the average inflation adjustment for 2024, which
                         we used as the base for the yearly adjustments.
                         8We identified ports and airports in Oregon, Washington, and California as West Coast
                         ports. These cover five customs district codes: 25, 27, 28, 29, and 30. For context, there
                         are 47 district codes.
                         9The Los Angeles district contains 14 ports and airports: the port of Los Angeles, the port
                         of Long Beach, Ventura, Port Hueneme, Capitan, Morrow Bay, Los Angeles International
                         Airport, Ontario International Airport, Las Vegas airport, TNT Express, IBC Pacific,
                         Meadows Field Airport, DHL-HUB, and UPS-Ontario.




                         Page 4                                                            GAO-26-108488 COVID-19
Figure 1: Value of Personal Protective Equipment (PPE) Imported from 2018
Through 2024




Note: We have adjusted all import values for inflation, using monthly import price indices from the
Bureau of Labor Statistics to identify the average inflation adjustment for 2024, which we used as the
base for the yearly adjustments.


Of the approximately $65 billion in PPE imported during the pandemic,
over $20 billion was for masks, and $27 billion was for gloves (see table
1).




Page 5                                                                    GAO-26-108488 COVID-19
                      Table 1: Dollar Value of Personal Protective Equipment (PPE) Imported During the
                      COVID-19 Pandemic, 2020 – 2022
                          PPE type                                                           Total value (in millions of dollars)a
                          Aprons                                                                                               $98
                          Gloves                                                                                            27,635
                          Gowns                                                                                               3,819
                          Hair nets                                                                                              63
                          Headgear                                                                                             904
                          Masks                                                                                             20,696
                          Protective garments                                                                                 7,637
                          Protective goggles                                                                                  2,990
                          Shoe covers                                                                                         1,293
                          Total                                                                                            $65,135
                      Source: GAO analysis of U.S. Census Bureau trade statistics. | GAO-26-108488
                      a
                       We adjusted all import values for inflation, using monthly import price indices from the Bureau of
                      Labor Statistics to identify the average inflation adjustment for 2024, which we used as the base for
                      the yearly adjustments.



Challenges at Ports   We and others identified various factors that contributed to congestion at
During the COVID-19   ports during the COVID-19 pandemic. 10 After the onset of the COVID-19
Pandemic              pandemic in March 2020, the number of U.S. import shipments overall
                      declined briefly, before rebounding from July 2020 through December
                      2021 and exceeding prepandemic levels. 11 This increase in cargo
                      volume, together with other factors—including limited storage space,
                      reduced capacity due to labor shortages, and limited technology and
                      equipment—contributed to congestion at ports. The Congressional
                      Research Service reported in 2021 that dozens of ships were at anchor
                      waiting to dock at ports in locations such as Los Angeles and Long
                      Beach. Figure 2 shows examples of challenges at ports related to
                      transporting goods during the pandemic. These challenges at ports
                      resulted in delays for all goods, including PPE, during the pandemic. The
                      Health Industries Distributors Association estimated that medical
                      10For example, the U.S. International Trade Commission reported that air freight
                      experienced supply chain challenges during COVID-19, in addition to ports. Air cargo
                      experienced a decrease in capacity to transport freight in the cargo holds of passenger
                      aircraft due to cancelled flights. This decreased capacity, coupled with increased demand,
                      resulted in a steep increase in air freight rates. International Trade Commission, The
                      Impact of the COVID-19 Pandemic on Feight Transportation Services and U.S.
                      Merchandise Imports.
                      11GAO, COVID-19: CBP Acted to Mitigate Challenges Affecting Its Trade Operations,
                      GAO-22-105034 (Washington D.C.: Sept. 19, 2022).




                      Page 6                                                                               GAO-26-108488 COVID-19
supplies, including PPE, were delayed an average of 37 days throughout
the transportation system. 12 This included an average 17-day delay at
ports, 11-day delay by rail, and 9-day delay by motor carrier.




12To develop this estimate, representatives from the Health Industry Distributors
Association surveyed a total of 14 health care distributors on the amount of time that
medical supplies were delayed, on average, during the fourth quarter of 2021.




Page 7                                                            GAO-26-108488 COVID-19
Figure 2: Examples of Challenges at Ports Related to Transporting Goods During the COVID-19 Pandemic




                                       Page 8                                                    GAO-26-108488 COVID-19
                         Labor shortages. The U.S. International Trade Commission reported
                         that port, rail, and motor carrier industries faced labor shortages, which
                         caused delays in transporting goods. 13 Specifically, according to Customs
                         and Border Patrol, the Port of Los Angeles had a backlog of containers in
                         May and June 2020 because warehouse operators had reduced their
                         staff when cargo drastically declined at the beginning of the COVID-19
                         pandemic. This reduction led to a lack of available staff when cargo
                         volumes increased after a few months.

                         Limited equipment and technology. The fluctuations in demand during
                         the COVID-19 pandemic also highlighted limitations in technology and
                         equipment. For example, when demand rebounded, some ports
                         experienced shortages of chassis and storage containers. In addition,
                         information systems and automated technology, which could be used to
                         increase efficiencies, varied by port. We previously reported that U.S.
                         ports have adopted automated technology to varying degrees. Port
                         stakeholders have said that these technologies’ effects on the workforce
                         and security, as well as their performance, have been mixed. 14 For
                         example, a port authority representative told us that port automation
                         would not have prevented many of the supply chain delays and
                         disruptions that arose during the COVID-19 pandemic.

Federal Supply Chain     We and others have previously reported on the roles of FEMA, HHS, and
Roles and the COVID-19   DOT in assisting the supply chain during the COVID-19 pandemic,
                         including their efforts to assist in the transportation of PPE.
Pandemic Response
                         •   FEMA. FEMA was responsible for reviewing resource requests and
                             making priorities and allocation decisions for health and medical
                             resources needed to respond to the spread of COVID-19 within the




                         13U.S. International Trade Commission, The Impact of the COVID-19 Pandemic on Feight
                         Transportation Services.
                         14GAO, Port Infrastructure: U.S. Ports Have Adopted Some Automation Technologies and
                         Report Varied Effects, GAO-24-106498 (Washington, D.C.: Mar. 19, 2024).




                         Page 9                                                       GAO-26-108488 COVID-19
    U.S. 15 In addition, FEMA was responsible for coordinating the
    distribution of those resources across the federal government, private
    sector, and other strategic partners in the civilian market. This
    included distribution to state, local, tribal, and territorial governments,
    as well as to private entities, such as hospitals.
•   HHS. HHS led the federal public health and medical response during
    the COVID-19 pandemic, including transporting PPE from the
    Strategic National Stockpile to areas of need. The Strategic National
    Stockpile is a multibillion-dollar inventory of drugs, vaccines, and
    supplies that can be provided to states, localities, territories, and
    Tribes during emergencies. HHS transported approximately $278
    million PPE from the Strategic National Stockpile during COVID-19,
    including approximately $206 million worth of masks. We previously
    reported on HHS’s efforts to distribute PPE from the Strategic
    National Stockpile during COVID-19. 16 HHS also could make priorities
    and allocation decisions for health and medical resources needed to
    respond to the spread of COVID-19 within the U.S. 17
•   DOT. DOT regulates and oversees various modes of cargo
    transportation—including trucking, rail, and air. Within DOT, FAA
    oversees the safety and efficiency of the national airspace system and
    distributes federal financial assistance to airports for airport



15See Exec. Order No. 13911, Delegating Additional Authority Under the Defense
Production Act With Respect to Health and Medical Resources To Respond to the Spread
of COVID-19, § 4, 85 Fed. Reg. 18403, 18404-18405 (Mar. 27, 2020); 44 C.F.R. Part 333.
Health and medical resources needed to respond to the spread of COVID-19 within the
U.S. included PPE. Exec. Order No. 13909, Prioritizing and Allocating Health and Medical
Resources to Respond to the Spread of COVID-19, § 1, 85 Fed. Reg. 16227, 16227 (Mar.
18, 2020); Exec. Order No. 13911 § 1. In April 2020, the President issued a memo
directing FEMA, in consultation with HHS, to allocate certain PPE for domestic use. See
Memorandum on Allocating Certain Scarce or Threatened Health and Medical Resources
to Domestic Use (Apr. 3, 2020).
16GAO, COVID-19: Sustained Federal Action Is Crucial as Pandemic Enters Its Second
Year, GAO-21-387 (Washington, D.C.: Mar. 31, 2021); COVID-19: Continued Attention
Needed to Enhance Federal Preparedness, Response, Service Delivery, and Program
Integrity, GAO-21-551 (Washington, D.C.: July 19, 2021); and Public Health
Preparedness: HHS Should Address Strategic National Stockpile Requirements and
Inventory Risks, GAO-23-106210 (Washington, D.C.: Oct. 17, 2022); Also, GAO, COVID-
19: Federal Efforts Could Be Strengthened by Timely and Concerted Actions,
GAO-20-701 (Washington D.C.: Sept. 21, 2020); and COVID-19: Urgent Actions Needed
to Better Ensure an Effective Federal Response, GAO-21-191 (Washington D.C.: Nov. 30,
2020).
17See Exec. Order No. 13909 § 2.




Page 10                                                        GAO-26-108488 COVID-19
                             infrastructure. 18 DOT does not generally have a role in port ownership
                             and operations. DOT supports ports by providing guidance,
                             participating in training exercises, and providing funding for
                             infrastructure projects. 19

                         In September and November 2020, we reported on the actions that HHS
                         and FEMA had taken—with support from DOD—to mitigate supply
                         shortages and expand the medical supply chain, chiefly through the
                         Supply Chain Task Force. 20 The Supply Chain Task Force, later renamed
                         the Supply Chain Advisory Group, was the primary federal body
                         coordinating and managing supply chain responsibilities. We refer to both
                         in this report as the Supply Chain Advisory Group. Charged with
                         maximizing the nationwide availability of supplies and equipment, the
                         Supply Chain Advisory Group focused on accelerating the delivery of
                         supplies, including PPE. 21

                         In response to the COVID-19 pandemic, FEMA initiated Project Airbridge
FEMA and DOT             in March 2020 to expedite the transportation of PPE and other medical
Expedited the            supplies by air from overseas manufacturers. FEMA also worked with
                         HHS and DOD to help ensure that PPE was distributed to locations where
Transportation of PPE    it was most needed. In addition, DOT used selected legal authorities
Primarily by Air, with   during the COVID-19 pandemic to expedite the transportation of PPE by
                         air and provide regulatory relief that could have helped expedite the
Support from Other       transportation of PPE by rail or highway. (See fig. 3.) Finally, some
Federal Agencies         federal agencies shared information and coordinated with other federal
                         agencies and transportation industry stakeholders to mitigate supply
                         chain issues during the pandemic.




                         18GAO, Air Cargo: DOT Should Communicate Data Limitations and Identify Stakeholder
                         Challenges, GAO-25-107334 (Washington, D.C.: July 23, 2025).
                         19GAO, U.S. Port Infrastructure: DOT and DHS Offer Funding and Other Assistance Ports
                         Can Use to Improve Disaster Resilience, GAO-25-107159 (Washington, D.C.: Mar. 20,
                         2025).
                         20GAO-20-701 and GAO-21-191.

                         21The Supply Chain Advisory Group focused on four key supply activities: helping
                         preserve existing supplies, accelerating the delivery of supplies, expanding the production
                         of supplies, and gathering data to help allocate scarce supplies. The Supply Chain
                         Advisory Group transitioned its responsibilities to HHS in late January 2021.




                         Page 11                                                           GAO-26-108488 COVID-19
Figure 3: Selected Federal Roles in Transporting Personal Protective Equipment (PPE) Through the Supply Chain During the
COVID-19 Pandemic




FEMA Imported PPE by                    From March through June 2020, FEMA conducted Project Airbridge to
Air, and Other Federal                  reduce the time it took to receive supplies, including PPE, from overseas
                                        manufacturers. FEMA initiated Project Airbridge to serve as a temporary
Agencies Identified Needs               solution to shortages in the domestic supply of PPE. 22 Under Project
and Provided Support                    Airbridge, FEMA paid for the commercial air transportation of supplies
                                        from an overseas port to a port in the U.S. According to FEMA, it
                                        arranged for air transportation to the US, and the medical distributors
                                        received the PPE at the airport for delivery to the medical distributors’
                                        warehouses. Medical supply distributors agreed to distribute at least 50
                                        percent of the transported PPE to customers at a reasonable price to
                                        areas FEMA and HHS prioritized.


                                        22Although Project Airbridge reduced shipment times to transport PPE into the U.S., a
                                        Department of Homeland Security Office of the Inspector General report found that FEMA
                                        did not sufficiently assess whether medical supply distributors needed Project Airbridge to
                                        stabilize their supply chains. In addition, FEMA did not ensure that distributors delivered
                                        PPE to health care facilities, as agreed. Department of Homeland Security, Office of
                                        Inspector General, FEMA Did Not Provide Sufficient Oversight of Project Airbridge, OIG-
                                        23-14 (Washington, D.C.: February 2023).




                                        Page 12                                                           GAO-26-108488 COVID-19
FEMA officials said Project Airbridge reduced shipment times from an
estimated 40 days to 7 days by using air freight instead of sea shipments.
According to data that FEMA provided, FEMA funded 437 flights from
March through June 2020 as part of Project Airbridge. In addition, FEMA
worked with six medical supply distributors to transport and distribute
approximately 1.2 billion PPE items, primarily gloves, masks, and gowns
(see table 2).

Table 2: Personal Protective Equipment (PPE) Items Imported by FEMA Project
Airbridge, March–June 2020

    PPE type                                                                   Total PPE items transported
    Gloves                                                                                             945,128,493
    Masks                                                                                              126,190,250
    Gowns                                                                                                66,633,405
    PPE apparel                                                                                              6,753,055
    N95 masks                                                                                                5,146,420
    Face shields                                                                                             2,751,824
    Coveralls                                                                                                1,473,960
    KN95 masksa                                                                                              1,200,000
    Aprons                                                                                                     45,000
    Respirators                                                                                                 8,000
    Total                                                                                            1,155,330,407
Source: GAO analysis of Federal Emergency Management Agency (FEMA) Project Airbridge data. | GAO-26-108488
a
 N95 masks are approved by the National Institute for Occupational Safety and Health to filter at least
95 percent of airborne particles. See 42 C.F.R. § 84.170. KN95 masks are not approved by the
National Institute for Occupational Safety and Health to meet the same standard. However, for part of
the COVID-19 pandemic, the Food and Drug Administration authorized certain KN95 masks for
health care use, provided certain conditions were met, under an emergency use authorization.


Several federal agencies provided support to FEMA’s Project Airbridge.
For example, FAA prioritized flights, and the Office of the Assistant
Secretary for Aviation and International Affairs expedited economic
licensing processes for certain air carriers, as described below. 23 In
addition, Customs and Border Protection expedited the customs
clearance process for Project Airbridge flights and formed the COVID-19
23The Office of the Assistant Secretary for Aviation and International Affairs may issue
permits to foreign air carriers authorizing them to transport cargo between a place in the
U.S. and a place outside the U.S. by aircraft and for compensation, if it makes certain
findings. Foreign air carriers that do not hold these economic licenses are prohibited from
providing such transportation. See 49 U.S.C. §§ 40102, 41301-41302; 49 C.F.R. §
1.25a(b)(6)(ii)(B) (delegating these authorities to the Office of the Assistant Secretary for
Aviation and International Affairs).




Page 13                                                                                GAO-26-108488 COVID-19
Cargo Resolution Team to mitigate challenges related to importing PPE
and other pandemic-related products. The team worked with FEMA daily
to alert ports that shipments of critical medical supplies were arriving and
helped expedite the arrival and clearance of 418 of the 437 Project
Airbridge flights. 24 FEMA officials also said that the Department of State
played a key role in facilitating the movement of PPE through China and
resolving customs issues with the Chinese government.

In addition to leading Project Airbridge, FEMA worked with HHS and the
Defense Logistics Agency on the Supply Chain Advisory Group to assess
demand for PPE, identify sources of PPE overseas, and procure and
transport medical supplies and PPE for Project Airbridge and the
Strategic National Stockpile.

•   Assessing demand for PPE. HHS officials said HHS and FEMA
    created the Supply Chain Control Tower to identify COVID-19
    outbreaks and monitor data on the market demand for PPE in each
    state, to determine where PPE could be distributed to address
    shortages. Specifically, HHS officials said they used the Supply Chain
    Control Tower to, among other things, monitor weekly survey data
    from medical facilities, including from over 2,000 hospitals, on the
    number of days’ worth of PPE they had left. HHS used these data to
    coordinate the transportation of PPE from medical distributors to
    areas with shortages. To do this, HHS worked with its 11 existing
    motor carriers, integrated express carriers, and air cargo partners to
    transport PPE from the Strategic National Stockpile to medical
    facilities with PPE shortages.
•   Identifying sources of PPE. FEMA officials said FEMA and HHS
    worked to identify available PPE from overseas sources. They began
    this effort to resupply the Strategic National Stockpile but shifted to
    identifying sources of PPE for the overall U.S. market. Once the
    Supply Chain Advisory Group assessed PPE demand in states,
    FEMA and HHS collaborated to identify manufacturing companies
    overseas that had available PPE. FEMA officials said the agency then
    coordinated with the State Department to verify that the manufacturer
    was a legitimate company and with the Food and Drug Administration
    to verify the quality of the PPE.
•   Procuring and transporting PPE. The Defense Logistics Agency
    worked with FEMA and HHS to procure and arrange transportation for
    the PPE from overseas manufacturers once they had identified a

24GAO-22-105034.




Page 14                                                GAO-26-108488 COVID-19
                              source. Defense Logistics Agency officials said the agency supported
                              43 FEMA agreements to acquire PPE and antigen tests for states,
                              and 23 HHS agreements to procure medical goods, including PPE, for
                              the Strategic National Stockpile, nursing homes, and test sites. 25
                              Defense Logistics Agency officials said these shipments were
                              delivered to government warehouses owned by FEMA and HHS.
                              According to officials, FEMA and HHS then worked with medical
                              suppliers to organize the delivery of PPE to hospitals or other areas,
                              as needed. 26 According to FEMA, two maritime carriers were used to
                              ship PPE from Asia to the West Coast along a 10-day direct sailing
                              route. FEMA used these carriers because they consistently had
                              available space on their direct sailing vessels, which allowed FEMA to
                              avoid port delays.

DOT Used Selected Legal   DOT used selected legal authorities during the COVID-19 pandemic to
Authorities to Help       expedite the transportation of PPE by air and to provide regulatory relief
                          that could have helped expedite the transportation of PPE. Through our
Expedite the
                          review of statutes, regulations, and executive orders, and our interviews
Transportation of PPE,    with DOT offices and operating administrations, we and DOT identified
Primarily by Air          eight selected DOT legal authorities that could help expedite the
                          transportation of PPE (see table 3).




                          25DOD officials said that these agreements resulted in over $360.3 million worth of PPE to
                          support FEMA and $3.2 billion worth of PPE to support HHS.
                          26DOD’s U.S. Transportation Command supported HHS with six requests for assistance
                          during COVID-19. Four requests were for the U.S. Transportation Command to transport
                          needles and syringes from overseas to the U.S.; one was to airlift personnel between two
                          points in the U.S., and one was to move personnel and COVID-19 test kits from overseas
                          into the U.S. However, none of these efforts involved the transportation of PPE.




                          Page 15                                                          GAO-26-108488 COVID-19
Table 3: Selected DOT Legal Authorities That Could Help Expedite the Transportation of Personal Protective Equipment (PPE)

                                                                                                                             Used during
DOT office or operating                                                                                                      COVID-19
administration               Legal authority             Description of legal authority                                      pandemic
Federal Aviation             49 U.S.C. § 40103           FAA may modify or revoke its assignments of the use of              Yes
Administration (FAA)                                     the navigable airspace when required in the public
                                                         interest.a
                             Regulatory relief           FAA may grant exemptions from certain FAA safety                    Yes
                                                         regulations, if it finds that the exemption is in the public
                                                         interest.b
Office of the Assistant      Emergency interstate air DOT may temporarily exempt foreign air carriers from                   Yes
Secretary for Aviation and   transportation by foreign certain statutory requirements and limitations to allow
International Affairs        air carriers              them to carry cargo in interstate air transportation in
                                                       certain markets, to the extent it decides an exemption is
                                                       in the public interest and if it makes certain findingsc The
                                                       Office of the Assistant Secretary for Aviation and
                                                       International Affairs may exercise this authority.d
                             Expedited economic          DOT may issue permits to foreign air carriers authorizing           Yes
                             licensing for foreign air   them to transport cargo between a place in the U.S. and a
                             carriers, upon request      place outside the U.S. by aircraft and for compensation, if
                                                         it makes certain findings.e The Office of the Assistant
                                                         Secretary for Aviation and International Affairs may
                                                         exercise this authority.f Foreign air carriers can request
                                                         expedited proceedings for this economic licensing.g
Federal Motor Carrier        Regulatory relief           FMCSA may grant temporary waivers of compliance with,               Yes
Safety Administration                                    and exemptions from, its safety regulations under certain
(FMCSA)                                                  circumstances.h
Federal Railroad             Regulatory relief           FRA may issue temporary emergency waivers of                        Yes
Administration (FRA)                                     compliance with any part of its railroad safety regulations,
                                                         if it makes certain determinations, which include that the
                                                         waiver is not inconsistent with railroad safety and is
                                                         necessary to address an actual, or impending,
                                                         emergency situation or emergency event.i
Office of Intelligence,      Defense Production Act      The President has delegated DPA, Title I authorities to             No
Security, and Emergency      of 1950 (DPA), Title Ij     DOT with respect to all forms of civil transportation.k
Response                                                 These delegated authorities, in part, permit DOT to
                                                         require the acceptance and priority performance of
                                                         certain contracts or orders over others to promote the
                                                         national defense.l The Office of Intelligence, Security, and
                                                         Emergency Response may exercise DOT’s delegated,
                                                         DPA, Title I authorities and oversees the implementation
                                                         of the Transportation Priorities and Allocation System,
                                                         which are DOT regulations that provide guidance and
                                                         procedures for the use of such authorities.m




                                              Page 16                                                               GAO-26-108488 COVID-19
                                                                                                                                                         Used during
 DOT office or operating                                                                                                                                 COVID-19
 administration                           Legal authority                        Description of legal authority                                          pandemic
 Maritime Administration                  DPA, Title VIIn                        The President has delegated DPA, Title VII authorities to DOT           No
 (MARAD)                                                                         with respect to all forms of civil transportation.o These
                                                                                 authorities, in part, permit DOT to consult with representatives
                                                                                 of business, industry, and other interests to develop and
                                                                                 establish voluntary agreements to help provide for the national
                                                                                 defense.p MARAD, in consultation with the Office of
                                                                                 Intelligence, Security and Emergency Response, may
                                                                                 exercise DOT’s delegated DPA Title VII, authorities as
                                                                                 they relate to the use of maritime industry-related facilities
                                                                                 and services, such as port facilities and sealift support,
                                                                                 and maritime-related voluntary agreements.q
Source: GAO analysis of statutes, regulations, executive orders, and Department of Transportation (DOT) information. | GAO-26-108488
                                                                 a
                                                                  FAA is required to assign the use of the navigable airspace by regulation or order necessary to
                                                                 ensure the safety of aircraft and the efficient use of airspace. 49 U.S.C. § 40103
                                                                 b
                                                                     See 49 U.S.C. § 44701(f).
                                                                 c
                                                                  For example, DOT must find that because of an emergency created by unusual circumstances not
                                                                 arising in the normal course of business, air carriers holding certain certificates cannot accommodate
                                                                 traffic in those markets. See 49 U.S.C. § 40109(g).
                                                                 d
                                                                     See 49 C.F.R. § 1.25a(b)(6)(i).
                                                                 e
                                                                  Foreign air carriers that do not hold these permits are prohibited from providing such transportation.
                                                                 See 49 U.S.C. §§ 40102, 41301-41302.
                                                                 f
                                                                     49 C.F.R. § 1.25a(b)(6)(ii)(B).
                                                                 g
                                                                     See 14 C.F.R. § 302.11(e).
                                                                 h
                                                                     See 49 U.S.C. §§ 31133(a)(10), 31136(e); 49 C.F.R. § 1.87(f).
                                                                 See 49 U.S.C. § 20103(g); 49 C.F.R. § 1.89(a). FRA emergency waivers must be requested. See 49
                                                                 i

                                                                 C.F.R. § 211.45.
                                                                 j
                                                                  See Pub. L. No. 81-774, 64 Stat. 798 (1950) (codified as amended at 50 U.S.C. § 4501 et seq.). Title
                                                                 I of the DPA is codified as amended at 50 U.S.C. § 4511.
                                                                 k
                                                                  See Exec. Order No. 13603, National Defense Resources Preparedness, § 201, 77 Fed. Reg.
                                                                 16651, 16652 (Mar. 16, 2012).
                                                                 See 50 U.S.C. § 4511(a); Exec. Order No. 13603 § 201. However, DOT may only exercise its
                                                                 l

                                                                 delegated DPA Title I authorities to support approved programs. See Exec. Order No. 13603 § 202;
                                                                 49 C.F.R. §§ 33.2, 33.20. An “approved program” is a program that the Secretary of Defense,
                                                                 Secretary of Energy, or Secretary of Homeland Security has determined to be necessary or
                                                                 appropriate to promote the national defense, in accordance with Section 202 of Executive Order
                                                                 13603. 49 C.F.R. § 33.20. The DPA defines “national defense” to include emergency preparedness
                                                                 activities conducted under Title VI of the Robert T. Stafford Disaster Relief and Emergency
                                                                 Assistance Act (Stafford Act). 50 U.S.C. § 4552(14); Stafford Act, Title VI (codified as amended at 42
                                                                 U.S.C. § 5195 et seq.).
                                                                 m
                                                                     See 49 C.F.R. § 1.45(q); 49 C.F.R. pt. 33 (Transportation Priorities and Allocation System).
                                                                 n
                                                                     See DPA § 708 (codified as amended at 50 U.S.C. § 4558).
                                                                 o
                                                                     See Exec. Order No. 13603 § 401.
                                                                 p
                                                                  See 50 U.S.C. § 4558; 44 C.F.R. § 332.1. However, DOT may only exercise its DPA Title VII
                                                                 authorities after certain conditions are met. For example, DOT must find that conditions exist that may
                                                                 pose a direct threat to the national defense or its preparedness programs and obtain the required
                                                                 findings and approvals from certain other executive agencies, such as the Federal Emergency
                                                                 Management Agency. See 50 U.S.C. § 4558(c); 44 C.F.R. § 332.2.
                                                                 q
                                                                     See 49 C.F.R. § 1.93(l).




                                                                 Page 17                                                                     GAO-26-108488 COVID-19
Expediting Air Operations and   FAA and the Office of the Assistant Secretary for Aviation and
Economic Licensing Processes    International Affairs officials used two of the legal authorities described in
                                table 3 to prioritize flights carrying PPE and to expedite the economic
                                licensing process for foreign air carriers transporting PPE.

                                •   Prioritizing flights carrying PPE. FAA officials said FAA used its
                                    legal authority to prioritize takeoffs and landings for domestic and
                                    international cargo flights carrying PPE. 27 Specifically, FAA officials
                                    said they coordinated with air traffic control towers, command centers,
                                    and industry stakeholders to identify flights with PPE and to prioritize
                                    those flights for departure or arrival. FAA began to use this authority
                                    at the start of the COVID-19 pandemic to support FEMA’s effort to
                                    import PPE through Project Airbridge and continued to use it after
                                    Project Airbridge ended. In total, FAA prioritized 4,417 flights carrying
                                    PPE from April 2020 through September 2020. 28
                                •   Expediting economic licensing. Officials from the Office of the
                                    Assistant Secretary for Aviation and International Affairs said the
                                    office used its legal authority to expedite the economic licensing
                                    process, upon request, for foreign air cargo carriers transporting PPE
                                    for FEMA’s Project Airbridge. 29 Specifically, officials said they worked
                                    with FEMA daily during the pandemic to help FEMA identify flights
                                    carrying emergency supplies for Project Airbridge. The office informed
                                    air cargo carriers and integrated express carriers of the steps needed
                                    to receive an economic license to transport goods to the U.S. and
                                    helped them expedite the licensing process. According to officials, the
                                    office granted licenses for 2,200 flights transporting PPE primarily
                                    from China to the U.S. from March 2020 through March 2022.




                                27FAA is required to assign the use of the navigable airspace by regulation or order
                                necessary to ensure the safety of aircraft and the efficient use of airspace and may modify
                                or revoke its assignments when required in the public interest. See 49 U.S.C. § 40103.
                                28According to data from DOT’s Bureau of Transportation Statistics, U.S. airlines operated
                                around 1.7 million domestic flights from April through September 2020.
                                29The Office of the Assistant Secretary for Aviation and International Affairs may issue
                                permits to foreign air carriers authorizing them to transport cargo between a place in the
                                U.S. and a place outside the U.S. by aircraft and for compensation, if it makes certain
                                findings. Foreign air carriers that do not hold these permits are prohibited from providing
                                such transportation. See 49 U.S.C. §§ 40102, 41301-41302; 49 C.F.R. § 1.25a(b)(6)(ii)(B)
                                (delegating these authorities to the Office of the Assistant Secretary for Aviation and
                                International Affairs). Foreign air carriers can request expedited proceedings for this
                                economic licensing. See 14 C.F.R. § 302.11(e).




                                Page 18                                                           GAO-26-108488 COVID-19
Providing Regulatory Relief   Some DOT operating administrations used their legal authorities during
                              the COVID-19 pandemic to provide relief from their respective regulations
                              via exemptions or waivers. DOT officials said that DOT’s operating
                              administrations issued these exemptions or waivers to keep the supply
                              chain moving for all types of goods, not specifically for PPE.

                              •   Passenger-to-freight exemptions. FAA issued exemptions from
                                  certain FAA regulations during the COVID-19 pandemic to allow
                                  certain passenger air carriers to transport cargo in the passenger
                                  cabins of aircraft. 30 FAA issued these exemptions to ensure continued
                                  air transportation, as passenger travel declined during the pandemic.
                                  One association representing the aviation industry said some air
                                  carriers used the passenger-to-freight exemption to expedite the
                                  transportation of PPE during the pandemic. As shown in figure 4,
                                  some airlines used this exemption to transport cargo, such as PPE, in
                                  the aircraft’s passenger cabin. The exemption described actions air
                                  carriers must take to address safety concerns of using the exemption
                                  to transport cargo in passenger cabins. For example, FAA provided
                                  specific requirements for restraining cargo on passenger seats and
                                  limitations on cargo weight and loading.

                              Figure 4: Boxes of Personal Protective Equipment Transported in the Passenger
                              Cabin of an Aircraft During the COVID-19 Pandemic




                              •   Hours-of-service exemptions. FMCSA issued an exemption, in part,
                                  from its hours-of-service regulations for drivers actively transporting
                                  supplies necessary for community safety and the prevention of

                              30See e.g., Federal Aviation Administration, Exemption No. 18584, Partial Grant of
                              Exemption, Regulatory Docket No. FAA-2020-0492 (July 10, 2020). FAA may grant
                              exemptions from certain FAA safety regulations if it finds that the exemption is in the
                              public interest. See 49 U.S.C. § 44701(f).




                              Page 19                                                            GAO-26-108488 COVID-19
    community transmission of COVID-19, including PPE. 31 FMCSA’s
    hours-of-service regulations generally provide that the maximum
    driving time for commercial motor vehicle operators transporting
    property is 11 hours within a 14-hour period. 32 This exemption
    allowed, but did not require, drivers to exceed this maximum. 33
    FMCSA officials said that motor carriers may have used this
    exemption during the pandemic and, if so, that this could have helped
    expedite the transportation of PPE. In August 2021, FMCSA issued
    an extension and amendment of this exemption, which provided that
    motor carriers were to begin reporting their use of the exemption each
    month through FMCSA’s portal. 34 FMCSA officials said that motor
    carriers were not required to report to FMCSA on their use of the
    exemption and that they did not receive any reports from motor
    carriers. Representatives of one motor carrier told us that they were
    aware this exemption was available but did not experience a driver
    shortage that would require them to use this exemption. The motor
    carrier representative also stated that a consideration in using these
    exemptions is that extending drivers’ hours could lead to a potential
    safety risk for drivers and pedestrians.
•   Inspections and testing waivers. FRA issued emergency waivers of
    compliance with certain FRA regulations upon request, in part, to
    address workforce shortages that were preventing railroads from




31See Federal Motor Carrier Safety Administration, Emergency Declaration No. 2020-002
Under 49 CFR § 390.23 (Mar. 13, 2020). FMCSA may grant temporary waivers of
compliance with, and exemptions from, its safety regulations under certain circumstances.
See 49 U.S.C. §§ 31133(a)(10), 31136(e); 49 C.F.R. § 1.87(f).
32See 49 C.F.R. § 395.3.

33In addition, FMCSA’s extension of its exemption clarified that drivers are not exempt
from its regulations prohibiting them from operating commercial motor vehicles when they
are, for example, fatigued, in such a way that impairs, or is likely to impair, their ability or
alertness so as to make it unsafe for them to drive. The extension also stated that motor
carriers may not require or permit fatigued drivers to operate these vehicles, and drivers
who inform motor carriers that they need immediate rest must be given at least 10
consecutive hours of rest before driving again. See Federal Motor Carrier Safety
Administration, Extension and Expansion of Emergency Declaration No. 2020-002 Under
49 CFR § 390.25 (Apr. 8, 2020).
34See Federal Motor Carrier Safety Administration, Extension and Amendment of
Emergency Declaration No. 2020-002 Under 49 CFR § 390.25 (Aug. 31, 2021).




Page 20                                                               GAO-26-108488 COVID-19
                                   complying with such regulations. 35 For example, some rail
                                   associations requested FRA to permit freight railroads to move
                                   locomotives between facilities even if they had not inspected and
                                   tested the locomotives within the periods specified in FRA regulations,
                                   and FRA granted them a waiver of those regulations. FRA officials
                                   said freight cars may have had reduced inspections, which could have
                                   helped expedite the transportation of PPE. While available, the
                                   waivers were not widely used because most rail companies were able
                                   to keep their operations moving without using the waivers,
                                   representatives from a rail association said.

Using Defense Production Act   The President has delegated DPA, Title I authorities to DOT with respect
Authorities                    to all forms of civil transportation. 36 These delegated authorities, in part,
                               permit DOT to require the acceptance and priority performance of certain
                               contracts or orders over others to promote the national defense. 37 These
                               authorities could help expedite the transportation of PPE during a national
                               emergency. 38




                               35See Federal Railroad Administration, Re: Request for Relief in FRA Emergency Docket
                               FRA-2020-0002 related to Coronavirus Disease 2019 (COVID-19) (Mar. 25, 2020). FRA
                               may issue temporary emergency waivers of compliance with any part of its railroad safety
                               regulations, if it makes certain determinations, which include that the waiver is not
                               inconsistent with railroad safety and is necessary to address an actual or impending
                               emergency situation or emergency event. See 49 U.S.C. § 20103(g); 49 C.F.R. § 1.89(a).
                               36See Pub. L. No. 81-774, 64 Stat. 798 (1950) (codified as amended at 50 U.S.C. § 4501
                               et seq.); Exec. Order No. 13603, National Defense Resources Preparedness, § 201,
                               77 Fed. Reg. 16651, 16652 (Mar. 16, 2012). Title I of the DPA is codified as amended at
                               50 U.S.C. § 4511.
                               37See 50 U.S.C. § 4511(a); Exec. Order No. 13603 § 201. However, DOT may only
                               exercise its delegated DPA, Title I authorities to support approved programs. See Exec.
                               Order No. 13603 § 202; 49 C.F.R. §§ 33.2, 33.20. An “approved program” is a program
                               that the Secretary of Defense, Secretary of Energy, or Secretary of Homeland Security
                               has determined to be necessary or appropriate to promote the national defense, in
                               accordance with Section 202 of Executive Order 13603. 49 C.F.R. § 33.20. The DPA
                               defines “national defense” to include emergency preparedness activities conducted under
                               Title VI of the Robert T. Stafford Disaster Relief and Emergency Assistance Act (Stafford
                               Act). 50 U.S.C. § 4552(14); Stafford Act, title VI (codified as amended at 42 U.S.C. § 5195
                               et seq.)
                               38We previously reported that DOD used other DPA authorities to increase domestic
                               manufacturing capacity of medical supplies during COVID-19. GAO-20-701.




                               Page 21                                                          GAO-26-108488 COVID-19
According to DOT, it did not use its DPA, Title I authorities during the
COVID-19 pandemic. 39 To do so, DOT officials said DOT must receive a
request from an agency with relevant jurisdiction, such as FEMA or HHS,
and that it did not receive such a request during the pandemic. FEMA and
HHS officials said they did not have any transportation concerns that
required DOT intervention during that period. 40

DOT’s Office of Intelligence, Security, and Emergency Response
collaborated regularly with other agencies to determine whether using
DOT’s delegated DPA Title I authorities was necessary to help expedite
PPE during the COVID-19 pandemic. 41 Officials said the office has an
established process to receive and process requests for other agencies to
use DOT’s delegated DPA, Title I authorities. 42 During the pandemic, this
process included weekly interagency meetings with DPA Program
Managers from agencies such as HHS, FEMA, and DOD to discuss the
execution of priority ratings and identify needs for agencies to provide
DPA support. FEMA and HHS officials told us they were aware of DOT’s
request process but that they used other methods to increase the supply
of PPE, such as through Project Airbridge, as described above. DOT
officials said the agency has continued to participate in a monthly DPA
interagency working group to coordinate with other agencies on potential
DPA requests.


39In our prior review, we found that DOT had not placed a priority rating on contracts or
orders during fiscal years 2018 through 2024. See GAO, Defense Production Act:
Information Sharing Needed to Improve Use of Authorities, GAO-25-107688 (Washington
D.C.: June 12, 2025).
40Both agencies used their delegated DPA Title I authorities to issue one allocation order
in April 2020 to control the distribution of certain scarce or threatened health and medical
resources, including PPE, within the commercial market during the pandemic. They issued
this allocation order to ensure that companies were not hoarding or exporting these
resources outside of the U.S., and the order was unrelated to DOT’s delegated authority
to issue a priority rating. Allocation orders control the distribution of materials, services, or
facilities in the U.S. commercial market deemed necessary to support national defense.
GAO-25-107688.
41The Office of Intelligence, Security, and Emergency Response may exercise DOT’s
delegated DPA, Title I authorities and oversees the implementation of the Transportation
Priorities and Allocation System, which are DOT regulations that provide guidance and
procedures for the use of such authorities. See 49 C.F.R. § 1.45(q); 49 C.F.R. pt. 33
(Transportation Priorities and Allocation System).
42The Office of Intelligence, Security, and Emergency Response receives Form OST F
1254, which other agencies and entities can submit to the Office of Intelligence, Security,
and Emergency Response to request special priorities assistance from DOT. See 49
C.F.R. § 33.40.




Page 22                                                              GAO-26-108488 COVID-19
                             The President has delegated DPA, Title VII authorities to DOT with
                             respect to all forms of civil transportation, which, in part, permit DOT to
                             consult with representatives of industry, business, and other interests to
                             establish voluntary agreements to help provide for the national defense. 43
                             MARAD, in consultation with the Office of Intelligence, Security, and
                             Emergency Response, may exercise DOT’s delegated DPA, Title VII
                             authorities. 44 DOT officials said that DOT did not use its delegated DPA,
                             Title VII authorities to enter into new voluntary agreements during the
                             COVID-19 pandemic because neither FEMA or HHS requested it to do
                             so. MARAD has two existing voluntary agreements with the maritime
                             industry that were established before the pandemic: the Voluntary Tanker
                             Agreement and the Voluntary Intermodal Sealift Agreement. DOT officials
                             said MARAD did not use these agreements to help expedite PPE during
                             the pandemic because their scopes and purposes would not have been
                             useful to the transportation of PPE. For example, the Voluntary
                             Intermodal Sealift Agreement provides DOD with access to commercial
                             sealift services and systems, including intermodal equipment, when DOD
                             deploys military forces during a national emergency or wartime operation,
                             or when DOD determines it is necessary for national security or
                             contingency operations, which did not occur during the pandemic. 45

DOT and Other Federal        DOT’s offices and operating administrations shared information and
Agencies Shared              coordinated with other federal agencies and transportation industry
                             stakeholders to mitigate supply chain issues during the COVID-19
Information and
                             pandemic. In addition, other federal agencies, such as the U.S.
Coordinated with the         Transportation Command and the Federal Maritime Commission,
Transportation Industry to   coordinated with transportation industry stakeholders to keep goods
Mitigate Supply Chain        moving through the supply chain. These efforts may have helped
Issues                       expedite the transportation of PPE.



                             43See DPA § 708 (codified as amended at 50 U.S.C. § 4558); Exec. Order No. 13603
                             § 401.
                             44See 49 C.F.R. § 1.93(l). However, MARAD may only exercise these delegated
                             authorities as they relate to the use of maritime industry-related facilities and services,
                             such as port facilities and sealift support, and maritime-related voluntary agreements, and
                             only if certain conditions are met. For example, MARAD must find that conditions exist that
                             may pose a direct threat to the national defense or its preparedness programs and obtain
                             the required findings and approvals from certain other executive agencies, such as FEMA.
                             See 50 U.S.C. § 4558(c); 44 C.F.R. § 332.2; 49 C.F.R. § 1.93(l).
                             45MARAD’s other voluntary agreement, the Voluntary Tanker Agreement, was designed to
                             provide DOD with the commercial tanker capacity to transport petroleum and petroleum
                             products necessary to meet national defense contingency requirements.




                             Page 23                                                          GAO-26-108488 COVID-19
According to DOT officials, DOT operating administrations also
participated in discussions with transportation industry stakeholders to
share information about the COVID-19 pandemic and distribute PPE to
their respective industries.

•   Motor carrier industry. FMCSA officials said the agency held daily
    calls with the motor carrier industry to discuss the industry’s
    immediate needs and transportation challenges, including those
    related to the usage of PPE. FMCSA officials said they also helped
    address the industry’s PPE needs by representing motor carriers on
    the Supply Chain Advisory Group and requesting that FEMA distribute
    cloth face masks to motor carrier companies. In addition, FMCSA
    officials said the agency also issued press releases to inform the
    motor carrier industry of exemptions from certain motor carrier
    regulations.
•   Maritime industry. MARAD officials said the agency hosted biweekly
    calls with maritime stakeholders, including port authorities,
    longshoremen’s unions, and U.S. flag vessel operators, to provide
    COVID-19 updates and learn about challenges the maritime industry
    was encountering. According to MARAD officials, MARAD also
    received and processed around 2.4 million cloth face masks from
    FEMA and distributed them to around 500 maritime industry
    stakeholders.
•   Rail industry. FRA officials said they participated in regular calls with
    rail associations to discuss the pandemic’s impact on railroad
    employees and operations, including the daily number of employees
    testing positive for COVID-19, staffing issues, and supply chain
    challenges. As part of these calls, FRA officials said they received
    reports from railroads on their use of emergency relief provisions and
    distributed cloth face masks to rail workers.

DOT’s Office of Intelligence, Security, and Emergency Response
responded to requests for information from other agencies, primarily
through the Supply Chain Advisory Group. Specifically, officials from this
office said that one of their roles during the COVID-19 pandemic was to
coordinate requests for information between the Supply Chain Advisory
Group and DOT operating administrations on issues related to
transportation.

According to officials, this information-sharing role sometimes involved
the transportation of PPE. For example, Office of Intelligence, Security,
and Emergency Response officials said they facilitated communications



Page 24                                                 GAO-26-108488 COVID-19
between the Supply Chain Advisory Group and the Office of the Assistant
Secretary for Aviation and International Affairs when the advisory group
had questions about air freight applications.

Other federal agencies also shared information and coordinated with
transportation industry stakeholders to transport PPE outside of Project
Airbridge and Supply Chain Advisory Group efforts.

•   U.S. Transportation Command. U.S. Transportation Command
    officials said they held calls with sea vessel operators once every
    other week. Officials said they worked with sea vessel operators to
    use these calls to share information on challenges affecting the
    maritime supply chain, such as port congestion caused by lines of
    ships waiting to offload cargo at ports. U.S. Transportation Command
    officials said that while U.S. flag vessels typically receive priority
    berthing access at ports, U.S. flag vessels had to compete with other
    sea vessel carriers for berthing access due to high volumes of ships
    during the COVID-19 pandemic. One sea vessel operator that
    transported PPE said the calls helped U.S. flag vessels get to ports
    and offload cargo faster.
•   Federal Maritime Commission. Federal Maritime Commission
    officials said the agency’s role was focused on advocacy and
    coordination during the COVID-19 pandemic. 46 For example, Federal
    Maritime Commission commissioners sent a letter to MARAD
    recommending that MARAD prioritize providing critical medical
    supplies, including PPE, to the U.S. maritime workforce.
    Representatives from one health care distributor industry association
    said the Federal Maritime Commission also communicated with
    industry stakeholders during the pandemic and worked with medical
    distributors to help them expedite PPE shipments at ports, as
    described below.




46The Federal Maritime Commission is an independent federal agency responsible for the
economic regulation of the commercial transportation of cargo by water between the U.S.
and foreign countries. See 46 U.S.C. § 46101(a); 46 C.F.R. § 501.2. It does not have
specific authorities that would allow it to expedite the transportation of PPE at ports.




Page 25                                                         GAO-26-108488 COVID-19
Stakeholders
Identified Methods
Used to Expedite the
Transportation of
PPE; Many Said an
Increased Federal
Role Was Not
Needed
Stakeholders Generally     Several of the 21 stakeholders we interviewed, specifically those that
Did Not Know Which         transport goods, said that a key challenge in expediting the transportation
                           of PPE is the difficulty in identifying which shipments contain PPE. 47
Shipments Contained
                           These stakeholders said they have limited information about, or may not
PPE, but Some Identified   know, the contents of their cargo, which may be due to how the cargo is
Methods to Expedite        labeled or classified. For instance, one stakeholder said that they
Goods                      generally do not have specific information about the contents of their
                           containers, unless the goods are hazardous.

                           Some stakeholders, including representatives of port operators and a sea
                           vessel operator, said that having more information about the contents of
                           shipments could help identify which shipments contain PPE and may
                           need to be expedited. Stakeholders suggested options for providing that




                           47Many stakeholders also cited challenges they experienced transporting all types of
                           goods, including PPE, during the pandemic. These challenges were similar to those
                           described above and included port congestion, port infrastructure and equipment
                           limitations, labor shortages, and maintaining worker safety.




                           Page 26                                                         GAO-26-108488 COVID-19
information, such as tracking databases, customs designations, and
commodity- or class-based freight ratings. 48

Despite the challenge of having limited information about the contents of
containers, the stakeholders we interviewed identified some methods to
expedite goods, including PPE. For example, stakeholders cited three
methods used during the COVID-19 pandemic. 49

•   Priority berthing. All four of the sea vessel operators we spoke with
    said that having priority berthing at a port helped them to more quickly
    transport goods during the pandemic. These stakeholders were able
    to receive priority berthing for different reasons, including having
    agreements with port operators and unions, having their own port
    terminal, or carrying specific types of goods (such as U.S. government
    or sustenance goods).
•   Peel piles. Peel piles are designated areas at ports for containers
    from a specific shipper. Two stakeholders, representing a port

48We and other federal agencies have reported on challenges related to supply chain
visibility and tracking the shipments of medical supplies during the COVID-19 pandemic,
as well as on how limited information about commodities coming through ports can impact
port congestion. Following a period of port congestion at West Coast ports in 2014 and
2015, we reported on the need for additional information on supply chains and commodity
flows to address freight bottlenecks. We recommended that DOT identify and collect
freight information and develop high-quality, reliable supply chain information, which DOT
addressed in its 2020 National Freight Strategic Plan. According to DOT officials, by
improving freight data on supply chains, DOT can better identify problems, aid in
prioritizing and planning infrastructure investments, and support national freight policy
goals. GAO, West Coast Ports: Better Supply Chain Information Could Improve DOT’s
Freight Efforts, GAO-17-23 (Washington, D.C.: Oct. 31, 2016). A Congressional Research
Service report on PPE production during the COVID-19 pandemic suggested that
Congress could consider authorizing federal agencies to collect more data on supply
chain information and the status of U.S. production and distribution. Congressional
Research Service, COVID-19 and Domestic PPE Production and Distribution: Issues and
Policy Options, R46628 (Washington, D.C.: December 2020). A Department of Homeland
Security Office of the Inspector General report found that FEMA, under pressure to
expedite critical medical supplies, did not follow established business practices for
tracking shipments, which limited its visibility into the resources shipped and received.
Department of Homeland Security Office of Inspector General, FEMA Did Not Effectively
Manage the Distribution of COVID-19 Medical Supplies and Equipment, OIG-23-34
(Washington, D.C.: July 2023).
49Representatives of rail carriers said that rail carriers have limited ability to expedite
goods, such as PPE, because rail carriers are on fixed networks with fixed speeds. In
addition to the methods described below, one health care distributor adapted its
distribution process to ensure that PPE reached its destination sooner. This stakeholder
said the company saved weeks by working with third-party logistics companies to deliver
PPE to the destinations immediately surrounding ports, instead of shipping these products
to their regional hubs before sending them out for distribution.




Page 27                                                               GAO-26-108488 COVID-19
    operator and health care distributors, said they used peel piles
    specifically to expedite the transportation of PPE during the pandemic.
    Some stakeholders told us that peel piles are an effective way of
    moving cargo efficiently because they allow drivers to easily access a
    specific collection of containers. For example, a representative of a
    port terminal operator said that peel piles help port terminals avoid
    situations in which drivers need to dig out certain cargo from a big
    pile. However, stakeholders said peel piles are generally used for a
    large number of containers and that PPE shipments typically are not
    big enough to warrant a peel pile. One port operator stated that they
    made an exception during the pandemic and created peel piles for
    PPE because the product was needed.
•   “Skip the line” pass. Two stakeholders representing health care
    distributors said that systems were available at ports for truck drivers
    to pick up medical supplies through a “skip the line” pass to expedite
    PPE during the pandemic. For example, one stakeholder said they
    worked with ports to develop a system for truck drivers carrying
    medical supplies to skip to the front of the truck queue. This method
    would ensure that truck drivers picking up needed medical supplies,
    including PPE, did not have to wait in the same line as other drivers
    that were picking up less critical items, such as furniture. However,
    the two motor carriers we interviewed were either not aware of, or did
    not use, this system to expedite the transportation of PPE.

Some representatives of ports and port terminal operators suggested that
changing the ways that cargo is loaded and stowed on ships and
unloaded at ports could be used as another method to expedite the
transportation of goods, including PPE. For example, stakeholders said
that containers could be placed strategically on a ship for quicker removal
and that using technology or designated chassis could help unload
priority containers faster. However, some representatives of sea vessel
operators said that changing the methods of loading, stowing, and
unloading ships would not be an effective way to prioritize shipments
based on their operations. For instance, ships are loaded based on
weight requirements and origin and destination points, making it
challenging to reorganize containers. Additionally, moving containers
around more than necessary increases the risk of damaging their
contents.




Page 28                                                GAO-26-108488 COVID-19
Many Stakeholders Said      Many stakeholders said they generally did not think that more federal
an Increased Federal Role   involvement was needed in expediting the transportation of PPE during
                            the COVID-19 pandemic, or that increased federal involvement in
in Expediting the
                            expediting goods could have negative consequences. Specifically,
Transportation of PPE       several of these stakeholders stated that the private sector and industry
During the Pandemic Was     partners were better suited to take the lead in expediting the
Not Needed                  transportation of goods through the supply chain. For example, one
                            stakeholder that transports goods said their networks were already set up
                            to efficiently move goods through the supply chain and could be designed
                            to optimize service, cost, and the time it takes to deliver a shipment.
                            Moreover, representatives of a port operator and sea vessel operator said
                            that, if the federal government had taken steps to prioritize a certain ship
                            or container on a ship, it could have resulted in more delays at ports due
                            to the extra time needed to reorganize containers.

                            Stakeholders in the transportation industry did not identify any effects that
                            expediting the transportation of PPE during the COVID-19 pandemic had
                            on the transportation of other goods. However, some stakeholders had
                            mixed views on the effect of increasing the federal role in expediting the
                            transportation of PPE on the transportation of other goods. Two
                            stakeholders representing port terminal operators said it would be
                            possible to effectively expedite one good without affecting the delivery of
                            other goods. For example, one stakeholder said that having sufficient
                            communication and planning across the supply chain could mitigate any
                            potential effects of prioritizing a specific good to expedite. On the other
                            hand, two other stakeholders thought that an increased federal role in
                            expediting the transportation of PPE could delay other goods or have
                            unintended consequences on critical shipments. For example, a
                            representative of a sea vessel operator that transports sustenance goods
                            to Hawaii and Alaska expressed concerns about deprioritizing these
                            goods to accommodate PPE shipments.

                            Several stakeholders provided examples of ways that the federal
                            government could have provided additional support to industry in
                            expediting the transportation of PPE during the COVID-19 pandemic. 50
                            Specifically, stakeholders suggested that the federal government could
                            have increased the amount of communication, guidance, and data it
                            provided to help industry partners leverage transportation networks and

                            50Stakeholders also suggested other ways the federal government could support industry
                            in expediting goods generally, such as increasing information sharing, providing port
                            infrastructure investments, supporting the availability of truck drivers, and improving
                            coordination and leadership across federal agencies.




                            Page 29                                                            GAO-26-108488 COVID-19
identify which shipments contained PPE and needed to be expedited.
Some stakeholders found that federal information-sharing efforts during
the pandemic were helpful, such as the Supply Chain Control Tower’s
data on identifying priority areas for PPE distribution.

DOT has taken steps to provide more support to industry and increase
the resilience of the national supply chain since the COVID-19 pandemic.
In 2021, as required by the Infrastructure Investments and Jobs Act, DOT
established the Multimodal Freight Office, to administer and oversee
certain DOT multimodal freight grant programs. 51 It develops and
manages the National Freight Strategic Plan, and facilitates information
sharing on freight issues between the public and private sector. One such
information-sharing effort is the Freight Logistics Optimization Works, a
public-private partnership that facilitates information sharing between
government and industry. According to DOT, this effort can help industry
stakeholders anticipate changes in the supply chain and take proactive
steps to mitigate delays and has helped DOT establish routine
communication with maritime freight stakeholders. 52 One stakeholder that
transports goods said that receiving real-time and forward-looking data as
a part of this effort has been helpful and is useful during a supply chain
bottleneck. 53 Additionally, DOT’s 2026 National Freight Strategic Plan
details DOT’s efforts to pursue national freight policy goals, including
making the national freight system more resilient to disruptions. 54 The
plan establishes a coordinated national framework for strengthening the



51See Pub. L. No 117-58, § 21101, 135 Stat. 429, 652-657 (2021) (codified at 49 U.S.C. §
118).
52In 2025, we recommended that DOT fully assess the reliability of the air cargo data it
collects and communicate the limitations of these data. We also recommended that DOT
evaluate existing sources of information and routinely communicate with air cargo
stakeholders to identify challenges to the efficient movement of air cargo. DOT identified
steps it plans to take to address these recommendations. GAO-25-107334.
53In June 2026, DOT announced DOT’s American Supply Chain Sovereignty Initiative in
which DOT plans to develop a high-visibility dashboard linking major logistics hubs,
including the Port of Los Angeles, with ocean carriers, trucking companies, rail operators,
and retailers. This initiative aims to increase operational efficiency and enhance security
across supply chains. According to DOT, if certain proposed legislation is enacted, DOT
and the Department of Homeland Security will be able accelerate the movement of cargo
being imported by participants in a certain Customs and Border Protection’s program
through this initiative.
54U.S. Department of Transportation, 2026 National Freight Strategic Plan (Washington,
D.C.: May 2026).




Page 30                                                           GAO-26-108488 COVID-19
                  safety, efficiency, resilience, security, innovation, and workforce of the
                  U.S. freight system.

                  We provided a draft of this report to DOT, DOD, the Department of
Agency Comments   Homeland Security, the Federal Maritime Commission, and HHS for
                  review and comment. DOT, DOD, the Department of Homeland Security,
                  and HHS provided technical comments, which we incorporated, as
                  appropriate. The Federal Maritime Commission did not have any
                  comments on this report.

                  We are sending copies of this report to the appropriate congressional
                  committees, the Secretary of Transportation, the Secretary of Defense,
                  the Secretary of Homeland Security, the Chairman of the Federal
                  Maritime Commission, and the Secretary of Health and Human Services.
                  In addition, the report is available at no charge on the GAO website at
                  https://www.gao.gov.

                  If you or your staff have any questions about this report, please contact
                  me at RepkoE@gao.gov. Contact points for our Offices of Congressional
                  Relations and Media Relations may be found on the last page of this
                  report. GAO staff who make key contributions to this report are listed in
                  appendix II.




                  Elizabeth (Biza) Repko
                  Director, Physical Infrastructure




                  Page 31                                                 GAO-26-108488 COVID-19
Appendix I: Analysis of U.S. Census Bureau
              Appendix I: Analysis of U.S. Census Bureau
              Trade Statistics


Trade Statistics

              To describe the amount and type of personal protective equipment (PPE)
              imported during the COVID-19 pandemic, we analyzed U.S. Census
              Bureau trade statistics trade data from January 2018 through December
              2024. We chose this period to examine how imports changed after the
              COVID-19 pandemic compared with what they were before, for context.
              For the purposes of this analysis, we identified the pandemic as taking
              place from January 2020 through December 2022. 1

              U.S. Census Bureau trade statistics, a widely used source analyzing U.S.
              international trade, do not contain precise data on imports of products
              related to COVID-19. As a result, we identified Harmonized Tariff
              Schedule codes related to PPE at the 10-digit category. 2 Specifically, to
              identify Harmonized Tariff Schedule codes related to PPE, we relied on
              the U.S. International Trade Commission’s April and June 2020 list of
              Harmonized Tariff Schedule codes of medical supplies relevant to
              COVID-19, which includes codes specific to PPE. 3 Because the U.S.
              International Trade Commission revises Harmonized Tariff Schedule
              codes regularly, we tracked changes to these categories using
              documentation it published. 4 Some of these categories represent more
              than one product, and some categories contain products that are not

              1For the purposes of this report, we date the pandemic’s onset to March 11, 2020, when
              the World Health Organization declared the COVID-19 outbreak to be a global pandemic.
              The public health emergency declared by the Secretary of Health and Human Services for
              COVID-19 ended on May 11, 2023. Because we report yearly values of imports, we
              decided to include all of 2020, as most months of that year were included in the pandemic,
              and to exclude 2023, as most months of that year were not included in the pandemic.
              2The Harmonized Tariff Schedule comprises a hierarchical structure for describing all
              goods in trade for duty, quota, and statistical purposes. This structure is based upon the
              international Harmonized Commodity Description and Coding System, administered by
              the World Customs Organization in Brussels; the 4- and 6-digit product categories are
              subdivided into 8-digit unique U.S. rate lines and 10-digit nonlegal statistical reporting
              categories. According to the U.S. International Trade Commission, classification of goods
              in this system must be done in accordance with the General and Additional U.S. Rules of
              Interpretation, starting at the 4-digit heading level to find the most specific provision and
              then moving to the subordinate categories.
              3See U.S. International Trade Commission, COVID-19 Related Goods: U.S. Imports and
              Tariffs, Investigation No. 332-576, USITC Publication 5047 (Washington, D.C.: April
              2020); and COVID-19 Related Goods: U.S. Imports and Tariffs, (Updated) Investigation
              No. 332-576, USITC Publication 5073 (Washington, D.C.: June 2020).
              4The Committee for the Statistical Annotation of Tariff Schedules, more commonly known
              as the “484(f) Committee,” is an interagency committee made up of representatives from
              the U.S. International Trade Commission, Customs and Border Protection, and the U.S.
              Census Bureau. The 484(f) Committee adds, removes, or modifies the nonlegal 10-digit
              statistical reporting numbers in the Harmonized Tariff Schedule and Schedule B. The
              484(f) forms have been published twice annually since 2019.




              Page 32                                                             GAO-26-108488 COVID-19
Appendix I: Analysis of U.S. Census Bureau
Trade Statistics




directly relevant to COVID-19 responses. Therefore, the values presented
may overestimate the imports of products directly relevant to COVID-19
responses. Nevertheless, the values are useful indicators for tracking
import trends of such products. While the U.S. Census Bureau tracks the
quantity of items imported, we excluded quantity data from our review
because quantity data were not required for some products prior to 2019.

We express import values in U.S. dollars to characterize trends in imports
and to establish trends in a single unit of measure. Since the unit of
measure for quantity (e.g., kilogram or dozens of units) may differ across
products, using quantity to portray trends in import volume could be
misleading, since it would be unclear whether changes were driven by
changes in the composition of products being imported, which might have
different units of measurement or weight, or actual changes in quantity.
We adjusted all import values for inflation, using monthly import price
indices from the Bureau of Labor Statistics to identify the average inflation
adjustment for 2024, which we used as the base for the yearly
adjustments.

To assess the reliability of these data, we reviewed relevant
documentation, received responses to questions from knowledgeable
U.S. International Trade Commission officials, and conducted electronic
data testing. We determined that the data were sufficiently reliable for our
purposes of describing the amount of PPE imported during the COVID-19
pandemic.




Page 33                                                GAO-26-108488 COVID-19
Appendix II: GAO Contact and Staff
                  Appendix II: GAO Contact and Staff
                  Acknowledgments


Acknowledgments

                  Elizabeth (Biza) Repko, RepkoE@gao.gov
GAO Contact
                  In addition to the contact named above, Maria Mercado (Assistant
Staff             Director), Mikey Erb (Analyst in Charge), Lilia Chaidez, Melanie Diemel,
Acknowledgments   Sarah Farkas, Chloe Kay, Robert Letzler, Camilla Ma, Mary-Catherine P.
                  Overcash, Paras Sharma, Alison Snyder, Laurel Voloder, Alicia Wilson,
                  and Elizabeth Wood made key contributions to this report.




                  Page 34                                             GAO-26-108488 COVID-19
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