ECOLOG, =20
Last week I posted a question regarding necessary USDA/APHIS and USFWS permits for importing preserved arthropods from Costa Rica. I received many prompt and helpful replies - thanks to all of you! Here is a compiled summary of what I found out. The bottom line:=20 1) You do NOT need an APHIS permit for dead, preserved specimens (with a few exceptions, e.g., Apoideae, see below) =20 2) You DO need to fill out a USFWS Form 3-177 within 180 days of arrival within the States, and it's not a bad idea to have a printed copy on hand when you go through customs =20 3) 70% ethanol is not allowed on planes, but you can use alternate preservation methods (diluting ethanol to 20% w/ water for the duration of the trip, freezing and transporting in plastic containers w/ mothballs) or ship by express carrier (but see their dangerous goods exceptions). 4) You may need to sterilize soil arthropods for soil microbes (perhaps this was an exception for this one case? See below) 5) You also need export permits from the countries you're working in (FYI: OTS is very helpful in obtaining export permits for work in Costa Rica). =20 I've highlighted important points in bold. I hope this is helpful. =20 Cheers, Nicole Michel =20 =20 =20 First of all for Costa Rica you need to have official Collecting and Export permits (separate permits) from their government in order to bring the specimens legally into the USA. Within 180 days you must file a 3-177 Declaration with the U.S. Fish & Wildlife Service at your port of entry. =20 According to International Air Transport Association (IATA) regulations you cannot bring 70% ethanol on board airplanes. The best thing to do is to drain off the ethanol just before returning and use some other non-hazardous/non-dangerous fluid like propylene glycol (OK for DNA work), glycerin, etc. The other option is to have them shipped in ethanol by a trained/qualified person at an institution using proper packaging, sealing the separate containers (not over 30ml each), and not over 0.5 liters per package, properly labeled with a red/white Dangerous Goods label, etc., i.e., also following IATA regulations. =20 APHIS permitting is primarily for importation of live specimens. When you enter the USA the US Customs Declaration will ask about products you are importing and you should check the box that says "..... wildlife products." Then CBP (US Customs) may divert you to USDA/APHIS/Homeland Security for further questions and inspection. Someone may also ask you for copies of your permits and even the 3-177 Declaration, even though you really do not have to file it then, so get one on line from http://www.fws.gov/le/ImpExp/faqs.htm=20 =20 I hope this answers your questions. Feel free to send this to the ESA listserve, if you think it will be helpful. =20 =20 =20 USFWS requires that you fill out Form 3-177. They're just making sure that you aren't bringing in endangered species. I BELIEVE that it can be done after the fact (within 180 days or so from the time that you get back) but you'll need to check their most recent instructions. Here's a link to the form and instructions: http://www.fws.gov/le/ImpExp/faqs.htm=20 If the specimens dead and preserved no APHIS permit is required. =20 As far as dead bees go (anything in the Apoidea), we do have notification and declaration requirements. Here's the link to the Bee regulations: http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=3Decfr&sid=3D149724f9e959= 5c2 e6d8827f049a03004&rgn=3Ddiv5&view=3Dtext&node=3D7:5.1.1.1.7&idno=3D7=20 The relevant section starts at 7 CFR 322.29. In a nutshell, it says that, for preserved bees, we need to be notified and that you have to let the border inspectors look things over. =20 =20 ---------------------------------------------------------- =20 In our class we have brought back a few liter bottles of preserved arthropods and have had no trouble at all especially if they were preserved. They didn't even flinch at least so far. We have bought back frozen insects that were in Tupperware containers with mothballs. In 6 years we have never had a hard time since they are in ethanol. We were even able to bring back pressed leaf samples and had no US permits but had to have both collecting and export permits from Costa Rica. The ethanol question will have to be directed at the airlines. Last year we preserved them in ethanol and then emptied the ethanol and added 40% ethanol or so that was not flammable to keep them moist and then added 75% back when we arrived home and they were fine. The other option would be to ship them from San Jose to the US but the mail there is VERY SLOW in my experience. =20 One note is to have all the material in one box, with a manifest or packing slip with a description of all of the materials in it. We take classes of 6 - 24 students and have about 14 large shipping boxes and with the manifest we have had minimal problems. =20 ---------------------------------------------------------- =20 I commonly bring preserved insect specimens back from China, and our group also brings back such specimens from Europe and Africa as well. By way of this email, I am requesting my colleagues to comment on your question.=20 I can tell you, with respect to China, that in recent years I commonly empty out the majority of the ethanol immediately prior to my return flight and then refill the vials immediately upon arrival back in the states. I also commonly ship the specimens via DHL or another express carrier, and in this case, I have a form letter from APHIS and US Fish and Wildlife attached.=20 =20 ---------------------------------------------------------- =20 Incase you haven't had a bunch of responses already, I'll give you my dated experiences. I brought back several vials of ethanol-preserved antlion larvae from Costa Rica in 2001, along with pinned adults. The APHIS inspector at the airport (New York, JFK) asked 1) the % of ethanol they were preserved in and the length of time they'd been preserved, 2) to see the pinned adults, ask how they'd been killed (freezing); time periods at different temperatures, time on pins, etc. In general, since they were obviously dead, not pests, and not endangered, he was not concerned; though he did ask me to contact USFWS when I got home to make sure they were as unconcerned as he was (they were). =20 A couple of months later I was planning to bring insects back from a trip to Pakistan, so I called the APHIS and FWS agents at JFK and gave them a heads-up that I would be coming through; they seemed appreciative of the call, but once again unconcerned. It seems like it was pretty easy to get their number and they returned my calls, so you might try that just to put your mind at rest. =20 The inspectors at airports are now in the Dept of Homeland Security chain of command, rather than the USDA-APHIS chain of command. That might change in the near future. However, my impression is that unless your arthropods are terrorists, you should be fine. It might be a good idea to make sure you have copies of print-outs, correspondence with USDA or a letter with your university letter head explaining how important the specimens are to your research, preferably signed by someone other than yourself. =20 Ethanol in checked luggage isn't something I can help with. Except that everyone else on the plane will have a couple of liters of rum in theirs. =20 And presumably you're aware that you need crazy amounts of paperwork to get the specimens out of Costa Rica? =20 ---------------------------------------------------------- In my experience coming from the Caribbean, it varies widely and every trip is something new.=20 =20 Coming from a foreign country, you definitely need your permits. =20 In theory, 70% ethanol should be allowed because it is the equivalent to bringing a bottle of rum on the plane. However, I have been stopped. I now drain off all the alcohol and add enough water to effectively dilute the alcohol below 20%. As soon as I arrive, I go straight to my lab and decant the water and add ethanol. This seems to work without damaging the specimens. =20 Because everything is dead and has been preserved, APHIS should have no objections.=20 =20 I have inquired about this to Homeland Security and TSA and they will tell you that there are no hard and fast rules(beyond the prohibition of flammables). TSA and the FAA told me that it is up to the discretion of the baggage screener as to whether something is allowable. One would hope for more standardization, but... =20 However you end up going, pack everything in plastic. I have found sentrifuge tubes to be very leakproof. I also bag these in at least two layers of ziplocs and have never had anything leak out and I have been doing this 8 years at 4-5 times per year. =20 I'm Canadian but have had some experience deal with APHIS and transporting specimens on planes. A quick google on the search terms "aphis import permit arthropods" brought this up (3rd question)=20 http://www.aphis.usda.gov/plant_health/permits/faq/insects_faqs.shtml However you more than likely will be subject to US Fish and Wildlife inspection, especially if there is a chance that anything you are bringing back is subject to CITIES rules. You should also be aware that you may need a permit to collect and possibly a permit to export from Costa Rica, some central and south american countries are very strict about this. =20 The restrictions on carrying ethonol are pretty strict, anything more than a few vials carried on your person and you risk having it confiscated and I doubt any airline will accept in checked baggage. You might consider freezing your samples for the trip and pack them in a cooler with ice packs (airlines will accept this method - just prepare to have it inspected). If not I'd look at sending the specimens via courier (DHL, FedEx), just make sure you look into their dangerous goods handling rules, usually it costs a extra and requires you to arrange the shipment ahead of time. =20 =20 =20 I have only dealt with the outside. But I had a friend who was going to bring back some soil springtails for me from Russia. Since they come out of the dirt, you also have to sterilize your samples for soil microbes (like hoof and mouth disease). Needless to say, the restrictions were too great and he didn't bring any samples back. =20 =20 =20 ************************************************** Nicole Michel Dept. of Ecology and Evolutionary Biology 310 Dinwiddie Hall Tulane University New Orleans, LA 70118 ************************************************** =20
