FW: Importing preserved arthropods
ECOLOG - In response to my earlier query and summary posting regarding importing preserved arthropods, Ellen Paul provided this useful clarification on USDA/APHIS and USFWS requirements, with specific information on how it applies to bird products. I'm passing it along at her request. Hope this helps! Cheers, Nicole Michel -Original Message- From: Ellen Paul [mailto:[EMAIL PROTECTED] Sent: Wednesday, May 02, 2007 11:12 AM To: Michel, Nicole L Subject: Importing preserved arthropods Nicole - Would you mind going back on Ecolog-L and adding this info: 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 The Ornithological Council advises that this statement is incorrect with regard to dead birds and dead manmals. See the Ornithological Council import permit guide at http://www.nmnh.si.edu/BIRDNET/PERMITS.html (major revision in progress, to include FedEx, DHL, Customs Broker info and IATA/DOT info). Permits are needed for ALL bird products (APHIS lingo for anything that was once part of a bird) and for ruminants, swine, and equids. Permit conditions will vary depending on the disease status of the country from which the exports occur and the biosafety status of your lab. Treatment of materials, if required, must be with a USDA-approved treatment method (the bird treatment methods are listed in the manual; note that FTA cards have recently been approved). If you need/want info on treatment standards for mammals, contact Ellen Paul at [EMAIL PROTECTED] Note that while technically the USDA does not currently regulate any small mammal diseases (where small mammal is defined as not swine, not ruminant, not equid), they do require permits and they will put birds and small mammals on a single permit. In fact, the entire permit system is outside the regulatory system, but try telling that to a Customs and Border Protection inspector at the port: sorry, I don't need a permit because there is no regulation saying that I need a permit. Note that CBP *is* part of Department of Homeland Security, and APHIS is part of USDA. After 9/11, the APHIS agricultural inspectors were transferred to CBP. So it is actually CBP Animal Quarantine Inspection people you deal with at the ports. Also note that you DO have to file the 3-177 at the time of import if you are importing any regulated wildlife (e.g., stuff covered under the Migratory Bird Treaty Act, CITES, ESA...). That 180-day rule applies to nonprotected species.and technically applies only to dead, preserved, dried, or embedded scientific specimens or parts thereof, imported by accredited scientists or accredited scientific institutions for taxonomic or systematic research purposes. We've had discussions with the USFWS about this limitation on the kind of research that qualifies for this exemption, and I hope that the next time they revise the regs, they will broaden this scope, but for now, this is the rule... ** Nicole Michel Dept. of Ecology and Evolutionary Biology 310 Dinwiddie Hall Tulane University New Orleans, LA 70118 **
Summary: Importing preserved arthropods
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=3Decfrsid=3D149724f9e959= 5c2 e6d8827f049a03004rgn=3Ddiv5view=3Dtextnode=3D7:5.1.1.1.7idno=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
FW: Importing preserved arthropods
Dear List, I am sending this response to all in case the information is helpful in some way for others. It appears the biggest challenge in importing preserved specimens is with the airlines and their safety regulations regarding flammable material. The other challenge is the permitting system in Costa Rica. Mo -Original Message- From: Jaronski, Stefan Sent: Monday, April 23, 2007 5:17 PM To: O'Mara, Maureen Subject: FW: Importing preserved arthropods Hi Mo, Am copying you on my consultant's response to Michel. Ugly ugly -Original Message- From: Furth, David [mailto:[EMAIL PROTECTED] Sent: Monday, April 23, 2007 4:54 PM To: [EMAIL PROTECTED] Cc: Jaronski, Stefan Subject: RE: Importing preserved arthropods 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. 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. 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 I hope this answers your questions. Feel free to send this to the ESA listserve, if you think it will be helpful. ** David G. Furth, Ph.D. Department of Entomology MRC 165, P.O. Box 37012 National Museum of Natural History Smithsonian Institution Washington, D. C. 20013-7012 USA Phone: 202-633-0990 Fax: 202-786-2894 Email: [EMAIL PROTECTED] Website: www.entomology.si.edu -Original Message- From: Jaronski, Stefan [mailto:[EMAIL PROTECTED] Sent: Monday, April 23, 2007 4:50 PM To: Furth, David Subject: FW: Importing preserved arthropods David, One of our folks just got this in. I thought you might be able to quickly and accurately answer Michel's question Stefan -Original Message- From: O'Mara, Maureen Sent: Monday, April 23, 2007 2:46 PM To: Jaronski, Stefan Subject: FW: Importing preserved arthropods Hi Stefan, This came across Ecological Soc. Of A. listserve. Thought you might know the answer to this since you deal with APHIS so much! Maybe even a suggestion on who or what department to contact? Mo -Original Message- From: Ecological Society of America: grants, jobs, news [mailto:[EMAIL PROTECTED] On Behalf Of Michel, Nicole L Sent: Monday, April 23, 2007 2:30 PM To: ECOLOG-L@LISTSERV.UMD.EDU Subject: Importing preserved arthropods Hi ECOLOG'ers and NEOORN'ers, =20 Apologies for cross-posting! =20 I have a question regarding USDA-APHIS import permit requirements. I will be collecting leaf-litter arthropods (spiders, beetles, ants, millipedes, etc.) in Costa Rica and need to bring preserved (in 70% ethanol) specimens back to the States. I've checked the USDA's website and have contacted numerous people in numerous offices and still haven't yet been able to determine whether or not arthropods count as an animal under their definitions. =20 =20 Does anyone out there have experience with bringing preserved arthropods back from Central America? I also have heard that there are strict restrictions on the amounts of ethanol in checked bags, but haven't yet been able to find out what those restrictions are. =20 Thanks for your assistance! =20 Cheers, Nicole Michel =20 =20 =20 ** Nicole Michel Dept. of Ecology and Evolutionary Biology 310 Dinwiddie Hall Tulane University New Orleans, LA 70118 ** =20
Importing preserved arthropods
Hi ECOLOG'ers and NEOORN'ers, =20 Apologies for cross-posting! =20 I have a question regarding USDA-APHIS import permit requirements. I will be collecting leaf-litter arthropods (spiders, beetles, ants, millipedes, etc.) in Costa Rica and need to bring preserved (in 70% ethanol) specimens back to the States. I've checked the USDA's website and have contacted numerous people in numerous offices and still haven't yet been able to determine whether or not arthropods count as an animal under their definitions. =20 =20 Does anyone out there have experience with bringing preserved arthropods back from Central America? I also have heard that there are strict restrictions on the amounts of ethanol in checked bags, but haven't yet been able to find out what those restrictions are. =20 Thanks for your assistance! =20 Cheers, Nicole Michel =20 =20 =20 ** Nicole Michel Dept. of Ecology and Evolutionary Biology 310 Dinwiddie Hall Tulane University New Orleans, LA 70118 ** =20
