bee importation

Doug Yanega dyanega at DENR1.IGIS.UIUC.EDU
Tue Nov 15 12:41:24 CST 1994

Apologies are due. I got a phone call from Mike Firko at USDA/APHIS today,
properly chastising me for misinformation in a recent posting - I had
commented that a European bumblebee-rearing outfit was playing fast and
loose with official USDA restrictions, and the USDA folks were apparently
not doing much about it. This was a hasty misprepresentation of the truth
that I could've avoided if I'd gone back myself and checked my source of
information. The problem is not so much that the USDA has not been doing
its best to enforce proper regulations, nor that the importers were engaged
in illegal activity - more a matter of the importer and their allies in the
US threatening to sue the USDA if they refuse to grant import permits and,
in essence, push the regulations aside by protesting unfair economic
hardship or whatever, using one form of legality to override another.
Apparently, the permits that *had* earlier been issued to allow importation
of bumblebees had been with the USDA blessing, all done above-board. Again,
my apologies for any implications about USDA negligence. The issue of
whether the USDA is unable to stop people with enough money to sue is a
separate one, and still a legitimate cause for concern, if a legal
precedent is set.
        However, the old promises uttered by Phil Lima (that scientific
shipments of dead bees from museums in other countries would not be
bothered if they weren't accompanied by import permits), apparently left
when Phil did, and official policy is indeed that any international loans
of bee specimens *must* be approved by the USDA beforehand. In other words,
my implication that the USDA was playing some of the same
"quasi-enforcement" games as FWS (where "internal policy" and the actual
regs didn't necessarily agree) was also - unfortunately, in this case -
incorrect, as of Phil's departure.
        I still maintain it serves no useful purpose for the USDA to insist
on regulating the international exchange of pinned material for research
purposes. Live bees, fine, I'll agree that's a sound policy...but when I
need to borrow a type specimen from Europe, I don't see how anyone benefits
from a two-month delay (a figure given me by someone who *has* filed the
permits in question) and the extra paperwork involved - if the USDA has
10,000 permit applications a year from folks working with live bees
already, I can't imagine how adding several hundred more permits for museum
material could possibly be anything but a drain on their resources, with no
benefit whatsoever. Bees are the only insect group requiring USDA approval
for shipment of *dead* material, and as far as I know, there is no
scientific basis for this policy (for example, it's perfectly all right to
import bees from Canadian museums, but nowhere else). I'm not even aware
that the USDA has any policies against *any* other museum specimens,
furred, feathered, or whatever - so here we have one of the most
ecologically and economically important groups of beneficial insects, and
official policies in place which ultimately serve to obstruct the free
exchange of scientific material needed to study them. Whatever the intent,
and however cooperative the USDA folks may be about handling these permits
(even if they "fly through" at 100% acceptance rate), the end result of the
"dead bees of any genus" clause is still immensely impractical for all

Doug Yanega      Illinois Natural History Survey, 607 E. Peabody Dr.
Champaign, IL 61820 USA     phone (217) 244-6817, fax (217) 333-4949
  "There are some enterprises in which a careful disorderliness
        is the true method" - Herman Melville, Moby Dick, Chap. 82

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