Fwd: Proposed U.S. Federal Bee Regulation now in Federal Register

Doug Yanega dyanega at POP.UCR.EDU
Mon Aug 26 11:47:31 CDT 2002


This should be of interest to anyone who deals with international
shipment (including hand-carrying) of dead insect specimens.

Wayne.F.Wehling at aphis.usda.gov wrote:

>  The Animal and Plant Health Inspection Service of the United States
>  Department of Agriculture wishes to inform you that we have published a
>  proposed revision to the Bee Regulations in the Federal Register for your
>  review and comment.
>
>  The docket was published in the Federal Register today, 19 August 2002.
>  The Federal Register notice (Docket No. 98-109-1) is available for public
>  comments through November 18, 2002.  I have included a pdf copy of the
>  notice below along with several other web addresses for sources of
>  information on this docket.
>
>  Public hearings will be held regarding this proposed rule on the following
>  dates and locations, consult the Federal Register notice for full details:
>  22 October 2002, Kailua-Kona, HI
>  24 October 2002, Fresno, CA
>  29 October 2002, Beltsville, MD
>
>  The proposed regulations would combine the existing honey bee regulations
>  (7 CFR 322) and the "pollinator regulations" (7 CFR 319.76) [SNIP]

These regulations were troublesome in the past, in restricting the
importation of "dead bees of any genus" into the US (unless they came
from Canada).

I've checked the PDF file of the revised regulations - pdf and txt
copies can be downloaded at:

http://www.aphis.usda.gov/ppd/rad/webrepor.html - a direct link is

http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=2002_register&docid=fr19au02-26.pdf

and noticed on pp. 11, 24 and 25, that "dead bees of any genus" are
STILL considered "restricted articles" - while a *few* of the
importation provisions (in particular, the usual requirement for an
export certificate) are relaxed for pinned specimens or those in
alcohol, a package containing ANY dead bees of any genus would
*still* require:

(1) importation *only* at a port of entry staffed by an APHIS inspector
(2) 10-day advance notification of APHIS prior to its arrival,
including data on the sender, recipient, and description of contents
(3) very explicit forms of labeling on the package ("black letters at
least 1 inch in height on a white background") stating that it
contains dead bees
(4) a complete invoice attached
(5) any such package is subject to inspection when it arrives, and
may be held until inspected
(6) if you enter a US airport or border crossing traveling with dead
bees you MUST declare them to an APHIS inspector there

This is UNACCEPTABLE. The purpose of these restrictions is stated as
necessary to "ensure that exotic bee diseases and parasites are not
introduced through the importation of dead bees" - but they present
absolutely NO evidence that scientific specimens might actually
transmit exotic bee diseases and parasites - anyone with knowledge of
bees and their diseases would recognize the extreme unlikelihood of
such a thing. The lack of any consultation with bee researchers in
this particular matter is also evident in their stating that "bees"
are defined as "any member of the Superfamily Apoidea" - which also
includes all Sphecid wasps! Therefore, any person or institution in
the US which receives a shipment containing any dead bees or sphecid
wasps (meaning, for instance, any museum receiving malaise trap
samples from abroad, or any collector returning to the US with any
dead bees or sphecids) will be *technically* in violation of USDA
regulations if they do not comply with the requirements above. Sure,
it's nice that they waived the permit requirement, but the remaining
requirements are still unacceptable *and* unnecessary, and we need to
be granted exemption from them. There is already a Customs
declaration on every such package that states "Dead, preserved
insects for scientific study" - THAT should be enough.

Each and every one of us who works with insect specimens needs to
send a comment explaining that scientific specimens do NOT pose a
*realistic* threat for introducing diseases and parasites, and that
dead bees intended for scientific purposes must NOT be classified as
"restricted articles" in the final draft of the regulations. Note
that we need to *specifically* request the *EXEMPTION* of dead bees
from such classification, because only if they are exempt will they
no longer be subject to search and seizure by inspectors, etc., as
listed above. This is especially important as it affects the shipment
of type specimens; there is obviously no justification for a USDA
inspector to tear open a carefully packed 19th-century holotype,
inspect it, and then try to re-pack it, risking damage to the
irreplaceable and fragile specimen. They should not even be given
that *prerogative*, regardless of whether or not they choose to
exercise it. Dead insects are the province of the USFWS, if anyone,
not the USDA.

You can send comments by e-mail to regulations at aphis.usda.gov;
comments *must* be in the body of text (no attached files), with your
name and address in the text, and "Docket # 98-109-1" *must* be in
the SUBJECT line. The deadline is mid-November, but the more comments
they receive NOW, the better our chances of making someone realize
they need to draft more realistic rules before committing to this.

PLEASE take the time to do this.

ARGH!




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