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

Phil Bunch pbunch at CTS.COM
Mon Aug 26 19:32:47 CDT 2002


Welcome to the wonderful world of regulations ;-)

Phil Bunch

On Monday, August 26, 2002 11:48, Doug Yanega [SMTP:dyanega at POP.UCR.EDU] wrote:
> 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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