Subject: Re: Importing herbarium specimens

[Joseph H. Kirkbride, Jr.]

From: Sally Shelton [Shelton.Sally at NMNH.SI.EDU]
Sent: Thursday, May 23, 2002 1:29 PM
To: PERMIT-L at SIVM.SI.EDU
Subject: Re: Importing herbarium specimens

From: Don <capnodium at yahoo.com>

Thank you Ms. Lehtonen for the rendition of APHIS
expectations on the importation of herbarium specimens.

These comments could be an excellent basis for further
clarification and modification of the regulatory viewpoint
to the benefit of both the Federal and State rule makers and
the targeted importer of herbarium specimens.

Some items are especially outstanding.

1. There needs to be a clear definition of "herbarium
specimen."

I presume that the specimen regarded as a herbarium
specimen for curation in a professional manner is totally
dead.

Most of the herbarium specimens I import are tentatively
identified at least to order, maybe family. I deliberately
go to foreign field areas to collect material that would be
new and unknown as well as that to serve as variants on
known species.

APHIS personnel have asked me the temperature of the field
drier heat source, how long I dried them,  how do I know
they are dead. All valid parameters in the consideration of
a definition for the herbarium specimen. Essentially this
process is largely intuitive, and has no definition. Is a
regulatory rule and check list and "decision tree" needed
for this longing standing item in the history of Botanical
science?

2. The most serious issue is the implication of herbarium
specimen illegality because the import permit dates have
expired. I daresay that many herbaria, large and small, will
be decimated if the imported herbarium specimens holdings
were seized, and likely destroyed, simply because the dates
for the import permit had long been passed.

The likely prevailing understanding is that the permit
dates are for the window of import, rather than intended to
dictate the length of time a specimen could be kept.

There needs to be a box to tick on whatever forms are to be
required to clearly indicate that the permit is in effect
"in perpetuity" if the permit is other than a device for the
specific act of bringing in the specimen from abroad.

Herbaria are in the business of collecting, preserving and
curating as well as interpreting the inherent data from
herbarium specimens. Why would any herbarium curate a
specimen that it would not initially intend to keep forever
(with exceptions of course for exchanges, etc.)

Seizure of herbarium specimens in the name of expired APHIS
permits should be regarded as a new form of bioterrorism!

Don R. Reynolds
dreynold at nhm.org