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I had a lengthy meeting with the Veterinary Services staff to go
over an accumulated list of issues; afterwards I wrote up the notes
and they were kind enough to double-check it for accuracy. There's
quite a bit here so you may want to take some time to read it
carefully.<br>
<br>
Note the change in the name - it is no longer National Center for
Import/Export. It is now National Import Export Services. The main
phone number is still <span style="font-size:11.0pt;
font-family:"Calibri","sans-serif";
color:#1F497D"> </span>(301) 851-3300, but it is now option 1
instead of option 5.
<p class="MsoNormal">Let me know if you have any questions about any
of the information reported below. <br>
</p>
<p class="MsoNormal">Ellen <span style="font-size:11.0pt;
font-family:"Calibri","sans-serif";
color:#1F497D"><br>
</span></p>
<pre class="moz-signature" cols="72">--
Ellen Paul
Executive Director
The Ornithological Council
Email: <a class="moz-txt-link-abbreviated" href="mailto:ellen.paul@verizon.net">ellen.paul@verizon.net</a>
Phone (301) 986 8568
"Providing Scientific Information about Birds<a class="moz-txt-link-rfc2396E" href="http://www.nmnh.si.edu/BIRDNET">"
http://www.nmnh.si.edu/BIRDNET"</a>
</pre>
<font size="+1"><b>Upcoming changes to your APHIS Veterinary
Services Import Permits (VS16-3 permits) and import practices</b></font><br>
<br>
<u>Imports from the European Union</u><br>
<br>
On 15 April 2013, the European Poultry Trade Region was declared
free of both Exotic Newcastle Disease and highly pathogenic avian
influenza.
<p>The rule recognized 25 countries in this PTR as free of Newcastle
disease and highly pathogenic avian influenza (HPAI). The rule
also recognizes the ability of these countries to take appropriate
restrictive actions on a zoned basis in the event of any outbreaks
of these diseases. </p>
<p>The EU-25 PTR countries are as follows: </p>
<p class="MsoNormal">Austria<br>
Belgium<br>
Cyprus<br>
Czech Republic<br>
Denmark <br>
Estonia<br>
Finland<br>
France<br>
Germany<br>
Greece<br>
Hungary<br>
Ireland<br>
Italy<br>
Latvia<br>
Lithuania<br>
Luxembourg<br>
Malta<br>
The Netherlands<br>
Poland<br>
Portugal<br>
Slovakia<br>
Slovenia<br>
Spain<br>
Sweden <br>
United Kingdom (England, Scotland, Wales, Isle of Man, and
Northern Ireland). </p>
<p>The Ornithological Council initially thought that this meant that
imports of avian research material from these countries would not
have to be treated prior to import. We soon learned, however, that
this rule applies only to imports of poultry and commercial bird
products. It does not apply to the import of research materials.</p>
<p>After discussion with the USDA APHIS Veterinary Services staff,
the Ornithological Council has learned that APHIS had no choice
but to make this distinction because the exemption for the poultry
and commercial bird products is based upon the continued
inspection, detection, and self-certification efforts that these
countries undertake in order to assure that their producers can
sell these products across country borders. This commercial
interest assures that the countries will make adequate efforts to
detect
outbreaks of highly pathogenic avian influenza<span
style="color:#1F497D">
</span>and exotic Newcastle disease and quarantine commercial
birds/poultry and their products in zones affected by these
diseases. No such
quarantine<span style="color:#1F497D">
</span>system is in place for wild birds. </p>
<p>However, the Veterinary Services staff realizes that because
import of research material from these countries was, before the
issuance of this April 2013 rule, regarded as HPAI-free for the
purposes of import of research material, it is appropriate to
continue to allow labs certified by the USDA* as at least
Biosafety Level 2 to import untreated material from these
countries. If you work with untreated material from these
countries, you must wear disposable PPE (personal protective
equipment) to avoid inadvertent escape of pathogens from the lab.
The disposable clothing must be removed before leaving the lab and
must be regarded as contaminated waste and placed in a durable,
leak-proof container after use. For further information about the
use and disposal of PPE, see the
<a href="http://www.cdc.gov/biosafety/publications/bmbl5/">Biosafety
in Microbiological and Biomedical Laboratories (5th Edition)</a>.
Follow BMBL procedures for decontaminating surfaces and equipment
where untreated material was handled or stored.
</p>
<p>If avian material is being imported from any country or region
that is affected by HPAI other than these 25 countries, the
material will have to be treated prior to import, even if yours is
a USDA-certified BSL2 lab.
</p>
<p>There are nine countries/regions that have been certified as free
of both END and HPAI; these restrictions will not apply to imports
from these nine countries.</p>
<p>Australia (except New South Wales)<br>
Argentina<br>
Canada<br>
Chile<br>
Costa Rica<br>
Fiji<br>
Iceland<br>
New Zealand<br>
Switzerland</p>
<p>Labs that are not certified as at least Biosafety Level 2 will be
required to treat imports from these countries prior to import
(even if the country has been declared free of Exotic Newcastle
Disease).
</p>
<p>*NOTE: Many universities are now requiring that labs maintain
BSL2 standards and the risk management committees of these
universities are inspecting labs to assure that the labs meet
these standards. However, for the purpose of import permits, this
is not legally sufficient. Your lab must be inspected by the USDA
once every three years if you want to import under BSL2
conditions.
</p>
<p>REMEMBER! A COUNTRY'S DISEASE STATUS CAN CHANGE AT ANY TIME. IT
CAN CHANGE AFTER YOU RECEIVE YOUR PERMIT! BE SURE TO CHECK THE
USDA APHIS COUNTRY DISEASE STATUS WEBSITE BEFORE YOU IMPORT:
<a
href="http://www.aphis.usda.gov/import_export/animals/animal_disease_status.shtml">http://www.aphis.usda.gov/import_export/animals/animal_disease_status.shtml</a></p>
<p>The approved treatment methods are as follows:</p>
<p>Heat to at least 100° C for at least 20 minutes <br>
Heat to at least 60° C for at least 30 minutes <br>
Heat to at least 56° C for at least 3 hours <br>
Immerse in 10% formalin/phenol or 10% formalin<br>
Immerse in 3% solution beta-Propiolactone for at least 30 minutes
<br>
Immerse in 2 % solution sodium dodecyl sulfate for at least 30
minutes
<br>
Immerse in phenol/chloroform (no solution strength specified;
material should remain immersed throughout import and until it
arrives at the institution)
<br>
Treat with Proteinase K<br>
Immerse in a minimum of 70% alcohol (material should remain
immersed throughout import and until it arrives at the
institution)
<br>
Affinity chromatography <br>
FTA cards (not suitable for feathers)<br>
4M guanidine hydrochloride<br>
10% Formalin-fixed slides<span style="color:#1F497D"> <span
style="background:yellow">
</span></span><b>– no permit required now</b></p>
<p>Approval pending: methanol-fixed slides</p>
<p>The Veterinary Services office will implement these changes
through permit conditions. Please contact the Ornithological
Council if you have any questions or if you would like assistance
in determining the appropriate wording for your permit requests.
</p>
<p class="MsoNormal" style="margin-bottom:12.0pt"><br>
<i>Pro forma invoices<br>
<br>
</i>Until now, your APHIS permits have required you to submit a
pro forma invoice listing the contents of your import. When your
permits are renewed, they will include a condition that states
that you may use a USFWS 3-177 in lieu of a pro forma invoice.
Remember - if you are importing anything that requires a USFWS
permit (Lacey Act, Migratory Bird Treaty Act, Endangered Species
Act, Marine Mammal Protection Act, CITES, Wild Bird Conservation
Act, or Bald and Golden Eagle Protection Act) you are required to
submit a 3-177 at the time of import. For import of "dead,
preserved, dried, or embedded scientific specimens or parts
thereof, imported by accredited scientists or accredited
scientific institutions for taxonomic or systematic research
purposes:" for which no USFWS permit is required, you may file the
3-177 after import but no more than 180 days after import.
<span style="font-size:10.0pt;
font-family:"Arial","sans-serif""><br>
<br>
</span></p>
<div>
<p class="MsoNormal"><i>"Split" import permits</i><br>
<br>
Last year, Veterinary Services began the practice of splitting
BSL2 permits into two separate permits - one for material that
must be treated prior to import (i.e., any country or region
affected by HPAI) and a second for material that could be
imported into a BSL2 lab without treatment prior to import
(i.e., any country or region not affected by HPAI). After an
initial phase-in, Veterinary Services began to double the fee to
reflect the fact that two separate permits were being issued.
The Ornithological Council requested that Veterinary Services
reconsider this decision but as the permits are now becoming
even more complex, it is more time-consuming to issue the
permits and the additional fee is necessary. Therefore, import
permit applications that result in the need to issue two
separate permits will entail a doubled fee. <br>
<br>
<i>Small mammals<br>
<br>
</i>In the past, Veterinary Services has included small mammals
on the avian import permits despite the fact that APHIS
currently regulates only ruminants, equids, swine,
hedgehogs, brushtail possums,
and tenrecs (to prevent the introduction of Foot-and-Mouth
Disease, Classical Swine Fever, Swine Vesicular Disease, African
Swine Fever, and African Horse Sickness).<br>
<br>
The term used by APHIS to cover all other mammalian material is
"small mammals." <br>
<br>
The avian import permits included small mammals as a means of
facilitating the process at the port; the Agricultural Quality
Inspectors who must inspect hundreds of different animal and
plant products are instructed to follow the permit rather than
searching enormous manuals for the appropriate restrictions or
lack thereof. <br>
<br>
However, given the increasing complexity of the avian permits,
APHIS will no longer include small mammals on these permits.
Instead, APHIS will issue a letter along with the avian import
permit stating that imports of mammalian products other than
ruminants, equids, swine, hedgehogs, brushtail possums, and
tenrecs is not restricted. Carry that letter with you, along
with your permit, if you are importing "small mammals."</p>
</div>
Carry this letter with you or attach it to the package when you
ship; be sure to include a pro forma invoice that identifies the
material. This pro forma invoice must be written in English. In the
future, your permit will allow you to use the USFWS 3-177 in lieu of
this pro forma invoice. Remember - if you are importing anything
that requires a USFWS permit (Lacey Act, Migratory Bird Treaty Act,
Endangered Species Act, Marine Mammal Protection Act, CITES, Wild
Bird Conservation Act, or Bald and Golden Eagle Protection Act) you
are required to submit a 3-177 at the time of import. For import of
"dead, preserved, dried, or embedded scientific specimens or parts
thereof, imported by accredited scientists or accredited scientific
institutions for taxonomic or systematic research purposes:" for
which no USFWS permit is required, you may file the 3-177 after
import but no more than 180 days after import.
<div>
<p class="MsoNormal"><br>
<i>Direct-to-USDA-certified lab<br>
<br>
</i>Not new, just a reminder - if you or someone on your behalf
is carrying untreated materials into the country, the materials
must go directly to your lab after import. So, for instance, if
a colleague at another institution or one of your former grad
students is using your permit (with your permission, as
demonstrated by written permission on university letterhead,
signed by you, in blue ink) to bring in untreated material, they
must bring that material directly to your lab. They can't take
it to their home institution and then send it to you or drive to
your lab. The import permit requires that untreated material go
directly to your lab after import.
<br>
<br>
If they happen to have a permit that allows them to import
untreated material AND a transport permit, they can take the
material to their lab using their import permit and then
transport it to you under their transport permit. Otherwise, the
material will have to come directly to your lab once it has been
cleared at the port. </p>
</div>
<p class="MsoNormal"> </p>
<br>
<br>
<p class="MsoNormal"><span style="font-size:11.0pt;
font-family:"Calibri","sans-serif";
color:#1F497D"> </span></p>
<pre class="moz-signature" cols="72">
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