USDA / USFW Insect Permits

[Bruce Walsh]

My major concern with the extremely broad sweep as currently seems to be
interpreted by USDA is that ANYTHING that is alive falls under this
definition.

The issue here is RISK caused by accidental or deliborate release of
butterflies and moths to crops and/or native species of plants.

The simple question begs.  The classic examples of such risk are from
individuals who had large breeding colonies or made deliberate introductions.

Are there ANY cases where the sort of route exchange that goes on between
collectors wherein individuals receive live material for rearing with all
adults killed for a collection (i.e., no reproduction of adults) has
caused ANY problem?  If not, I would argue that to avoid flooding poor Wayne's
office with permits that a blanket policy dealing with these sort of very
small exchanges be established and be easy to apply for.  Once again, if
the issue if REDUCTION OF RISK, the case is obvious.  If the issue is
regulation for regulations sake, support will be poor at best.  A clear policy
for dealing this the very small exchanges that routinely occur would go a
very long way towards a very broad-based support for the wider policy.

Again, I remark that biosafety committees around the country have routine
polices for dealing with routine recombinant DNA issues (such as PCR
reactions) to allow them to focus on more serious issues (i.e. BL-2 cases).

Cheers

Bruce