[NHCOLL-L:3406] FW: PCR product and USFWS 3-177

Mon Apr 23 09:34:15 EDT 2007

Forwarded message from Ellen Paul concerning my query about USFWS and PCR product.  I thought it might be of interest to the group.

Andy

   A  :             A  :             A  :
}<(((_°>.,.,.,.}<(((_°>.,.,.,.}<)))_°>
   V                V                V
Andy Bentley
Ichthyology Collection Manager/Specify Usability Lead
University of Kansas
Natural History Museum & Biodiversity Research Center
Dyche Hall
1345 Jayhawk Boulevard
Lawrence, KS, 66045-7561
USA

Tel: (785) 864-3863
Fax: (785) 864-5335
Email: ABentley at ku.edu       

   A  :             A  :             A  :
}<(((_°>.,.,.,.}<(((_°>.,.,.,.}<)))_°>
   V                V                V 

________________________________

From: Scientific Permits issues [mailto:PERMIT-L at SI-LISTSERV.SI.EDU] On Behalf Of Ellen Paul
Sent: Sunday, April 22, 2007 7:04 AM
To: PERMIT-L at SI-LISTSERV.SI.EDU
Subject: PCR product and USFWS 3-177

Sorry - I meant to answer this and just got distracted and never got back to it....please post to NHCOLL for me as I'm not on that list....

The proposed revisions to the CITES regulations (proposed 19 April 2006) say:

Urine, feces, and synthetically derived DNA (section 23.16): We
propose that the international trade of these specimens be exempt from
CITES requirements under certain circumstances. We consider samples of
urine and feces to be wildlife byproducts, rather than parts, products,
or derivatives. We differentiate between DNA extracted directly from
blood or tissue samples and synthetically derived DNA. DNA extracted
directly from blood and tissue samples must comply with all CITES
permitting requirements. At CoP8, the Parties rejected Denmark's draft
resolution to exempt blood and tissue samples to be used for DNA
studies. The Parties agreed that such tissues should not be exempt from
CITES controls.

The proposed regulation never uses the term "PCR product" - which would have been preferable in terms of clarity and certainty, but as Carla states, the USFWS position is that PCR product contains essentially no original DNA. 

Note that these proposed revisions are just that - proposed. It can take a year or more for regulatory revisions to get through the final approval process. In fact, the last time the USFWS tried to revise these regs, they sat in the approval process for so long that they became outdated and the USFWS had to start all over again.

To clarify about the USDA regulating PCR product - again, Carla is right. They do (for PCR derived from birds and the mammal species that they regulate). However, the PCR process meets the treatment standards so while you need a permit (you always need the permit), it doesn't have to be re-treated and doesn't have to be imported into a BSL2 lab.

Ellen

-- 
Ellen Paul 
Executive Director 
The Ornithological Council 
Mailto:ellen.paul at verizon.net 
"Providing Scientific Information about Birds"
Ornithological Council: http://www.nmnh.si.edu/BIRDNET

Bentley, Andrew Charles wrote: 

Ellen

Any comment??

Thanks

Andy

   A  :             A  :             A  :
}<(((_°>.,.,.,.}<(((_°>.,.,.,.}<)))_°>
   V                V                V
Andy Bentley
Ichthyology Collection Manager/Specify Usability Lead
University of Kansas
Natural History Museum & Biodiversity Research Center
Dyche Hall
1345 Jayhawk Boulevard
Lawrence, KS, 66045-7561
USA

Tel: (785) 864-3863
Fax: (785) 864-5335
Email: ABentley at ku.edu       

   A  :             A  :             A  :
}<(((_°>.,.,.,.}<(((_°>.,.,.,.}<)))_°>
   V                V                V 

________________________________

From: Scientific Permits issues [mailto:PERMIT-L at SI-LISTSERV.SI.EDU] On Behalf Of Carla Cicero
Sent: Monday, April 16, 2007 10:46 PM
To: PERMIT-L at SI-LISTSERV.SI.EDU
Subject: Re: [NHCOLL-L:3379] PCR product and USFWS 3-177

Hi Andy - My understanding is that PCR products are NOT regulated by USFWS for import/export, although DNA extracts are. The situation is different with USDA, which does regulate PCR products. I'm copying this to permit-L in case the story is different. But we specifically asked this question to USDA and USFWS at a permits workshop at the American Ornithologists' Union meeting a couple of years ago. Ellen may have more to add. 

Best,
Carla

On 4/11/07, Bentley, Andrew Charles <abentley at ku.edu> wrote:

Hi all

Has anyone had any experience filling out 3-177's with regard to PCR product?  Is PCR product considered "a part thereof" as stated in the regulations or is this considered to be non-biological material that is not covered by 3-177 regulations?

The other scenario is that USFWS has just not encountered this yet and as such it is not explicitly stated in the regulations.

Any ideas or help would be appreciated.

Thanks

Andy

   A  :             A  :             A  :
}<(((_°>.,.,.,.}<(((_°>.,.,.,.}<)))_°>
   V                V                V
Andy Bentley
Ichthyology Collection Manager/Specify Usability Lead
University of Kansas
Natural History Museum & Biodiversity Research Center
Dyche Hall
1345 Jayhawk Boulevard
Lawrence, KS , 66045-7561
USA

Tel: (785) 864-3863
Fax: (785) 864-5335
Email: ABentley at ku.edu       

   A  :             A  :             A  :
}<(((_°>.,.,.,.}<(((_°>.,.,.,.}<)))_°>
   V                V                V 

-- 
Carla Cicero, Ph.D
Staff Curator of Birds and Genetic Resources
Museum of Vertebrate Zoology
3101 Valley Life Sciences Building
University of California
Berkeley, CA 94720-3160 
TEL: (510) 642-7868
FAX: (510) 643-8238

http://mvz.berkeley.edu/
http://socrates.berkeley.edu/~ccicero/ <http://socrates.berkeley.edu/%7Eccicero/> 
http://ornisnet.org/ 

<http://www.nmnh.si.edu/BIRDNET> 

-------------- next part --------------
An HTML attachment was scrubbed...
URL: http://mailman.yale.edu/mailman/private/nhcoll-l/attachments/20070423/95573dbd/attachment.html 