Some unsolicited advice on import permits for primatologists -- and a short story

By Liz Tapanes

the author of this post working with sample in a lab
July 22, 2019

During the summer of 2018, I boarded a plane and headed off to Madagascar for the second time. I was excited because this was going to be my “big year" for sample collection.  I planned to bring back the bulk of samples I wanted to use in my dissertation. During that ~20 hour journey, I read a short book called The Feather Thief, which chronicles the theft of bird skins collected by Alfred Russell Wallace from the Trig Museum. It's half mystery and half non-fiction, but importantly, it helped me develop an appreciation for the C.I.T.E.S. treaty (Convention on International Trade in Endangered Species).

Specifically, C.I.T.E.S. protects endangered plants and animals –by ensuring that international trade and collection of biological specimens doesn’t threaten the survival of the species in the wild. It protects ~35,000 species, including the diademed sifaka, which I study. The U.S. Fish & Wildlife Service (Department of the Interior) overseas research/science permits for animals protected under C.I.T.E.S in the USA.

I collected 300+ biological samples from sifaka lemurs last summer, but they never left Madagascar. In short, the import permits weren't secured in time. I left the samples behind and awaited the process of gaining sample import permits from U.S. Fish & Wildlife. Many told me I was 'attempting the impossible' and that I wouldn't see the samples for years. (As an aside: the permits office is currently very understaffed - thank you, current administration). I cried often, but I sent in my application (in October 2018) while restructuring my dissertation - I was set to propose in December.

Ultimately though, it is my project, and it is my fault that the permits did not come through in time. Despite the difficulties of working with endangered primates, I mostly and usually feel only privilege and appreciation for working with these animals. As it turns out, I settled on a dissertation I loved even more than the first, and one that is more important for the primate population.

I am shortening a very long story, but my permits for importation arrived in the mail a few days ago, on July 13th, 2019 – a nine-month turn around time. I will not use the samples for my dissertation, but I and my colleagues will use them in future work. During the waiting process, I had time to think about permits, and below is some advice on the ethics and technicalities of import permits that I have accumulated. While I admit that it is highly biased based on my experiences, I hope it can be helpful to others.

I. Advice for planning to collect and export/import samples – the ethics behind the science

  1. Ensure that you apply early for any necessary permits, this includes (but is not limited to): sample collection, sample export, and sample import. By early (for import), I mean at least a year before you will need access to the samples. For export, ask others who typically export samples out of the relevant country how much time is needed to apply.
    • Making sure you have all the necessary permits to move samples you collect is your responsibility – not anyone else’s.
  2. Ensure that you are aware of current laws and regulations for obtaining export (from the primate range country you work in) and import permits (to your country of residence).
    • Being informed of the current laws is your responsibility, not your collaborators. Currently, you need U.S.F.W.S./C.I.T.E.S. permits for anything that is not urine or feces. Other non-C.I.T.E.S permits (e.g. CDC) might be required as well, depending on species and sample type.
  3. Verify that your methods of sample collection, storage, and transport are rigorous and maintain the integrity of your sample. Do this before going to the field and applying for permits.
    • Check local laboratories, universities, or N.G.O.'s for their availability and willingness to store samples for you if you need to wait for permit processing. Secure the monthly cost before you agree to storage. Store your samples in a buffer (when possible) that would preserve the DNA/RNA for weeks outside of ultra-cold or -20°C freezer conditions.
  4. Be prepared to encounter situations that challenge your moral compass, and know what you value before needing to justify yourself.
    • This is especially true when it comes to import/export permits. I have seen biologists import things without permits (i.e., leaves in their shoes), and I also received contradictory advice about the samples. I placed higher value in my long-term relationships with Madagascar and the U.S.F.W.S. more than I valued my immediate scientific needs.
  5. Be a role model in the local community where you work when you are collecting samples, and going through the process of export and import.
    • We cannot ask local people to value these animals and their forests if we cannot hold ourselves to these same standards. Our science isn’t more worthy than their livelihoods - if anything, it is less worthy.
  6. Think long-term when you are planning a research study, sample collection, and storage.
    • What conditions will preserve your samples best? How can you collect the most data and cause the least disturbance to the animals? Think beyond your study. Is there anything you can collect that may potentially have value to a future collaborator?

 

II. Advice on submitting a successful application for sample import – the logistics of faster turn-around times (maybe)

  1. Provide as many details as possible. They may seem insignificant to you, but they are not to U.S.F.W.S. Don't use acronyms. Explain buffers, methods, etc. Do not explain your statistical analysis. Think of this application as the hybrid baby of the N.S.F. and I.A.C.U.C. Justify everything. How many animals?  What will you use the samples for? How will you collect the samples specifically? Why do you need so many samples? How old are the animals?
  2. Collaborate with a local N.G.O., if and when you can. Many of us already do this if we work in primate range countries. Letters from these local N.G.O.'s stating they support your work in the forest may be helpful.  If you did not collect the samples yourself, provide a note that you have permission to import the samples from the entity that did.
  3. If C.I.T.E.S. protects your species, explicitly state multiple times how your work furthers the conservation of the species. (If your work does not further the preservation of the species, reconsider how you can collect more informative samples).
  4. Send an e-mail version of the hard copy application you mail to U.S.F.W.S. (this includes a PDF copy of the answered questions, and an excel document with all the sample details and totals).
  5. Provide fieldwork permits from the years from which your samples were collected detailing that the country allowed you to conduct this research these years.
  6. Communicate often with the biologist assigned to process your permit application. Don't get me wrong; don't e-mail them to waste their time. Generally, feel free to reach out to them if you have questions about where your permit is in the review process.
  7. Be very specific, and clear, about the number of samples, types of samples, and/or sizes of samples you will be importing.
  8. Be prepared to add amendments (or send them additional information while they process your application). Both set you back a few weeks here and there.
  9. Do ask to import samples from future years if you know you will collect again during the application phase. I applied in 2018 and included samples for 2019 in my application. Justify this in your application, especially if collecting again has any implications for conservation.
  10. Ask friends and collaborators to see their successful applications, especially if there is a successful application for your study site or related species. I was very grateful and privileged to have access to an application the Beza Mahafaly team in southwestern Madagascar put in (thanks to Dr. Richard Lawler). This made it easier for me to draft an application rather quickly and more efficiently the first time.
  11. Just submit it. The process is still partly a mystery to me, but you are one step closer once you are in the queue to being reviewed.