CBP provides Outreach Training to Researchers and EHS Professionals
I attended an excellent presentation by Mary Braswell, Supervisory Agriculture Operations Manager, with US Customs and Border Protection (CBP).
She and her team were in Richardson at UT Dallas on August 18th to conduct outreach training and bring awareness to research staff, students and EHS professionals on CBP regulations regarding importing and exporting biologic materials. Shane Solis, Director – Research, Campus and Environmental Safety at UT Dallas organized the virtual and onsite event.
CBP is tasked with enforcement of regulations of biological materials that have been established by a multiple of other governmental agencies, such as the DOT, EPA, CDC, USDA, and Fish and Wildlife.
According to Ms. Braswell there has been a recent spike to the number of interception and seizure activities of undeclared biological materials both being imported and exported out of the US, many by the air passengers themselves.
How could that impact us? Not only have biological materials been used by terrorists, but inadvertent releases of biological agents have resulted in illness or death in animals, plants and even humans. There are many reports of non-intentional release of non-native species, now considered invasive, causing environmental damage to an ecosystem.
Here’s a short list of biological materials regulated by CBP:
- Anti-serum, anti-venom, anti-toxins
- Bacterins (killed or weakened bacteria for use as a vaccine.)
- Blood, plasma, blood cells, clotting factors
- Cell or tissue cultures; and cell/tissue culture products (includes enzymes, other proteins, extracts, nucleic acids [DNA/RNA]).
- Fetal Bovine Serum (FBS), other sera, Bovine Serum Albumin (BSA), enzymes, hormones
- Histopathological slides (fixed in formalin).
- Microorganisms (includes recombinant or non-recombinant, bacteria, fungi, yeast, protozoa, viruses, prions), live or killed; and, products of microorganisms (includes plasmids, nucleic acids (DNA/RNA), toxins, enzymes, recombinant human insulin, other proteins and extracts).
- Peptides
- Polyclonal antibodies
- Test kits
- Tissue/organ extracts and samples
- Toxoids
- Unused culture media
- Urine, feces, saliva
- Vaccines
- Materials collected from endangered species
When asked, what was the most common issue for Universities? Ms. Braswell stated, biologicals that were, “not declared,” and noted that undergraduate students in particular have been a source of the recent increase in numbers. Presumably because of the lack of knowledge or awareness of the regulations or the risks.
“The best advice…,” she said, “declare what you’re bringing in.”
Bottom line, biological materials being imported or exported must be declared to the CBP. Failure to do so can results in delays, penalties, criminal prosecution and seizure or loss of the biological materials.
So which regulations apply?
Here are some of the important links she provided:
- https://www.cbp.gov/trade/basic-import-export/what-you-need-know-importing-biological-materials-united-states At the bottom of this webpage are 8 additional links to specific agengies with jursidiction depending on that biological material.
- Tips for New Importers and Exporters https://www.cbp.gov/trade/basic-import-export/importer-exporter-tips
- Planning a trip abroad? “Know before you go” https://www.cbp.gov/travel/us-citizens/know-before-you-go
I would like to thank Ms. Braswell and her team for coming out and informing us about these important regulations affecting researchers and students.
Questions? Contact Mary Braswell at [email protected] 713-387-7256 or her colleague, Richard Karstom at [email protected] at 713-387-7259.