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Marine Turtle Newsletter 58:5-6, © 1992

Guest Editorial: CITES and Scientists-Conservation in Conflict

Brian Bowen
Department of Genetics, University of Georgia, Athens, Georgia 30602 USA

At the 1992 CITES Meeting in Kyoto, Japan, Denmark introduced a resolution to exempt DNA and small volumes of blood (<2 ml) from CITES regulations. The rationale behind this petition was that DNA and small blood aliquots have no commercial value but considerable scientific worth. The proposal was opposed by the United States, Canada, Switzerland, and New Zealand. This petition (and its subsequent defeat) opens several issues which merit deliberation by the conservation community. The Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) was formulated to eliminate international commerce in endangered species and related products. Toward this end, the Convention has been an unprecedented success. International trade restrictions largely eliminate the profit incentive for exploitation. However, international transport of endangered species or their parts is still necessary for conservation-oriented research. Convention authors were aware of this and provided routes of access for legitimate scientific investigation. For the past six years I have been involved in a population genetic survey of marine turtles. During this time our team has worked with scientific permit offices in some 20 nations. Responses to our permit applications have ranged from routine processing to complete silence. With this background, I would like to explore the pros and cons of regulating international traffic in DNA and blood samples.

Jurisdiction: The strongest argument for regulating DNA and blood samples is to protect endangered taxa from injurious sampling. While there is no commercial incentive for removing blood and DNA samples, this activity is not exempt from conservation concerns. In some cases, removing blood or tissue samples could traumatize or even kill the organism. Therefore, it seems prudent that this activity be regulated. Happily, virtually every nation has regulations controlling scientific access to species classified as endangered. In other words, management authorities decide whether scientific collections are justified long before those specimens enter the international arena. Thus, the potentially injurious aspect of this activity (i.e., the collection of blood or tissue) is not conducted under CITES international jurisdiction. CITES regulations are not intended to dictate scientific permit policies within member nations.

Enforcement: Without identification procedures, restrictions on DNA and blood samples are difficult to enforce. Would wildlife inspectors be expected to sequence DNA or proteins to identify endangered species material? In the specific case of DNA samples, even more complex problems exist. Polymerase Chain Reaction (PCR) methodology allows one to make millions of copies of a desired DNA sequence with minimal lab facilities, and it is impossible to distinguish between the "real" DNA and the derived "imitation". The only possible enforcement strategy would be to regulate all international transport of DNA as "look-alike" products. This would be an unwieldy approach but, even if enforcement were possible, the real question is-to what end? The only group prosecuted for this type of "smuggling" would be biologists working on endangered species. An adversarial approach to endangered species research could hardly be called a victory for conservation.

Scientific value: The current methodology allows many aspects of life history to be inferred from small tissue samples. With a few grams of blood or other tissue one can define population structure, reconstruct migratory patterns, document mating behavior, and resolve subtle aspects of social structure. The conservation value of such life history information is beyond price, while the commercial value of the "biological microfilm" is negligible. To restrict movement of DNA and blood samples serves only to reduce the flow of scientific information.

Reasonable access: If CITES permits were readily available to scientists, exemptions for DNA and small volumes of blood would not be necessary. In the current environment, however, exemptions are necessary. While many nations encourage conservation-oriented research, it is widely acknowledged that some permit offices are not receptive to scientific applications. Since smugglers do not apply for permits, denying permits to scientists is the most obvious way to demonstrate an active permit program. By routinely delaying or rejecting permit applications from biologists, these offices are ultimately damaging the conservation goals there were created to serve.

With these issues in mind, I urge the representatives of member nations to exempt DNA and small blood samples from CITES regulations. More importantly, CITES signatory nations need to recognize their obligation to provide reasonable access for biological research. CITES was never intended to obstruct conservation biology.