Mind Your PPQs

Despite the skeptics, the Cincinnati Zoo’s World of the Insect proved to be an enormous hit with zoo visitors, providing an entirely new look at the creatures that make up the smaller majority of animal life on earth.  To this day, however, insectariums aren’t a regular fixture at many zoos.  Where they are present, they tend to feature a very limited cast of characters, with the same few species being seen in almost every collection.  So what gives?

A major obstacle that any zoo that wishes to display insects must overcome is the permitting.  Housing almost any species of plant-eating invertebrate – insects, millipedes, snails and slugs among them – requires a Plant Protection and Quarantine (PPQ) Permit 526.  This permit, issued by the United States Department of Agriculture, is required for the importation or interstate movement of any species which has the potential to become an agricultural pest should it escape from human care.  That consists of… well, almost everything with six legs.  It also refers to viruses, bacteria, fungi, and parasitic plants, but in the confines of the zoo, it usually is associated with invertebrates.

To secure this permit, a zoo must demonstrate, through elaborate paperwork, how they intend to house and care for their invertebrates in a manner that insures that they will not get loose and wreck ecological or agricultural havoc.  Visit a zoo insectarium and you’re likely to notice double doors, meant to reduce the likelihood of a wayward pest getting out.  Deceased animals, bedding from the enclosures, and old furniture must often be incinerated, flash frozen, or otherwise sterilized to make sure no unnoticed eggs hatch out in the dumpster behind the building.  Site inspections will be carried out after the pest species has arrived to make sure that the SOPs detailed in your application are being followed.  Careful inventories must be maintained to make sure that all pests are properly accounted for.

The species that are not regulated by PPQ permits are animals that don’t eat plants.  That includes spiders, scorpions, and centipedes (though some species, such as certain mantises, are restricted as potential threats to pollinating insects).  I suspect that this is a big part of the reason why many zoo “insect” collections feature such a diverse array of tarantulas and other invertebrates that can be transported freely without the need for these permits.  

 A handful of other species do not require these permits, perhaps because they are already abundant in the US and the risk they pose to agriculture is low.  An example of this is the Madagascar hissing cockroach, probably the most commonly kept insect animal ambassador for zoo education programs.  Insects like the MHC are the exception, rather than the rule, though.  With so many invertebrate species and so little known about the potential impacts that most would have of the environment or on agriculture, the USDA seems to feel that blanket positions are safer.

This is all on the federal level, of course.  As with all things animal related in America, there is a whole separate level of state regulations to navigate as well (here, for example, are guidelines from Florida).  Some states have draconian restrictions that ban keeping almost anything.  Others are the Wild West, where everything goes.

I will admit that this is pretty strict enforcement… on paper.  In my less careful days, I happily bought insects and other invertebrates for the small, private zoo I worked for, with neither the owner nor I being the least bit aware that we needed permits for some of the species I bought.  Our regular USDA inspector never even went into the building that they were housed in during her inspections, nor did we think it necessary or even relevant to mention them.  I only heard about these permits when I requested a few Australian walking sticks from an AZA zoo years later and they inquired as to the status of the PPQ 526 permit.

A year or two ago, I remember visiting the Albuquerque BioPark Aquarium and Botanic Garden, and being delighted by the excellent insectarium in the later.  It was filled with an exciting collection of arthropods from around the world, including many species I had never seen before.  This was after my escapades with the walking sticks, and I knew then how regulated the transport of many of these species was.  As I exited the building, I remember thinking that this might have been the first animal exhibit I had ever seen where all of the associated paperwork and permits would have weighed more than any of the animals themselves.