# getting other feeders "approved" by APHIS and USDA



## Rain_Frog (Apr 27, 2004)

For those that ship live insects, has anyone been able to convince APHIS to approve G. assimilis and G. bimaculatus? What about bean weevils and roaches?

I am planning on starting an insect business and hearing about the deadly cricket virus, I would like to import some of these other species. I read on other forums that people that attempted to acquire other cricket species, but were shot down. One article about the virus stated that the USDA is looking into alternatives that could be approved. 

From reading and talking to a few people, APHIS has refused private trade approval for most of our feeder roaches, especially blaptica dubia-- so private trade of this species goes on illegally underground, but unenforced. That doesn't mean they could "sting us" at some point.

Is there any organization I could write to for convincing the government to start approving other types of feeders? I strongly support the Florida bans on tropical roaches and why they would be stringent, and I have the same ethical concerns for other states like AZ, CA, and TX. But to colder regions like where I live? I'm curious how many herpers actually have a colony of roaches going (as well as the various online stores selling them).


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## Rain_Frog (Apr 27, 2004)

Today I had an interesting conversation with the Kansas State Plant Department.

I called the USDA’s Plant Protection and Quarantine’s Pest Permit Evaluation, and they couldn't even answer what was restricted and what wasn't. So, they told me to call the KS State Plant Dept. 

The person on the phone was very nice. He told me that the State of KS has no issues with fruit flies. I also told him that APHIS says on their site that drosophila are not restricted unless they are being imported. He did tell me that I need the check with each state though just to see if there are restrictions-- unfortunately there isn't an easier way.

From a federal standpoint, the USDA has different requirements. But from a state standpoint he said, Kansas is not interested in most exotic insects except boll weevils. Other states he said don't care, but KS does. 

I told him about the situation with roaches in the reptile hobby. I kinda ranted a little bit about the private trade in feeder insects and the new cricket virus going around (pressuring private trade to find alternative feeders)-- he said he was unfamiliar with the situation with Blaptica dubia. I told him that many, many people in the reptile / amphibian trade are working with this species, but unfortunately, some responsible people have tried to apply for a permit but were denied. Meanwhile, everyone else keeps to themselves for fear of getting in trouble, but the government is also aware of it but doesn't even enforce it. He was aware of hissing roaches becuase he knew some people that kept them as pets.

I said that Florida has restriction on roaches, but in general, virtually everyone selling B. dubia is doing so "illegally" because of interstate transport laws. But in reality, with the exception of warmer places, they haven't become a nuisance and are well established in the private trade. I told him IMO that some of these laws may be outdated or need leeway because of the growing pet industry. He said there seems to be a "void" in the situation-- he was going to check into it for his own personal interests. He said it was fine that I was ranting about it-- and that he appreciated that I contacted their office to do the "legit" thing in case a permit was needed. But like he said, there is a "void" especially if people already have them in the US, but nobody has a straight answer about it.

So, apparently most people of APHIS and the USDA aren't even paying attention to the situation. The representative said, for my personal interests, to look into each state's requirements to see if there would be problems shipping any type of feeder insects.

This is both good and bad. Bad, because nobody knows if the government will "sting" them, but good because people act like they don't care. He told me that the federal government and state govs are more interested if you're importing insects from other countries, but they don't care if you sell outside the country unless there are restrictions.

Part of the issue is state vs. federal. The Fed gov say "no," but the local states surrounding KS may say "who gives a s**t?"

It seems that roaches and many other feeders are in limbo because the USDA can't comment.


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## Ed (Sep 19, 2004)

Why don't you work with a native Gryllus species instead of trying to bring one into the country? Most of those are going to be amenable to captive culture with some trial and error. 


Ed


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## Rain_Frog (Apr 27, 2004)

Hi Ed,

I'm not 100% positive, but I think I read on another forum that a few people tried to get permits for G. assimilis but were turned down. Gryllodes sigillatus is now found in the southern US, but technically they are from Asia and not North America.

And what species would be amendable to captive culture other than G. sigillatus and G. assimilis? I recently tried to culture Allonemobius socius collected from my own backyard, but most died for some strange reason. According to an article I read, can be tricky because you need to have the correct temperatures and photoperiod to prevent diapause.

Diapause is what I'm concerned about.


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## Ed (Sep 19, 2004)

A number of the North American Gryllus species have been shown amenable to laboratory culture. Most are based on this sort of methodology 
Cambridge Journals Online - Abstract 

(you'll have to purchase access). 

Ed


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## Pssh (Oct 23, 2010)

Hello, I'm new here, but I thought I might chime in. In all honesty, you could probably just have someone mail you some of the species you are interested in. All kinds of illegal insects come in through the mail all the time and no one seems to care, even when the name/species is written right on the package. Of course, that wouldn't be the legal way to do it. 

Lately I've been trying to breed camel crickets as an alternative to crickets (they don't chirp!!!) haven't gotten any offspring yet as I just started, but it seems easy enough. I'm not sure if you are interested in them for PDFs or other things, but I imagine they would be too big for all but larger frogs. They are a little more slow growing than normal crickets, but they are better in my opinion. You could also attempt to breed north American grasshoppers that are native to the whole US, like D. carolina, and sell those. Again, they would probably be too big for PDFs, but would probably thrive as a feeder for larger animals. There are also a few species of grasshopper that breed all year long when they are kept warmer and on at least a 12/12 photoperiod. I was told it was completely legal to ship them as long as they are already native to the state that it's going to.


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## Ed (Sep 19, 2004)

Pssh said:


> Hello, I'm new here, but I thought I might chime in. In all honesty, you could probably just have someone mail you some of the species you are interested in. All kinds of illegal insects come in through the mail all the time and no one seems to care, even when the name/species is written right on the package. Of course, that wouldn't be the legal way to do it.
> 
> Lately I've been trying to breed camel crickets as an alternative to crickets (they don't chirp!!!) haven't gotten any offspring yet as I just started, but it seems easy enough. I'm not sure if you are interested in them for PDFs or other things, but I imagine they would be too big for all but larger frogs. They are a little more slow growing than normal crickets, but they are better in my opinion. You could also attempt to breed north American grasshoppers that are native to the whole US, like D. carolina, and sell those. Again, they would probably be too big for PDFs, but would probably thrive as a feeder for larger animals. There are also a few species of grasshopper that breed all year long when they are kept warmer and on at least a 12/12 photoperiod. I was told it was completely legal to ship them as long as they are already native to the state that it's going to.


Actually according to the USDA, it is illegal to ship any plant pests (even those that are native to the state in which you are shipping them to) without a permit with the exception of fruit flies. 

As for not getting in trouble, it was only a couple of years ago, USDA agents (with badges and coats labeled USDA) showed up at the local herp shows looking for illegal inverts, mammals, as well as reptiles that need permits to ship across state borders without a permit (sulcatas, some hingebacks..) 

Ed


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## Ed (Sep 19, 2004)

I sent some questions to APHIS on the 23/Nov/2010 and I recieved the following response 



> Dear Mr. Kowalski,
> Thank you for submitting your inquiry. In response to question 1, this is the definition from the Plant Protection Act of 2000:
> Any living stage of any of the following that can directly or indirectly injure, cause damage to, or cause disease in any plant or plant product including:
> (A) Protozoan,
> ...


So in a timely manner we now have the answer to what constitutes a plant pest and is regulated by APHIS. 

I am waiting on the answer to bean beetles, and the roaches you mentioned Doug. I will post the answer when I get it.. This information is provided secondary to some research for an article I'm working on as well for a 4-H class I'll be teaching. 

Ed


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## Rain_Frog (Apr 27, 2004)

> Actually according to the USDA, it is illegal to ship any plant pests (even those that are native to the state in which you are shipping them to) without a permit with the exception of fruit flies.


One thing that gets ignored in these discussions about permits for drosophila is the fact that they're genetically engineered. The next next time I call someone, I need to ask if our flies need genetically engineered organism permits. I should probably call the San Diego Drosophila Stock Center as they've been very helpful for miscellaneous questions about drosophila. 

And it is illegal to import Drosophila species from foreign sources now without a permit.

Like my KS Agricultural Dept. rep said, there seems to be a "void" going on right now with the current laws after I explained the "roach situation" in the hobby. (which I even told my rep that they are outdated with the arrival of the global reptile trade and the advent of ecommerce). 



> As for not getting in trouble, it was only a couple of years ago, USDA agents (with badges and coats labeled USDA) showed up at the local herp shows looking for illegal inverts, mammals, as well as reptiles that need permits to ship across state borders without a permit (sulcatas, some hingebacks..)


As I said earlier, my rep said the state of KS is not interested in pests other than boll weevils. True, the USDA says no roaches, but it doesn't necessarily mean that the federal government can overrule the states in this situation. Also, I explained to him that the roaches are already here and widespread. He said there is more emphasis put on importing foreign insects then ones already here, which further complicates the problem. And just because the USDA said drosophila do not need permits doesn't mean individual states could make interstate transporation illegal without a permit he said. And which states are these?

If you check on arachnoboards.com archives, James Tuttle of Blaberus.com has permits for 49 individual states to ship roaches besides hissers. I emailed him, but haven't gotten a response yet. James writes in a post that some of his packages were stopped before he acquired permits, but he was never fined. But when he exported some to Canada, he was fined $225.

American Cockroach as feeder? - Arachnoboards

I did contact Black Jungle and they said to their knowledge, springtails and drosophila did not require a permit.

Do we know the actual species names of our springtails? All I see is "Folsomia candida" and everything else is just by scientific name ( "Sinella sp").


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## Rain_Frog (Apr 27, 2004)

Hi Ed,

Could you please tell me who you emailed? Every time I've emailed APHIS I either got a very late response, or not one at all. Did you inquire about springtails?


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## Ed (Sep 19, 2004)

Doug,

I don't think the fruit flies we use fall under the USDA definition of genetically engineered.. (See for example http://www.aphis.usda.gov/publications/biotechnology/content/printable_version/faq_ge_animal_08.pdf )

They were irradiated to induce mutations, they did not have DNA spliced into them from other organisms. 

You are misunderstanding the situation. The USDA (through the Federal goverment) controls interstate transport. The state may say it is okay but if the feds say no, then you cannot use interstate transport go get them there.. You could try quantum tunneling... 

Ed


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## Ed (Sep 19, 2004)

Rain_Frog said:


> Hi Ed,
> 
> Could you please tell me who you emailed? Every time I've emailed APHIS I either got a very late response, or not one at all.


 
As this was a plant pest question I used the link provided on the APHIS site for questions about plant pests. I limited my questions to specifics to prevent it from being difficult to answer or unrealistic to answer. 

[email protected] 

When I have asked questions in the above format, I have never had to wait more than 14 days to get an answer. 



Ed


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## Rain_Frog (Apr 27, 2004)

> Lately I've been trying to breed camel crickets as an alternative to crickets (they don't chirp!!!) haven't gotten any offspring yet as I just started, but it seems easy enough. I'm not sure if you are interested in them for PDFs or other things, but I imagine they would be too big for all but larger frogs. They are a little more slow growing than normal crickets, but they are better in my opinion. You could also attempt to breed north American grasshoppers that are native to the whole US, like D. carolina, and sell those. Again, they would probably be too big for PDFs, but would probably thrive as a feeder for larger animals. There are also a few species of grasshopper that breed all year long when they are kept warmer and on at least a 12/12 photoperiod. I was told it was completely legal to ship them as long as they are already native to the state that it's going to.


Have you attempted to feed camel crickets to larger herps? If so, what species?

I read somewhere that some grasshopper species may be an intermediate host for tapeworm, not to say our feeder insects couldn't be carriers of other things, but that's one thing I've heard.


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## Ed (Sep 19, 2004)

I recieved the rest of my response from APHIS today (nine days after submission of the original request, which was filed over a holiday weekend). 

The response was in answer to the following questions 

2) does the cow pea weevil (Callosobruchus maculatus) require a plant pest permit to ship across state borders 

3) do the roaches used as feeders specifically Blaptica dubia and/or Blatta lateralis need a plant pest permit to be shipped across state borders? 



> Interstate movement permits are required for the cowpea weevil. We are denying permits for the interstate movement of the two roaches listed.


Ed


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## Rain_Frog (Apr 27, 2004)

Ed (and anyone curious),

I got my response back from APHIS. Here was the first sentence of the response.



> Mr. Peel,
> You are correct; the interstate movement of Collembola (springtails) does not require a permit.



All species except Drosophila suzuki do not require a permit, but he told me to check with biotech regulatory service about genetically modified species, but on their website (that I don't have time to hunt for this morning) I discovered that transgenic drosophila do not need permits because they do not contain sequences from pest species.


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## Ed (Sep 19, 2004)

Rain_Frog said:


> Ed (and anyone curious),
> 
> I got my response back from APHIS. Here was the first sentence of the response.
> 
> ...


Is lack of permits for Drosophila under the new nomenclature or under the old nomenclature as that could be a big difference depending on what species people are rearing.. 

Ed


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## Ed (Sep 19, 2004)

Bumping this back up since at least one cricket company has gotten approval from the feds for Gryllus assimilis and the G. assimilus actually seem to do better than the brown house cricket that is being wiped out by the virus. 

Ed


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## snake5891 (Dec 10, 2009)

I'm tempted to order 500_ Gryllus assimilis_ just to see if they're less prone to just dying on me like I felt with _Acheta domestica_ when I tried to breed my own.


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## Ed (Sep 19, 2004)

snake5891 said:


> I'm tempted to order 500_ Gryllus assimilis_ just to see if they're less prone to just dying on me like I felt with _Acheta domestica_ when I tried to breed my own.


I've ordered them several times now and the mortality is way less in my purely anecodotal opinion. 

Some comments,

Ed


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