For a short time, the U.S. was the world leader in regulating to prevent introduction of a foreign amphibian disease that has caused a deadly epidemic in Northern Europe – and could cause the same outbreaks here. Unfortunately, we have since surrendered our leadership. But, we still can and must act. Here is the story as I have seen it unfold (having begun my advocacy on this particular threat in late 2014).
The fungus Batrachochytrium salamandrivorans (“Bsal”) is carried on the skin of a large number of salamander species; it was first described in 2014. To help prevent Bsal from arriving and killing native salamanders, the U.S. Fish and Wildlife Service (FWS) published its “Interim Rule” in January of 2016 to list 201 salamander species as “injurious wildlife” under the Lacey Act (available here; the list of blocked species is here). The FWS had determined that Bsal caused major die-offs of salamanders in Europe and posed an imminent threat to our U.S. native populations. The fungus, which had very likely been carried from Asia to Europe via the pet trade, is not known to exist in the U.S., which is a very fortunate thing because we are the global “hotspot” for salamander diversity. An array of beautiful and popular species are found across the nation, especially in the Appalachian and south-eastern States and the Pacific Coast States.
That 2016 regulation was an important advance fought for by many amphibian conservation advocates and experts. We were proud that ours was the first government to take proactive steps. Unfortunately, the FWS regulation’s focus on just 201 salamander species — out of more than 650 named species worldwide — meant that the regulation was not protective enough to reliably keep Bsal out (as scientists had stressed to the FWS back in 2015). However, we took hope from the fact that it was an “Interim” regulation responding to the urgency of this new risk and the agency had repeatedly announced it intended to revise it into a Final Rule, which process could toughen it up. However, two and a half years have gone by with no action.
In the fall of 2017 the new Bsal science was showing even greater risk than was understood before. This was gathered into a comprehensive Scientists’ Statement of Reasons for a Class-wide Moratorium of Amphibians in USA Import Trade to Prevent Entry of Bsal, signed by 12 leading amphibian health experts (available here). Further driving home the need for toughening the Interim Rule, in February of 2018 a crucial paper came out, the Yuan et al. salamander study, Widespread occurrence of an emerging fungal pathogen in heavily traded Chinese urodelan species. (Conserv Lett. 2018;e12436). Reviewing Table 1 therein reveals that of 8 species that tested positive for Bsal infection in China, when compared to the 201 species regulated under the FWS Interim Rule, at least 3 species were positive for the infection that are not prohibited from import: Andrius davidianus, Pachytriton wuguanfui and Paramesotriton aurantius.
To reiterate: the Interim Rule allows unregulated Bsal-infected species from China to be imported. Further, we know the list of native U.S. species regulated under the list of 201 species is underprotective. Knowledgeable scientists say that Bsal can infect and harm at least 5 additional native species beyond those the FWS listed, while many more unlisted species can act as carriers of the pathogen. (That research likely will be published over the course of this and next year.) In short, the 2016 Interim Rule now looks like Swiss cheese.
Meanwhile, we have given up our Bsal leadership position to Canada, the European Union and the United Kingdom. After first adopting a 1-year import moratorium, Canada now (effective May 12, 2018) prohibits imports of all species of the order Caudata (salamanders, newts and mudpuppies) except via a special permit (available here). Taking a different approach, at the end of February the European Union recommended a sweeping “Clean Trade” program relying on pre-shipment certifications, applicable to both imports into the EU and trade between member nations (available here). The EU animal health authorities recommended that members allow no commercial salamander shipments without risk mitigations, such as detailed quarantines and testing of shipments.
Just recently the United Kingdom followed the EU recommendation and adopted a strict health certificate and quarantine approach for salamander and newt imports targeted to prevent Bsal (available here). It involves three, alternative, detailed quarantine options, while allowing importers to propose a different quarantine approach if it is based on peer-reviewed published science.
To make matters look worse for the U.S. by comparison, this Administration has for no clear reason disengaged from the previously-announced FWS plan to finalize the underprotective Interim Rule. There was a public comment period that ended in March of 2016. Because of that now two-year old closed comment period, the FWS officials in charge just this past April flatly refused to meet with a group of salamander experts to discuss the implications of the new science mentioned above. Then, we found out that the FWS actually officially has delayed finalizing the Interim Bsal Rule indefinitely; the agency now classifies it as a “Long-term Action” with no planned date for completion. (Per White House, Office of Management and Budget, Unified Regulatory Agenda, here).
This administrative slow-down is remarkably unfortunate. Rather than reflecting the new realities and proposing a state-of-the-science “Clean Trade” approach like the EU and UK, or mandating a permit for all salamander imports like Canada, or at least adding the other known unlisted Bsal-carrying and Bsal-vulnerable species to the list of 201 prohibited species adopted back in 2016, the FWS now appears content to expose the country to the risk of this devastating wildlife epidemic via unregulated imports.
It would be one thing if there was some overwhelming economic value to salamander imports, but that is not so. Salamander imports make up a tiny part of the pet trade – their total dollar value is paltry compared to other imported animals. Neither the organized pet industry nor anyone else is actively trying to block progressive protections. Indeed, the pet industry will itself benefit greatly from not having Bsal here infecting its own commercial pet supply. And the industry will benefit from not being blamed if or when released pet salamanders spread Bsal into the wild, which is an all-too-likely scenario based on past species and pathogen incursions.
As called for in the 2017 Scientists’ Statement mentioned above, in order to protect our priceless North American salamander fauna we need a “class-wide ban” – at least. This can and should still allow for appropriate exceptions under FWS permits for education, research, display and other important uses as are already provided for under the Lacey Act.
If you would like to get involved in the informal “Bsal Discussion Group” that is engaged in advocacy to improve the FWS regulation, please contact me at: jenkinsbiopolicy@gmail.com.
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PART II, coming soon, will delve into the new science about the “old” emerging amphibian epidemic, Bd, which has devastated frogs and toads across the planet.
Posted by Peter Jenkins
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