How to import samples legally: APHA and SASA regulations
This video details the legislation surrounding sample imports from non-EU countries. It is not intended as a complete guide, and we encourage you to use this video to identify whether your planned samples fall under this legislation, with regard to the country of origin and the sampe type, and how to plan your study to ensure your samples can be exported promptly, and transferred to a facility within the bounds of this legislation.
The legislation varies across the UK, and it is important you understand the regulations within your host institute.
Scotland: Science and Advice for Scottish Agriculture
England and Wales: Animal and Plant Health Agency
Northern Ireland: Plant and Tree Health
If your samples do fall under this legislation, and you are planning to send your samples to a NEIF facility, be sure to check the relevant legislation for either Scotland (NEIF sites in East Kilbride) or England (British Geological Survey, University of Oxford, University of Bristol or the Centre for Ecology and Hydrology).
It is important for you to note, that samples sent without the proper authority and packaged in the correct way, may be destroyed on arrival. This video will detail the triple wrapping requirements, but it is worth reaching out to the relevant facility well in advance of shipping to ensure you are in compliance, and your samples will be protected.
This video will introduce you to your legal requirements when it comes to importing samples from non-EU countries. None of the analytical facilities can take in samples that have been imported incorrectly
Please watch this video and determine whether or not you need to pursue further guidance from your local licensing officer.
If you are planning to collect new samples for analysis, or import samples already collected from non-EU countries, excluding Liechtenstein and Switzerland, you may need a specific license to import these samples legally.
This license is issued in England and Wales by the Animal and Plant Health Agency (or APHA), sometimes referred to as DEFRA licensing, and legacy referral as FERA licensing and in Scotland is covered by SASA, the Science and Advice for Scottish Agriculture, and in Northern Ireland, the Department for Agriculture and Rural Development.
The license arrangements are in place to protect UK environments from potential risk to biosecurity from an unintended release of pathogens, spores, microorganisms, and other materials.
It is important that these regulations are adhered to, and that you have made arrangements under the relevant license, with an authorised license holder, before you commence fieldwork or sample collection.
The following refers to plant, soil, sediment, and rock samples. If you are importing animal or human tissue or waste samples then you will need to arrange for a special one-time import licence from the APHA.
It takes a minimum of two months to arrange a new perpetual site plant health license, and most UK universities would be familiar with this legislation and likely have a licence in place for at least one site. Licenses are specific to individual sites, and sometimes even rooms within those sites. Material can only be imported directly to a licenced site and then transferred between licenced sites with specific permission from APHA or SASA.
Before planning sample collection, your first task should be to determine:
Is an authorisation required for your sample type?
Who is responsible for managing the license at your institution? They are sometimes referred to as the licensing officer, they will provide you with a letter of authority to allow you to import.
You should determine whether you need an additional permission from the country of origin to export samples, they may also require a copy of the UK letter of authorisation to allow that export to go ahead.
What sample types may be covered by the license:
soil and growing medium including humus, peat and bark
freshwater sediments from a lake or a river
Estuarine or inshore sediments
Filter papers collecting soil or sediments
Water containing soil or sediments
Rocks with a weathered surface in contact with or exposed to soil or sediment contamination
Other materials with soil or sediment coating
Water containing plant life, and plants, both living and dead
Rocks that have lichen or moss on their surfaces such as those utilised in cosmogenic dating.
Critically, it is important to understand the types of materials to which this does not apply:
pure and unused coconut fibre
pure sand, clay, talc, rocks, volcanic pumice and chalk that are not biologically contaminated.
water that isn’t contaminated by soil or organic matter.
The precautionary principle should be considered here, if you are in doubt, it is better to reach out for guidance, and to contact the APHA or SASA licensing officers within the importing site before starting your fieldwork.
Marine sediment cores are usually exempt from these requirements, including any core collected from an environment with an open ocean connection. Again, if you are in any doubt, it is essential that you contact the relevant local licensing office to check your compliance. BOSCORF staff can assist with guidance for your project if you are planning analysis at the facility.
For terrestrial samples, it is always worth checking with the facility before import to ensure they are aware of your sample’s origin, and they can advise you on the relevant procedures.
Contacts for SUERC, BGS and BOSCORF are provided in the additional materials for this video.
Even if you have imported samples in the past, it is worth checking that you are up to date with current legislation as this legislation is subject to change.
Samples sent to laboratories without appropriate paperwork, may be seized at customs or destroyed on arrival in order to maintain our licenses for other laboratory users.
If you require a letter of authority to import, it is important to take certain steps before commencing your fieldwork to ensure that your samples can be exported from your field site promptly.
Contact the licensing officer at your import site:
This may be at your own university, or at the analytical facility you plan to utilise
This is a letter with a unique Introduction Reference Number, or IRN, which will be copied across to the facility records
A letter of authorisation from the country of origin if required: This could be provided by the equivalent of the plant health agency in the UK, it is best to start this process early on in your fieldwork planning. It is up to the researcher to determine if this is applicable for the given country of export.
You should understand your responsibilities and the instructions: This normally means labelling your package with your details, the details of the consignment are prescribed in your Letter of Authority, the quantity of material which will have been pre-agreed with the facility, and taking copies of the authorisation and letter of authority with you to arrange shipping
For shipping, the Letter of Authority and authorisation should be attached to the outside of any packages and if you are undertaking fieldwork in remote locations, it is useful to take pre-printed copies of these letters with you.
There will be specific shipping arrangements in place, and these may vary between the facilities depending on sample type.
For BOSCORF, we do ask that samples are not imported directly to BOSCORF, but instead are transferred for analysis after importing under your own APHA/SASA license.
For example, sediment cores cannot be autoclaved to minimise the contamination risk, you will be given instructions on how to triple wrap your core samples to ensure that when they are unpacked, the risk of escape of biological material is minimised. As one layer of packaging must be shatterproof, we can arrange to send you D-tubes for safe transport.
it is essential that one layer is shatterproof and if you have any questions, please contact the facility, as you may need to take specific packaging requirements with you on your fieldwork.
Each sample must be completely air-tight, and sealed from each other and the environment so that the box containing the sealed samples does not itself become contaminated, and therefore licenced material itself.
Samples should be double wrapped before going in the outer shipping container/boxes
Once you have arranged shipping, it is helpful to alert the facility to the likely arrival date of your samples, so that they can be collected and stored appropriately as soon as they arrive.
If you are transferring samples from your UK institute to a facility for analysis, the steps are similar, with the additional step for the sending licence holder to fill out the APHA PHI 10 form and will need the license details from the receiving institute for approved transfer. This is specific to England and Wales, you should enquire with the receiver if they are in Scotland.
You won’t be able to start lab work on samples that don’t have proper authorisation, there is also the risk that they may become subject to destruction during transit. You should note, that samples sent from unauthorised sites cannot be returned to you, and may be destroyed to maintain compliance with the site licence.
Once your samples are received, they are stored into designated areas, or quarantine cabinets until processing.
For some samples, it is possible to sterilise them on arrival by autoclave or oven treatment. This removes them from the licence and means they can be treated as native UK materials.
You should note, that we cannot accept sterilisation in the country of origin as appropriate for our license, we will need to sterilise here as well. For biological material, this could be discussed as part of your intended analysis in advance of arranging shipment.
It should be noted that currently APHA only accept autoclaving as sterilisation, for other techniques such as gamma irradiation you would have to “prove” the sample had been sterilised.
It is important to know that BOSCORF will only accept sediment cores that have been prepped for analysis. BOSCORF is not licensed to split imported non-marine sediment cores. All core sample preparation must be undertaken at your home institution.
We can provide guidance on suitable splitting and preparation of core samples for you to undertake at your home institute. All samples should be no more than 1m in length.
And the samples are stored within secure boxes, inside a dedicated quarantine cabinet, with specific dimensions. BOSCORF has a limited capacity for storing these samples, therefore all analysis is carefully scheduled to keep sample volume within our limits.
This is why early communication is important, as soon as you are aware your sample may fall under this license, we encourage you to contact us, so that BOSCORF can manage and maintain its license requirements. It is also vital that we can return samples to you promptly, to maintain the analytical schedule.
In summary, contact the facility in advance of fieldwork to discuss your sample, the preparation steps it may require before analysis and especially if it falls under the plant health licensing regulations.
Ensure you take appropriate shatterproof packaging with you for shipping back to the UK
Contact the plant health agency in the country of origin before you go
Take multiple copies of your Letter of Authority and authorisation with you to attach to your package
Alert the facility when you have finalised your shipping so you package is anticipated, and can be stored and sterilised appropriately
Discuss these requirements as soon as possible after starting your project to ensure you are in compliance.
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