Stewardship of Human Remains

As provided for in the YPM Collections Management Policy, this policy governs the Yale Peabody Museum’s (YPM) use of its collections of human remains to facilitate research, teaching, and the dissemination of knowledge in accordance with high ethical and professional standards that acknowledge the dignity of deceased individuals and the views of descendant communities.  

This policy and the accompanying YPM Human Remains Access Procedures apply to all human remains within the care of the YPM, including those remains that are legally accessioned and those on loan or deposit, for which the YPM acts as custodian, except that human remains that are subject to the Native American Graves Protection and Repatriation Act (NAGPRA) will be administered by the Repatriation Registrar in accordance with NAGPRA, rather than under this policy. Derivatives of human remains (e.g., photographs, CT scans, X-rays, and casts) are also considered under this policy.   

The YPM adheres to the following principles in applying and interpreting this policy:  

• The YPM treats all human remains with respect and dignity.
• The YPM recognizes that human remains play an important role in advancing scientific research and education.
• The YPM consults and collaborates with lineal descendants, communities or groups of origin, or other appropriate representatives to obtain informed consent regarding research, teaching, or display of human remains pertaining to their ancestors.
• The YPM will consider whether the circumstances of a collection’s acquisition accord with contemporary ethical and professional standards in determining whether use of that collection is appropriate.
• The YPM will prioritize the preservation and conservation of its collections of human remains.

The YPM, in consultation with Yale’s Office of the General Counsel, complies with all laws and regulations relating to human remains, including, but not limited to, NAGPRA. 

1.3.1. Relevant Terminology

1.3.1.1. Human remains are defined as the physical remains of a Homo sapiens individual and may include partial or complete skeletal elements (including those found in archaeological contexts that are commingled with faunal or midden material) and both dried tissue (e.g. mummified remains) or prepared tissue (e.g. scientific slides of human soft tissues). Artifacts containing or fashioned from human remains are also subject to this policy. Human remains that were naturally shed (e.g. hair, fingernails) or obtained under a modern informed consent regime will typically be considered outside of this policy. Derivatives of human remains include photographs, casts, 3D scans, and X-rays, and other digital media.

1.3.1.2. Lineal descendants are the direct descendants of a person, such as child, grandchild, great-grandchild, and so on. A direct line of descent can be concluded through DNA results.

Non-lineal descendants are relatives who are not in a direct line of descent, such as siblings, nieces, nephews, and cousins. Non-lineal descendants may share DNA with a person from whom they are not directly descended.

The Human Remains Advisory Panel (HRAP) advises curators and other YPM staff on issues (other than issues involving NAGPRA-eligible remains) involving the acquisition, use, conservation, restriction, or return of particular collections of human remains, including, but not limited to, the review of access requests for the use of human remains. HRAP is a standing group of YPM faculty and staff consisting of:

• the Repatriation Registrar (Chair);
• the Head Registrar;
• the Curator-in-Charge of Anthropology; and
• 2-3 additional staff members or curators (at least one of whom must be a curator) with training in biological anthropology, with a preference for training in human osteology and/or skeletal biology and experience with human remains research.

The ethical consideration of all collections within the possession of the YPM is consistent with Yale University ethics policies and the YPM Collection Management Policy. Further, the YPM Human Remains Policy emphasizes the considerations that are unique to the stewardship of human remains. We recognize that the building of scientific knowledge is a common good and is the core mission of a research institution. Modern approaches to biological anthropology, employed by the YPM, include consideration of lineal descendants and communities of origin. The YPM is committed to its role and responsibility to afford all human remains within its care with dignity and to facilitate research in a respectful manner.

The YPM rarely acquires human remains (whether from archaeological excavation or by transfer, donation, or purchase). Exceptions might include ethically sourced teaching material, material critical for reconciling historical collections management issues (e.g. the return of undocumented loans), and material that will allow for the return or repatriation of remains. 

The YPM will deaccession human remains in accordance with the University Collections Policy (Policy 9000) and YPM deaccessioning procedures. Human remains may be subject to ethical returns to communities of origin, and requests for their return will be reviewed by HRAP. 

2.2.1. Returns

Requests for the return of human remains to descendants and communities or governments of origin are reviewed by HRAP. Return recommendations are provided to the divisional curators and staff.   

The YPM accepts incoming loans of human remains from other institutions. Outgoing loans for human remains are generally reserved for instances in which approved research includes the destructive analysis of the remains.

Curators, in consultation with HRAP, will determine when loans are appropriate. All human remains lent to or deposited at the YPM will be subject to the requirements of this policy.

All human remains within the care of the YPM are stored in spaces with secure access and environmental conditions appropriate for preservation, in particular:

• The YPM’s skeletal and mummified human remains collections, including remains subject to NAGPRA, are in separate and secure storage rooms that are adjacent to the cultural materials and archives curated by the Division of Anthropology.
• Fragmentary skeletal remains may be commingled with archaeological assemblages; in these cases, the YPM staff will determine whether the remains should be stored within the archaeological context in the Division of Anthropology’s general collections storage, or removed from the context and stored in dedicated human remains storage.
• Soft tissue materials that have been prepared as slide specimens are located separately with care that considers the environmental needs of those types of materials.
• Human remains that have been incorporated into cultural items are stored within the Division of Anthropology’s general collections storage.

Human remains will be stored in a manner that promotes their long-term preservation, for example, using enclosed or covered boxes, trays, or other types of containers made of archival quality and stable materials, except that communities of origin and lineal descendants may request alternate storage arrangements that may be approved by curators in consultation with HRAP and other relevant collections and conservation staff.

The permissibility of using human remains for teaching, research, or display depends on several factors, notably, whether the proposed use would affect preservation of the human remains, and whether the remains were acquired in accordance with high ethical and professional standards. Specifically, use of remains depends on their circumstances of acquisition, including the presence of informed consent: 

• In general, the YPM will not use human remains whose circumstances of acquisition are not in keeping with contemporary professional ethics, except for uses related to return or repatriation, or uses requested by descendants or descendant communities. 
• Human remains whose circumstances of acquisition cannot be determined should be considered for use with caution and alternatives used if available; curators, with the assistance of the HRAP, should make every effort to determine the likely circumstances of acquisition in such cases and should make decisions accordingly. 
• Human remains whose circumstances of acquisition for which informed consent has been given by one or more interested parties, and which do not raise any other ethical concerns, may be made available for research and teaching at the discretion of the presiding curators and by recommendation of the HRAP. 
• All human remains used for educational purposes should be protected from damage and handled with care, dignity, and respect.  

The YPM will only display human remains following careful review by HRAP, relevant YPM curators, and any relevant public engagement or exhibition staff and when available informed consent for display (which can be withdrawn at any time) has been obtained from affiliated communities, descendants, or other appropriate parties. This policy extends to images of human remains, which are restricted from online display. 

The YPM will typically require that instructors use its anatomically prepared, articulated skeleton, for which informed consent has been obtained. In the case of a compelling justification for use of other remains, the relevant divisional curators, with recommendation from the HRAP, will consider the request pursuant to the principles stated in Section 3.1. above. 

3.3.1. Teaching Access Requirements

Procedural requirements for the educational access of the YPM human remains collections, including the articulated skeleton, are outlined in the YPM Human Remains Access Procedures. 

Access to human remains held by the YPM for research purposes will be considered on a case-by-case basis by the HRAP and relevant curators.   

3.4.1. Destructive Analysis 

The YPM acknowledges that destructive sampling is required for certain techniques such as radiocarbon dating, isotopic analysis, or aDNA sequencing. Researchers requesting access to perform destructive sampling should adhere to 3.4.3. Access Requirements.    

3.4.2. Commercial Use 

Research on and/or analysis of the YPM human remains collections must be for scholarly, academic purposes. Research for commercial, for-profit purposes is not permitted.  

3.4.3. Research Access Requirements 

Procedural requirements for requests to access the YPM human remains collections for research purposes are outlined in the YPM Human Remains Access Procedures. 

3.5. Other Access Requests 

Requests to access the YPM human remains collections for purposes outside of teaching and research will be considered on a case-by-case basis. The HRAP will review requests according to the processes provided in the YPM Human Remains Access Procedures.  

Researchers interested in learning more about the non-NAGPRA YPM human remains collections (e.g., holdings, availability for research) are encouraged to contact the Human Remains Advisory Panel (HRAP) at hrap.@yale.edu.  

Researchers will be asked to fill out a Human Remains Access Request Form. A link to the form is provided below.  

1. Researchers should initiate a formal request by submitting a “Request to Access Human Remains Collections” form through the HRAP website. 
   
   1. Researchers will be asked to provide a description of the proposed research, a list of the specific YPM collections or items they wish to access, and an explanation of how access to the YPM collections is critical to their research goals.  
   2. Additional information will be required for all researchers wishing to conduct destructive analyses on human remains (see Destructive Sampling section below).  
   3. Researchers should also indicate whether they desire access to imaging or non-destructive testing facilities outside of the human remains collection space (e.g., CT scanning, radiography, Raman spectroscopy, XRF) so that YPM staff may oversee and facilitate transport.  
2. HRAP and curators will review all requests for access (see review process below). Final decisions rest with the division curators after consideration of the HRAP recommendations.  
3. Researchers with permission to access a collection will be assisted by the appropriate staff to arrange start and end dates for their research visit.    
4. Researchers will be expected to uphold the policies of the YPM as outlined in the Human Remains Research Terms and Conditions.   

Researchers may be asked to provide a record of individual and/or community consultation under certain circumstances (e.g., genetic research, research on human remains with known lineal descendants or living kin, or in cases when the research implications may affect living communities or interested parties). This record should be accompanied by a statement identifying the method of consultation, how the consulting partners were selected and why, and permissions granted, including, where possible, permission to conduct the research and publish the findings.   

Educational Access 

University professors, lecturers, and teaching assistants may request access for teaching with the ethically sourced skeleton via the request form on the Human Remains website. The HRAP will help to coordinate access and arrange for respectful storage and transfer if required.    

All other requests should also be directed to the HRAP, which will review each request with the relevant YPM curators. The review process will closely follow the review process for research access (see below).  

Destructive Sampling 

Researchers requesting access to perform destructive sampling should adhere to the following procedures:  

1. Researchers must submit a formal “Request to Access Human Remains Collections” as outlined above.  
2. Researchers wishing to perform destructive sampling must submit a “Request to Perform Destructive Sampling” form.   
   1. Researchers must detail the specific methodologies and techniques they will be using, as well as justification for why the destructive sampling is necessary. Researchers must provide explicit details on the sampling process, including the size or weight or samples required, number of samples, the skeletal location, and the amount of material that will be damaged or destroyed during the sampling process (i.e., what elements or areas of the skeleton will be needed). This includes any sectioning of the skeletal remains that would need to occur before transport to another facility, not just the extracted sample itself.  
   2. Researchers must indicate in their proposals that they have eliminated all possible non-destructive methods and that they have taken all measures to ensure the least destruction in consideration of future research.   
   3. Researchers must describe their qualifications as well as what safety measures will be taken during the sampling process.  
3. Researchers with permission to access a collection will be assisted by the appropriate staff to arrange start and end dates for their visit.    
4. Researchers must follow the YPM Human Remains Access Terms and Conditions as well as the specific YPM and division policies regarding destructive sampling.   
   1. All items should be photographed before and after sampling according to the standards of the YPM. The researcher must provide a list of all catalog numbers as well as the type of material removed.  
   2. Unused portions of the sample must be returned to the YPM after analyses are completed.  
   3. The HRAP and curators may indicate special conditions in the authorization form.  
   4. The hosting YPM Division is responsible for archiving all associated documentation in EMu.   

1. All requests received through the HRAP contact will be forwarded to the appropriate division curators (for example, if a request is made to access human remains currently under the division of Anthropology, the Anthropology curators will receive the request, in addition to the panel members).   
2. The HRAP will review all requests. Though not an all-inclusive list, the following considerations will be made by the HRAP when reviewing requests:  
   1. Meet the qualifications of section 3.1 General Principles of the YPM Human Remains Policy.  
   2. Merit, practicality, and novelty of the research proposal, as well as the significance of the data from the YPM collections to the research project.   
3. Due diligence in conducting consultation.  
4. Extent of prior handling or destructive analyses on the desired collections.  
5. Provenance and accessibility of the desired collections.   
6. Methodology, particularly in the case of destructive sampling.   
7. After review, the HRAP will provide curators with a recommendation to either grant or deny access. This recommendation will include any necessary documentation and/or justification to support their recommendation. If the panel recommends that a request be denied, the panel will provide clear reasoning for how they reached that conclusion. The panel may also recommend approving the request, but with certain limitations or restrictions.  
8. Upon final approval or denial of requests, the Curator-in-Charge will document.