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Bryn Mawr's NAGPRA Process

September 27, 2021

This message was sent to the Bryn Mawr College community on September 27, 2021

Dear Bryn Mawr Students, Faculty and Staff,

We are writing to share important information about collections at Bryn Mawr College. This spring, Bryn Mawr undertook a review of collections that might include human remains or burial-related items, seeking to confirm the College’s compliance with the Native American Graves Protection and Repatriation Act (NAGPRA). (1)

This was the second NAGPRA review conducted by the College. Following the initial passage of NAGPRA in 1990, the College undertook an extensive first review of its permanent holdings to look for Native American remains, funerary objects, sacred objects, or objects of cultural patrimony that should be repatriated. In instances where any Indigenous remains or objects are found, the institution holding them must produce detailed inventories of human remains and more general summaries of holdings of Native American cultural items and make them available to Tribal Nations. In 1996, the College reported its summary to the National Park Service, which administers NAGPRA.

In our late spring 2021 review, the College’s Special Collections Department discovered that a collection that was on loan to the College from the Academy of Natural Sciences at that time was not included in the initial review, since it was not a permanent holding. The collection in question includes Native American funerary objects from various localities, and a small number of fragmentary remains belonging to several individuals from an archaeological site in Adams County, Mississippi. Those collections were subsequently donated to Bryn Mawr in 1998, and our review this spring revealed that the College did not complete a review of the collection at the time the collection was accepted as required under NAGPRA. This was an institutional failure, for which we are now taking responsibility.

Upon discovering the required process for inventory and summary had not been done, we immediately contacted personnel at the National NAGPRA Program and hired a consulting firm with a long history of working with Native American Tribes on NAGPRA issues, Bernstein & Associates NAGPRA Consultants. With their guidance, we are now in the process of working with official representatives of Tribal Nations from whose ancestral lands these remains and objects were removed in order to facilitate repatriation as desired by the Tribes. We are committed to seeing that this work is carried out with compassion and respect. At all times, we will follow the protocols set forth by both the Tribal representatives with whom we are consulting and NAGPRA.

Maintaining collections of Native American human remains and funerary objects without the knowledge and permission from the Tribes is unacceptable, and such actions are not in keeping with the values of Bryn Mawr College. Because we do not yet know the wishes of the Tribes with whom we are in communication, we will not be publicly detailing these ancestral remains and cultural items at this time. We will abide by the Tribes’ wishes for any disclosures about the remains and objects, and for their care and treatment while they are housed at the College.

In addition to rectifying the failure to review this collection properly in 1998, the College has put in place policies, practices, and continuous professional development to strengthen our adherence to NAGPRA and to keep focus on ethical professional practices overall in relation to collections. Since March 2000, we have had a Board of Trustees-approved Collections Management Policy that precludes accepting such items, and the Special Collections team and the College’s Collections Committee will continue to vigilantly uphold and regularly review collection policies to ensure we are abiding by ethical best practices when we bring new collections into the College. Over the past year, Special Collections staff have been engaged in an intensive process of articulating the department’s ongoing commitment to confronting the legacies of colonialism and racism in special collections, and we will continue that work with focus this year and into the future. In addition to this repatriation process, different College departments will partner this year to articulate clear policies and practices that ensure any work with human remains in the context of academic disciplines follows all legal and ethical best practices.

We apologize on behalf of the College that Bryn Mawr accepted the collection from the Academy of Natural Sciences without a thorough review and affirm that we will be moving forward in alignment with NAGPRA and with Bryn Mawr community values that are fundamentally important to us. We are working closely with the appropriate Tribal representatives and the NAGPRA consulting firm throughout this process and look forward to informing the Bryn Mawr community about the resolution when it is complete.

All are welcome to an open forum on Thursday, Sept. 30th, 4-5pm, as an opportunity for community reflection, questions, learning, and discussion. With input from the Bryn Mawr community, as well as the wishes of descendant communities with whom we are in conversation, we will consider what learning opportunities we can facilitate for Bryn Mawr community members who would like to understand more about NAGPRA and Bryn Mawr’s collections and practices.

Sincerely,

Kimberly Wright Cassidy, President
Gina Siesing, Chief Information Officer & Constance A. Jones Director of Libraries

(1) NAGPRA is a federal law enacted in 1990 that provides a process for museums and federal agencies to return Native American human remains and certain cultural items – funerary objects, sacred objects, and objects of cultural patrimony – to lineal descendants, Indian Tribes, and Native Hawaiian organizations. NAGPRA affirms the principle that human remains must at all times be treated with “the respect and sensitivity they deserve,” and that human remains and cultural items removed from federal or tribal lands “belong, in the first instance, to lineal descendants, Indian Tribes, and Native Hawaiian organizations.” The facet of NAGPRA relevant to the review of this collection that should have taken place in 1998 is the NAGPRA’s Future Applicability Rule. For more information, see https://www.nps.gov/subjects/nagpra/regulations.htm.