Departmental Statement on Ethics of Research and Stewardship of Human and Non-Human Skeletal Remains

Departmental Statement on Ethical Stewardship of Human Remains

The Department of Ecology, Evolution and Environmental Biology [E3B] at Columbia University is committed to the ethical pursuit of knowledge, and the responsible stewardship of that which is entrusted to our custodial care including human and non-human skeletal remains.  We are guided in our efforts by the Native American Graves Protection and Repatriation Act (NAGPRA), and by international treaties, professional protocols, and our own commitments to just, ethical, and responsible research practice.

To that end, in concert with the Department of Anthropology (the original custodians of these remains for the University), we are engaged in an ongoing process of identifying and inventorying human remains on site, consulting with relevant professional and cultural organizations and authorities to determine provenance, and working to ensure the well-being and, where possible, repatriation. University approved protocols [see here] are in place for the handling (even the viewing) of human remains as well as of casts of remains. 

I.  History of the Collection

E3B is the current custodian for approximately two thirds of the human skeletal remains held by Arts and Sciences along with the majority of non-human skeletal remains on the Morningside Campus. Until the retirement of Dr. Ralph Holloway in 2023 and concurrent move of part of the osteological collection, these remains were under the care of the Department of Anthropology. 

The history of how the majority of these remains came to Columbia is poorly known.  This is in large measure the result of practices in the 20^th century when researchers purchased remains from individuals or companies (e.g., Watt’s, Carolina Biological, Ward’s, Clay Adams).  They also received “donations” and informally exchanged remains between institutions adding another level of complexity.  In addition, remains were brought from excavations, some carried out under permit in other parts of the world, others without such permission.   Many of those conducted in the US now fall under NAGPRA.

Some of the remains at Columbia may have come from prisons via the medical school or medical examiner’s office.  New York State law in the early 1800s allowed prisons to send the bodies of executed prisoners to medical schools for dissection.  In addition, until fairly recently, New York City law allowed the medical examiner’s office to transfer the bodies of “unclaimed” individuals to medical schools and teaching collections (though Columbia University ceased this practice prior to the revised legislation in 2016).  Unfortunately, Columbia did not keep records of these many of these remains, so piecing together the history are exceedingly complex.  Attempts to associate some of these individuals with Smithsonian holdings from medical research were not successful

Initial study of the archival records of Franz Boas (currently held in Philadelphia), and Duncan Strong (held primarily at the Smithsonian Institution), reveal limited information about a few individual skulls. During his tenure at Columbia, Boas was involved in expeditions to Canada and ran a field school in Mexico. Strong worked in the US and in South America. As such, remains that are likely indigenous to the Americas span the continent.  This paucity, indeed, near absence of records, greatly complicates the process of identifying provenance. 

There are a few limited exceptions, specifically, the remains from Duncan Strong’s Viru Valley Expeditions 1952-53, (currently in the care of the Department of Anthropology), and his On-A-Slant Village/Fort Abraham Lincoln excavations in 1947. The latter were stored at the American Museum of Natural History [AMNH] until the early 2000s when they were transferred to the Department of Anthropology. The faculty followed appropriate procedures culminating with the Inventory Completion Notice posted to the Federal Register (see here).

The other primary exceptions are remains that were purchased from major osteological suppliers in the 1960s and early 1970s.  These remains likely originated from India as part of the extensive bone trade at the time.  Though legally acquired, they are not viewed as ethically neutral, meaning that consent was not given.  The Indian government at present does not want the repatriation of the million-plus remains in global collections.  Current professional practice advocates for continued study of these remains with strict protocols until collections of ethically sourced remains can be established. 

II.   Compliance with the Native American Grave Repatriation Act [NAGPRA]

At present (as of 11/2025), Department E3B and the Department of Anthropology, have filed the necessary paperwork for all human remains of known Native American ancestry in their custodial care.  In 1990, Congress enacted the Act.  It requires institutions receiving federal funds to report any Native American human remains, associated or unassociated funerary objects, sacred objects, and objects of cultural patrimony that are held.  NAGPRA both acknowledges the rights of lineal descendants, Native American tribes, and Native Hawaiian organizations to the return of human remains and certain cultural items, and provides a mechanism to do this.  Lineal descendants, tribal chairpersons, or authorized NAGPRA representatives of federally recognized tribes can make claims under this act. 

NAGPRA Compliance Efforts Under the Department of Anthropology

As noted above, the remains that were transferred from the AMNH to Columbia’s Department of Anthropology were filed with the National Register. [see here]. The related tribes/nations were formally contacted again in 2023 to reiterate the University commitment to repatriation if desired.  No requests for repatriation have been submitted at this time.  Though not required by NAGPRA policy, we felt it was our ethical responsibility to obtain permission for continued non-invasive study of these remains.  When the Mandan representative (the lineal descendants for most of the remains), declined to give permission, we immediately complied with their request and these remains are not handled by students or faculty. These individuals were the only Native American remains of known provenance that the faculty were aware of at the time. 

NAGPRA Compliance Efforts Under Department E3B

Remains from the Dakotas 

*Note:  NAGPRA process conducted by E3B, filed under Anthropology, as discovery of remains took place at the time of transfer between departments.

As set out in the formal notice of inventory completion [see here], in the process of moving the osteology laboratory during the summer of 2023, a box containing a skull was found that was previously unknown to the University’s current faculty.  The remains were accompanied by a piece of paper with the sole notation “Dakota”, but it is uncertain what county or state the remains came from. Consultations were initiated with the 12 possible lineally affiliated recognized tribes/nations.  The notice of inventory completion was officially posted to the National Register in July 2025.  We await official request from the Sisseton-Wahpeton Oyate of the Lake Traverse Reservation (other respondents having deferred to them) so that we can initiate the return process.  We look forward to welcoming their representative to campus. 

[For those unfamiliar with the NAGPRA protocols, there might be curiosity at the length of the process.  According to federal policy, universities and museums must make multiple attempts via different modes to contact all appropriate parties. The first step involved research to identify all possible lineal descendants.  A formal letter is drafted that is reviewed and approved by the University General Counsel prior to certified, return-receipt mailing.  Groups may be given six or more months to respond to initial requests.  In the process, groups contacted might note other tribes/nations that should be consulted. When there is no response, subsequent letters are sent with an extended time frame, followed by emails and phone calls. Responses may be delayed for a variety of reasons, often because the tribes/nations cannot afford sufficient personnel to assist with all of the requests.  A record is kept of all attempts at outreach and communication, though according to NAGPRA policy it is not filed with that office.

Remains from San Nicholas Island

The remains (cranium) of a single adult individual from San Nicholas Island were identified serendipitously in the process of tracing remains from Rapa Nui. [see here] The latter were identified through an article published by Bruno Oetterking in Zeitschrift für Morphologie und Anthropologie in 1934. At the end of the article, there were photographs of the individual from Rapa Nui alongside a cranium identified as originating from San Nicolas Island, California.  Faculty recognized the individual from the custodial collection of Department E3B.  There are no records as to when or how or when these remains came to Columbia. It was not part of any known archaeological expedition.  

Research revealed that the island was home to the Nicoleño people, the last surviving member of whom passed in 1853.  Our initial search indicated that the Nicoleño people were probably related to the Tongva on the mainland.  Though this is not a certainty, we contacted the various groups who identify as Gabrieleño/Tongva.  During the process of formal outreach to these groups, it was brought to our attention that other groups including the Pechanga, Chumash and several bands of Luiseño Indians (all federally recognized groups) had claims to San Nicholas Island as well.  During the consultations with these groups, we learned that the US Navy now controls the island and that federal policy is that they take custodianship of any remains from the island and are responsible for completing the NAGPRA process.  The federally recognized tribes/nations involved concurred with this.  As such, Columbia does not file the official inventory.  We await the US Navy to arrange transfer of the remains. 

Remains transferred to the American Museum of Natural History [AMNH]

Archival research conducted as part of the inventory discussed below, identified eight skeletal elements that had been under the stewardship of the AMNH with numbers matching their records.  These including three crania and five individual elements (calcaneus, cervical vertebrae, fibula and mandible).  Several of the elements were identified as likely falling under NAGPRA.  It is not known how they came to Columbia.  In May 2025 Columbia formally transferred possession of them back to the AMNH.

III.  Revised NAGPRA Protocols & Inventory of the Collection

In 2024, the Departments of Ecology, Evolution and Environmental Biology and Anthropology, with the support of Arts and Sciences, undertook hiring a consultant with osteological and archival expertise to inventory the human remains in the custodial care of both departments.  Among the goals was to identify and reconstruct histories for individuals that would fall under the revised 2024 NAGPRA guidelines with respect to remains of Native American remains of unknown provenance. Additional goals included osteological assessment and archival research to try to trace provenience of all individuals including those who might be identified for domestic or international repatriation efforts.

The initial phase of the inventory and analysis was completed and a minimum* of 138 individuals identified.  As explained below, some of those individuals have since been repatriated, so the number as of 11/2025 is lower.  The majority are crania and skulls, along with innominates, complete pelves and individual bones.  There were seven complete or partial articulated skeletons.  With rare exception, the majority are adults.

 [*The MNI or minimum number of individuals is the standard practice in biological anthropology, bioarchaeology, forensics, and related fields, for estimating the size of an assemblage of remains.  All osteological elements are tallied and the most frequently occurring one helps to set the MNI.  For example, if there were two left femurs, the MNI would be two individuals.  As such, with many disarticulated remains (mostly purchased in the 1960s and 70s from the aforementioned Indian bone trade), it is highly likely that the collection includes the remains of many more unique individuals.]

As part of this inventory the ancestry and sex of individuals has been estimated but not determined.  With respect to remains that may fall under NAGPRA, this complex investigation is in progress and involves consultations with appropriate possible tribal representatives.  At this point in the process, it is not appropriate (and according to NAGPRA guidance, not permissible) to share information about the work except to those directly involved.   We can relay that the consultation process has started.   

In the meantime, the work of identification of all the remains in our custodial care is a long-term process that is ongoing.  Toward that end, a proposal to the University for funds to support additional archival research—a critical next step--is being developed.  The aim is to identify and repatriate as many individuals as possible, whether or not they fall under the revised NAGPRA regulations. 

Explanatory Note Concerning the Identification of Populational Affinity

The identification of populational affinity in biological anthropology, forensic, or bioarchaeological research is complex, imprecise, and fraught with controversy.  Debate concerns the undertaking as well as the methods.  Although some researchers (Bethard and DiGangi, 2020), view it as a “lost cause”, others (Klales et al. 2020) support the endeavor despite the serious limitations. Gene flow among human populations for the last hundreds of thousands of years make it impossible to circumscribe any one population.  As a result of the racial science of the late 1800s and early 1900s, and current reification of racial categories through genomics, many in the public at large are convinced that discrete biological populations of humans exist; they do not. 

In practice, the well known “categories” used in the US and elsewhere, are bound to socio-legal identity rather than geographic origin.  For example, Hispanic is a linguistic category (Spanish-speakers) yet is listed on the US census as an ethnicity and is often used as a “racial” identification.  Individuals of Hispanic identity can vary dramatically with respect to the extent of indigenous, African, and European ancestry.  High percentages of admixture are also present for Americans of African heritage, complicating attempts to assess populational affinity.  Given the limitations of both morphoscopic (visual assessment) and metric (e.g., FORDISC) analyses (when permissible), archival research is considered a primary tool for reconstructing the history of long-held remains, such as those in the care of Columbia and other universities. 

IV.  International Remains

The inventory identified remains originating from various countries that fall outside the scope of NAGPRA.  These include individuals from a range of localities including Mexico, Canada, Senegal (by way of Paris), Peru (probably), along with the already noted South Asian individuals.  It is likely that other remains originated outside of the United States but at present, there is no documentation to help clarify origins; it is hoped that archival work will help with this process. Our goal is to repatriate these remains as well, but at present, there is no official process/mechanism in place.  This is an issue for the field in general as researchers work toward developing best practices to identify and involve appropriate stakeholders. Our work in this area proceeds through collaborations with other scholars in the field and organizations such as the International Repatriation Network. 

Though not under legal obligation to repatriate, we view return of these remains as an ethical and moral necessity. Just as the University acted to return the remains from Rapa Nui when their origin was identified, [see here], we are committed to doing the same whenever possible. Currently, we are working with representatives of the Musqueam Nation, Canada, regarding remains that likely originate from the Marpole Midden in Vancouver. This site was on the ancient Musqueam village of c̓əsnaʔəm and was a sacred burial ground. Archival research identified letters that trace the sale of remains by Herman Leisk, to Franz Boas in the 1930s. Leisk, an amateur archaeological who worked at the site, removed the remains of many individuals for international sale.

V.  Ethical Protocols & Training

In January 2024 the University formally approval the current E3B Protocols for Studying Human Remains [see here]. The study of human remains is restricted to students in upper-level courses. These students must go through ethics training and agree in writing to the stipulations of this protocol.  The protocols and revised training are based on consultations with colleagues from peer institutions involved with similar issues.  The primacy of ethical issues is integral to analyses throughout the semester. Students taking courses such as Explorations in Primate Anatomy, which focus on non-human remains but who work in the osteology lab, must also go through ethics training and sign the protocols.   

An important modification to prior practice is that students in the introductory courses such Human Origins and Evolution, no longer have access to human skeletal remains in their labs but instead use casts.  Though our newest purchases are ethically sourced casts where consent was given (e.g., Maxwell collection), since older acquisitions may not be ethically neutral, they are still required to complete a more limited but no less important ethics training.  Students who miss this session must complete readings and an assignment prior to participation in any lab where human casts are present.  As with the laboratory setting, food and drink (save for water) are not permitted when casts of human remains are used in lab sessions and photography of these individuals is forbidden.  In addition, casts of human remains are no longer loaned for limited use either within Dept. E3B or to other departments unless proof of ethics training is provided.  The same holds for courses such as Biomechanics for the Dancer, which previously included a class session in the osteology lab.

VI.  Housing of Remains

The remains under the custodial care of Department E3B are housed in a secured location in Schermerhorn Hall.  The facilities are monitored 24/7 using a Ubibot sensor system to meet the professional standards with regard to temperature and humidity levels for human remains.  The remains are housed in museum quality cabinets; shelves and table surfaces are covered with neoprene padding for protection.  As noted in the protocols, food and drink (save for water) are prohibited in the osteology lab.  

In cases in which Native American descendants are known and remains will either remain in our care or await repatriation, we elicit and adhere to all requests for specific care.  These vary but include placing the remains in organic cotton bags, covering remains with red cotton cloth, providing tobacco and/or sage, water, etc.

VII.  Attempts to Create an Ethically Sourced Collection of Human Remains at Columbia

As stated above, our goal is to repatriate as many remains as possible to the appropriate individuals/communities/nations.  At the same time, it is our hope to build an ethically sourced collection of remains for study.  Discussions were initiated in 2024 with the faculty of Columbia’s Vagelos College of Physicians and Surgeons regarding their donation program and the prospect of expanding the donation process for long-term study. Although, the faculty was amenable, and thought it likely that some individuals or families of individuals would give consent, the endeavor is on hold as we have been unable to find a facility for the skeletonization process.  Outreach to colleagues across the country revealed that this is a common impediment and only a handful of universities provide space and support for this important work. 

VIII.  Looking Forward

It is important to note that the challenges that Columbia faces regarding the human remains in its custodial care are not unique.  The lack of documentation for collections created in the last century has left professionals in the field at a loss as to best practices for identification, disposition, and the possibility of continued use in education.  Members of the American Association of Biological Anthropologists [AABA], the leading professional organization in the field, have felt this acutely, leading to symposia at the recent annual meetings and ongoing working groups.  For example, in December 2025, the AABA will hold a webinar entitled, Tracing Forgotten Histories: Identifying Unprovenienced Human Skeletal Remains and Establishing Best Practices for their Ethical Treatment.  Events such as this underscore the widespread nature of the problem and the complexity of the undertaking. 

We will continue to work diligently with colleagues and organizations (domestic and international) with the hopes of repatriating as many individuals as possible to the appropriate stakeholders. The Department and the University do not take the responsibility for the care of the individuals in our custody lightly.  We see it as integral to our professional and personal ethics as well as to our academic mission.