Ivory Keytop Regs
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Dear Colleagues,

I'm forwarding some background information on proposed Federal regulations on all sales of ivory, products with ivory components, such as ivory keytops in pianos.

A complex issue, one with implications for our small world of piano keyboards...... Enclosed below is a thoughtful discussion by Art Reblitz, which he posted to the Mechanical Music Digest.

Learning the context of recently expanded poaching and slaughtering elephants to fill a new high demand of their tusks is in order.

Personally, I would be very happy to never have to deal with restoring old ivory keytops again!

Best wishes,
Bernard Mollberg
Mollberg Piano Restoration, LLC
753 Divide Pass
Blanco, TX 78606-5518
830 833-2210

Ivory substitutes compared against Broadwood keyboard

From: orchestrion@comcast.net  (Art Reblitz)
To: Mechanical Music Digest <
rolls-1201@mmdigest.com >
Date: Sun, 13 Apr 2014 18:44:38 -0600

Subject: Ivory Transport & U.S. Fish & Wildlife Services

    The new ivory regulations also extend to interstate and intrastate
    moves within the U.S.A.  As the regulations are written now, it seems
    it will be legal to own a piano with ivory keytops, but not legal to
    sell one unless you can prove that it's over 100 years old, the keytops
    are original to that piano, and you have a CITES certificate stating
    this.  However, there is a temporary hold on enforcement (see below).
    If you don't read this entire message, please read at least the last
    three paragraphs.

    In the last year, a Piano Technicians Guild (PTG) member in the Chicago
    area spent months trying to get a Boesendorfer grand certified with its
    original keytops but failed because Fish & Wildlife said there was no
    way to prove that they were original.  Consequently, she replaced them
    with plastic.

    Piano Technicians Guild officials and about 30 other organizations have
    signed a letter of concern that was sent to the House Ways and Means
    Chair.  They've also been in dialogue with the two largest pipe organ
    technician organizations to consider lobbying strategies since the PTG
    and pipe organ groups have similar interests.  The PTG plans to publish
    an article on the subject in its May Journal.  The board of AMICA is
    also aware of this and will be kept informed.

    I sent a list of specific questions to the PTG, who included them in
    their communication with Fish & Wildlife.  These include things like
    "How does someone prove ownership of a piano that is being moved to
    a repair shop but not sold," "Will it be legal to give a piano to
    someone in another state," and "What is a repair shop supposed to do
    with ivories removed from an old uncertified piano when replacing them
    with plastic?"

    The PTG president also told me this:

    "The intent of the language was not to make criminals out of piano
     owners, so they have placed a temporary hold on enforcement of the
     new rules which were scheduled to take effect in June.  The purpose
     of the temporary hold is to come up with a set of rules specifically
     for keyboard instruments.  There will be a publication of a proposed
     set of rules at which time there is a window for public comment on
     the rules to potentially amend them.  I am committed to making those
     rules public to our PTG membership as well as publicizing the dates
     for the commentary period so our members can weigh in with their
     opinions to the correct public officials who will be deciding the
     ultimate outcome of the issue."

    It might be a good idea to wait until representatives of the
    organizations who have signed the letter of concern learn something
    definitive before acting as individuals.  This might prevent a lot of
    hearsay from getting into circulation before actual rulings are made
    on exemptions, enforcement, etc.

    Also, it will be wise to refrain from circulating inflammatory,
    politically-charged statements against the regulations, because their
    fundamental purpose -- preventing more harm to living elephants -- is
    honorable.  The question is whether destroying old ivory artifacts will
    reduce or increase demand for illegal poaching.  The answer remains to
    be seen.

    Here's another thought for all to consider: from now on, when
    discussing ivory in a piano, use the term "ivory keytops" rather than
    "ivory keys".  If enforcement does take place, we don't need to have
    poorly-informed Fish & Wildlife agents destroying whole keyboards or
    pianos because they didn't know the keys are made of wood with only
    a thin layer of ivory on top, which can be removed without destroying
    a whole instrument.

    Art Reblitz - 40-year RPT member of PTG
    Colorado Springs, Colorado

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