Frequently Asked Questions

The discipline of Anthropology, and thus the Museum, was founded on the practice of collecting cultural heritage and ancestral remains, but in ways that viewed and treated Indigenous peoples as “study-subjects.” Acknowledging and confronting the history of anthropology and museum practice that had its roots in settler colonialism and imperialism both in the United States and around the globe is essential to changing what anthropology museums are.

Most of the collections arrived at the museum during the late nineteenth and early twentieth centuries through archaeologists, academics, and others, who sought to understand “America’s past” through large-scale excavations. Some of these efforts were supported by the Federal government, and the Antiquities Act of 1906 specifically directed that universities and public museums were the repositories for these collections. Harvard was at the center of American archaeology and among the most frequent recipients of collecting permits at that time. Therefore, the collection grew with the growth of anthropology, an academic discipline. For more information, please see NAGPRA at the Peabody.

A good place to start is a local Tribal Museum or Tribal administrative office. The National Association of Tribal Historical Preservation Officers (NATHPO) may also be able to provide advice.

Yes and in fact, NAGPRA was not the first repatriation law passed by Congress. The National Museum of the American Indian Act of 1989 (amended 1996) formed the National Museum of the American Indian at the Smithsonian Institution and provided a repatriation framework for all Smithsonian Museums. This law applies only to Smithsonian Museums, so NAGPRA was enacted the following year to apply to Federal agencies and museums and universities that receive funding from the federal government.

The Museum provides travel funding for Tribal representatives to come to the museum for the physical repatriation of ancestors and associated funerary belongings under NAGPRA. Unfortunately, the museum is unable to financially support travel and expenses related to consultation visits and other types of repatriation visits. Federal grants are available to support consultation/documentation and repatriation. For collections outside of the NAGPRA, the Association of Tribal Archives, Libraries, and Museums has the “Going Home Fund” to help fund the return of culturally sensitive items. The museum is happy to provide letters of support for Tribal Nations and Indigenous communities applying for these grants.

NAGPRA requires the Peabody Museum and other museums to repatriate Native American human remains, funerary objects, objects of cultural patrimony, and sacred objects. The statute, along with subsequent administrative regulations, sets forth a detailed administrative process that museums must follow, including the inventorying of relevant holdings, communications and consultations with Indian Tribes, publication of notices in the Federal Register, and eventual transfer of human remains and cultural items to lineal descendants or Tribal Nations. Details of the statute, regulations and process is available at National NAGPRA, National Park Service, U.S. Department of the Interior. To learn more about NAGPRA please visit National NAGPRA’s training website page and their Frequently Asked Questions website page.

Most of the collections arrived at the museum during the late nineteenth and early twentieth centuries through archaeologists, academics, and others, who sought to understand “America’s past” through large-scale excavations. Some of these efforts were supported by the Federal government, and the Antiquities Act of 1906 specifically directed that universities and public museums were the repositories for these collections. Harvard was at the center of American archaeology and among the most frequent recipients of collecting permits at that time. Therefore, the collection grew with the growth of anthropology, an academic discipline. For more information, please see NAGPRA at the Peabody.

Research and teaching on collections under NAGPRA is only permitted with approval from authorized Tribal representatives. In October 2021 the museum implemented a new Research Policy for Human Remains and Associated Funerary Objects Under NAGPRA for all NAGPRA collections. The policy aims to encourage knowledge generation in a manner founded on respect for, and in partnership with, descendant communities, in line with the museum’s broader commitment to ethical stewardship.

Under NAGPRA, the number of ancestors is described by the term “minimum number of individuals” which is estimated using catalog records in the museum’s database. Determining the actual number of individuals can be challenging as different skeletal elements from the same individual may have been assigned different catalog numbers in the past. This is particularly true for individuals from complex archaeological contexts. An explanation of definitions used in the NAGPRA legislation can be found on the National Park Service NAGPRA Glossary.

The museum’s Federal Register Notices can be found on our Published Notices page. As of June 1, 2023, the university has published 205 Federal Register Notices and returned 4,309 ancestors and more than 10,000 funerary belongings, sacred objects, and objects of cultural patrimony from 35 states. To date, more than 250 Tribal Nations have completed NAGPRA repatriations at the Peabody Museum. 

The Harvard Corporation has delegated decision-making for NAGPRA to the Peabody Museum director. The NAGPRA Advisory Committee provides critical guidance to the director on all aspects of NAGPRA implementation.

Each NAGPRA request is distinct and the time to effect repatriation through the NAGPRA process varies widely. The foundation of the NAGPRA process is respectful consultation, and staff aim to be responsive and sensitive to Tribal timelines and priorities.

The Federal Register is published daily by the National Archives and Records Administration and is the “official newspaper” of the U.S. Federal Government. When a repository determines the appropriate lineal descendant or Tribal Nation culturally affiliated to the ancestors or cultural items, a Federal Register Notice is published. Ancestors and associated funerary belongings are published in a Notice of Inventory Completion, while unassociated funerary belongings, sacred objects, and objects of cultural patrimony are published in a Notice of Intent to Repatriate. In some cases, a correction notice will be published to update information provided in the initial notice. Publication in the Federal Register is required under NAGPRA and provides an opportunity to publicly announce a repatriation decision. An explanation of definitions used in the NAGPRA legislation can be found on National Park Service NAGPRA Glossary.

The staff is continually engaged in consultations and is working to accelerate its work through proactive outreach to Tribes across the Nation. In Fall 2022 the Museum announced the "Disposition Project" which is a 3-year commitment to complete the Federal Register Notices for ancestors and their associated funerary belongings. The Museum has hired new staff more than doubling the number of people focused on implementing NAGPRA. The university now has one of, if not the, largest museum staff dedicated to NAGPRA in the country.

Our 3-year commitment is to transfer legal authority, control, and decisions about all ancestors and their associated funerary belongings to Tribal Nations. This commitment centers on Tribal consultation and follows the process outlined in the NAGPRA regulations.  Ancestors may remain on the Harvard campus after this time as Tribes, on their own timeline, make plans for bringing ancestors home.

Once the notice period of 30 days has ended, if no other claims have been made, the Peabody will transfer control of the items to the intended tribe(s), regardless of whether physical transfer is possible at that time. Peabody staff will continue to care for the items according to the wishes of the tribe(s) until they can be physically repatriated.

If certain facts in a published Federal Register notice change prior to the repatriation or transfer of the human remains or cultural items, the museum must draft a correction (or “amendment”) notice. Amendment notices are used to change:

• the number of human remains,
• the number of associated funerary objects,
• the number of other cultural items, or
• the cultural affiliation or aboriginal land determination.

For NAGPRA related questions, please email pmnagpra@fas.harvard.edu- this inbox is closely monitored by our NAGPRA team daily. Meet the team doing this work on Getting Started.

Yes, the museum returns ancestral remains outside of NAGPRA. Following the recommendations of the Hammonds Report, the museum is working with the Human Remains in the Harvard Museum Collections Returns Committee to establish criteria that defines ancestral remains ineligible for use in academic research and education at the university, and provide direction for the university to implement interment, reinterment, return to descendant communities, or repatriation of remains as needed.

Yes, the museum returns cultural items outside of NAGPRA. In September 2022, Harvard created general guidance on the University’s approach to return requests under the Provost's policy for Considerations of Claims for the Return of Items in Harvard University Collections. This document supports new policies and procedures for the return of cultural items from the Peabody Museum. The University’s Human Remains in the Harvard Museum Collections Returns Committee oversees the return of ancestral remains. For more questions, please contact pmreturns@fas.harvard.edu.

We welcome requests from origin communities, descendant communities, Indigenous nations, and national governments. Requestors are asked to include documentation of cultural affiliation (a relationship of shared group identity) or, when a request is not made by an origin or descendant community, documentation that they have the legal standing and authority to make a claim. Ideally, requests are made by the recognized official representative of the community governing body, nation, or state for such matters (e.g., Tribal chair, elected or appointed community leader, etc.).

There may be many reasons why cultural items currently in the Peabody Museum’s care should be returned to descendant communities. For example, reasons could include circumstances surrounding an item’s acquisition by the Museum such as forced or coerced sale, military or political violence, looting, theft, or other use of force and/or coercion on the part of the collector; removal from the origin community via misrepresentation or under protest. Other reasons speak to the inalienability of certain cultural items that should not have been sold, traded, or otherwise disposed of by an individual. Additionally, there are situations in which an item’s removal from the origin or descendant community had and continues to have a detrimental effect on cultural practices or spiritual wellbeing of a community and the return of a cultural item best serves the culturally responsive care of both the community and cultural item, regardless of the circumstances of acquisition.

For the sake of all possible claimants, the process is necessarily one of careful assessment, due diligence in provenance research, and thoughtful deliberation that can be time consuming and complex. Thorough provenance and the establishment of a relationship are key components to requests for the return of cultural items. In making a decision to return, the Museum seeks to fully understand the history of the item, the circumstances of its removal from the origin community, and the path the item took through time as it made its way to the Peabody. Through this information, which is always assessed via consultation with the requestor, we work to establish the requestor’s relationship to the item and the ways in which the community and the item itself are better served through repatriation. Once information and sources have been compiled and discerned, the request can move forward through the review process.

Requests are formally acknowledged upon receipt and reviewed by designated Museum staff. The review process consists of three stages: 1) an initial review of the cultural item being requested, the requestor’s reasoning and relationship to the cultural item, and any associated documentation; 2) review by Museum advisory committees that provide recommendations to the Museum’s Director; and 3) administrative review and issuing of a final decision, usually by the Provost of the University.

For the sake of all possible claimants, the process is necessarily one of careful assessment, due diligence in provenance research, and thoughtful deliberation that can be time consuming and complex. In some cases, additional information may need to be identified, requested, and compiled during the evaluation and review stages, and available resources may limit the pace at which this important work progresses. In all steps, the Peabody’s goal is to achieve a thoughtful outcome framed by our firm commitment to ethical stewardship and community partnership.

Decisions on returns are made on a case-by-case basis once we receive a request. The museum works closely with the requesting community to fully understand their goals and to undertake provenance research. Investigating the history of a specific item, and the path it took before arriving at the museum, provides important information that can benefit all possible claimants. Discussions can take time and, depending on the wishes of a requesting community, decisions may not be made public immediately.

For more information on the returns process and to begin a claim, please contact us at pmreturns@fas.harvard.edu. This email is continually monitored by staff and we will reach out to provide additional guidance and information about required elements of a claim submission, to answer questions around process, and to help with access to collections and related documentation.

In developing its approach, the Peabody takes guidance from the following Harvard University and Peabody Museum policies: 

• Peabody Museum Ethical Stewardship 
• Consideration of Claims for the Return of Items in Harvard University Collections (September 2022) 
• Harvard University Report of the Steering Committee on Human Remains in University Museum Collections (Fall 2022) 

This policy operates within national and international legal contexts concerning issues related to cultural property: 

• United States Antiquities Act of 1906 
• Archaeological Resources Protection Action Act of 1979 
• UNESCO Convention on the Means of Prohibiting and Preventing the Illicit Import, Export and Transfer of Ownership of Cultural Property (14 November 1970) as implemented in the United States via the Convention on Cultural Property Implementation Act of 1983 

In addition, the Peabody Museum adheres to the American Alliance of Museum’s Code of Ethics (1993, amended 2000), which specifically states that such claims, “… should be handled openly, seriously, responsively and with respect for the dignity of all parties involved.” The museum fully commits to undertaking appropriate and respectful due diligence in evaluating all such claims, and to the transparency of its process in considering requests. 

We welcome requests around archival repatriation. These requests will be considered under the eligibility criteria outlined in the Claims for Returns of Cultural Items policy.

No research is permitted on ancestors covered under NAGPRA unless authorized Tribal representatives have granted permission. The museum is working with the Human Remains in Harvard Museum Collections Research Review Committee on policies that will guide the University in reviewing all research requests and establish criteria that define permissible uses of some ancestral remains in Harvard collections in research and education. All such research requests are reviewed by the Committee.

The museum did not publicly release details of individuals in response to early requests from several tribal nations. 

As part of phase one, we contacted more than 300 Tribal Nations and received some early feedback with concerns about publishing the list of names on our website. To be responsive to this feedback, we did not publish the names. We instead sent lists of individuals to Tribal leaders to allow time for Tribal Nations to receive and review this difficult information. Since this initial outreach, many Tribal officials have reached out to the museum for more information resulting in personal calls and email communications. 

We recognize that ‘hair samples’ is an imperfect term. We use it, however, to maintain consistency with publications and museum records, and because we were not able to identify an appropriate alternate term. The term ‘hair samples’ in this context means clippings of hair from the head. While the amount of hair collected from individuals varies, on average the clippings of hair are between three to six inches long and range from just a few strands to a few dozen strands of hair. We recognize that the length or amount of hair does not minimize the impact of its collection. Woodbury also prepared approximately 300 individual glass slides from this set of hair samples. To make the glass slides, a strand of hair was encapsulated in resin and then a slice of that was used on the slide to view under a microscope. The collection also includes these approximately 200 pieces of resin.

The clippings of hair are located within the historical envelopes prepared by George Woodbury with the information provided to him by the initial collectors. This information often included age, sex, degree of blood, ethnic group, and name of individual. In our communications with families and Tribal Nations, we are honoring requests for spiritual and traditional care. 

The other parts of the collection also includes hair collected from individuals at hospitals in Canada, as well as from individuals in Asia, Central America, South America, and Oceania. Further information will be shared as soon as possible together with any additional details we learn about their provenance. 

More on the details of this collection and its history of access at the museum are available on Summary of Research on the Collection.

If you are a representative of a Tribal Nation or potentially a lineal descendant looking for the historical documentation about this collection, please email us at pmreturns@fas.harvard.edu. 

On November 30, 2022, after review, the Department of the Interior informed the museum that the collection is subject to the Native American Graves Protection and Repatriation Act (NAGPRA). We are working with the Department of the Interior’s National NAGPRA Program on implementation of the NAGPRA process with respect to the Woodbury Collection. The museum and the Department of the Interior are committed to a partnership with the aim of a respectful, effective, and efficient returns process, while still following the requirements of the regulations.   

The current process for returns can be found on Returns through NAGPRA.

Tribal affiliations have been directly transcribed from records taken by collectors in the 1930s. The listed tribal affiliations are a product of those collectors, whose own bias or ignorance may have resulted in misspellings or offensive or racist terminology. Collectors were not Woodbury himself, but rather Federal agents, administrators, teachers, and other people who Woodbury reached out to with his request for hair samples.