POL-U2100.06 Complying With Native American Graves Protection and Repatriation Act (NAGPRA)
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Dates and Approval
Effective Date:
January 27, 2026
Approval Date:
January 23, 2026
Approved by:
President Sabah Randhawa
Who does this policy apply to?
This policy applies to all members of the campus community who have possession or control of Native American cultural items, including human remains, funerary objects, sacred objects, and objects of cultural patrimony for employment and educational activity related purposes.
Overview
This policy establishes institutional oversight and compliance with the Native American Graves Protection and Repatriation Act, 25 U.S.C § et seq. and its companion regulation at 43 C.F.R, Part 10 (collectively referred to as NAGPRA). NAGPRA guides the disposition of Native American and Native Hawaiian cultural items and human remains under the control of federal agencies and institutions such as Western Washington University (WWU) that receive federal funding.
WWU is committed to complying with NAGPRA and to working with lineal descendants, traditional religious leaders, and Native American and Native Hawaiian organizations, both federally and non-federally recognized, with respect to determinations of cultural affiliation and repatriation of Native American and Native Hawaiian human remains, funerary objects, sacred objects, and objects of cultural patrimony in the University’s possession or control. WWU is also committed to ensuring that all such human remains, funerary objects, sacred objects, and objects of cultural patrimony that are in its possession or control are appropriately identified and treated with respect during that process.
Definitions
Campus Community
University employees, including but not limited to adjunct and clinical faculty, visiting faculty, and postdoctoral appointees; visiting scientists and scholars, and students engaged in research or scholarship conducted in campus facilities or at off-campus locations.
Cultural Items
Collectively, funerary objects, sacred objects, and objects of cultural patrimony as defined under NAGPRA.
Funerary Objects
Any object reasonably believed to have been placed intentionally with or near human remains, and connected, either at the time of death or later, to a death rite or ceremony of a Native American culture.
Human Remains
Any physical part of the body of a Native American individual.
Native American
Of, or relating to, a tribe, people, or culture that is indigenous to the United States.
Objects of Cultural Patrimony
Objects having ongoing historical, traditional, or cultural importance central to a Native American group, including any constituent sub-group (such as a band, clan, lineage, ceremonial society, or other subdivision), according to Native American traditional knowledge. These objects must be reasonably identified as being of such importance central to the group that it cannot or could not be alienated, appropriated, or conveyed by any person, including its caretaker, regardless of whether the person is a member of the group, and must have been considered inalienable by the group at the time the object was separated from the group.
Sacred Objects
A specific ceremonial object needed by a traditional religious leader for present-day adherents to practice traditional Native American religion, according to Native American traditional knowledge. This term is specifically limited to an object needed for the observance or renewal of a Native American religious ceremony.
Policy Statements
1. Provost Oversees Compliance with NAGPRA
The Provost is responsible for overseeing the University’s compliance with NAGPRA and will commit the necessary resources to ensure that Native American cultural items, including human remains, funerary objects, sacred objects, and objects of cultural patrimony subject to NAGPRA are curated and repatriated in a respectful, dignified, and legally compliant manner.
Under the purview of the Provost, the day-to-day compliance operations are delegated to the NAGPRA Program and Collections Manager (hereinafter NPCM), who serves as the main point of contact regarding NAGPRA compliance and related inquiries.
The NPCM works with the NAGPRA Advisory Committee to oversee the University’s compliance with NAGPRA. This includes, but is not limited to, evaluation of Native American human remains, funerary.
2. Teaching with, Displaying, or Storing Objects Subject to NAGPRA Requires Advanced Approval
WWU employees must obtain advanced written approval from the NPCM before teaching with, displaying on campus and/or during courses or storing objects or items that are subject to NAGPRA.
WWU employees who possess or become aware of items or objects that may be subject to NAGPRA at the university are required to contact the NPCM for an evaluation, PR0-U2100.06, Evaluating Cultural Items for NAGRPA Eligibility and FRM-U2100.06, Request for an Evaluation of Cultural Items for NAGPRA Eligibility Form.
This requirement applies regardless of if the collection is in the possession, control, or custody of WWU. WWU is a federally funded institution and subject to NAGPRA, thus even privately owned collections used, displayed, or stored on campus are subject to this regulation.