Living Collections, Lax Ledgers: Auditing How US Zoos and Botanical Gardens Account for Psychoactive Plants

Botanical collections are repositories of chemistry. Among the orchids and oaks, accredited US zoos, arboreta, and conservatories grow plants that indigenous cultures have used as sacraments for centuries — Salvia divinorum, Ipomoea tricolor, Banisteriopsis caapi, Lophophora williamsii. When news broke that a salvia specimen at the Memphis Zoo had become the subject of an internal review, the story prompted a question the zoo world has largely avoided: are these living collections secured, inventoried, and governed by anything more rigorous than a curator's memory?

The Regulatory Mosaic

The answer, perhaps unsurprisingly, is a patchwork. Under the Controlled Substances Act, only peyote (Lophophora williamsii) occupies a schedule of its own — Schedule I — and even then exemptions carve out specific religious and, in some states, research contexts. Salvia divinorum is federally unscheduled, though more than a dozen states restrict it. Banisteriopsis caapi, the ayahuasca vine, is unregulated federally despite containing DMT-producing potential in combination with companion plants. Morning glory seeds occupy an ambiguous shelf: the plants are legal ornamentals; the intentional extraction of lysergamide analogs from their seeds is not.

This means the DEA's oversight of a zoo's psychoactive flora ranges from direct (peyote) to nonexistent (salvia, in most states). The agency regulates possession of controlled substances — but a cactus on a greenhouse bench is not a vial in a cabinet, and enforcement attention has historically followed the latter.

What AZA Standards Do — and Don't — Say

Association of Zoos and Aquariums accreditation is the field's gold standard, but its standards address hazardous animals, controlled veterinary drugs, and perimeter security. Psychoactive botanicals do not appear as a distinct category. Collection management policies are left to institutions, which produce results of wildly varying rigor: some zoos label nothing, some display interpretation panels noting traditional uses, and a handful maintain internal restricted-lists requiring dual sign-off for propagation or transfer.

The risks are correspondingly diffuse. A visitor clipping a cutting. A volunteer propagating a species without understanding its status. An animal in a mixed-species exhibit browsing foliage with serotonergic activity. None of these scenarios has produced a documented public crisis in the US — a fact that is either reassuring or, depending on whom you ask, evidence that no one is looking.

Toward a Model Policy

Several elements of a workable framework already exist in fragmentary form. Herbaria with controlled-taxon policies offer one template: restricted access, accession records tied to each specimen, and de-accession documentation. Zoo pharmaceutical protocols for opioids and ketamine offer another: inventoried quantities, audit trails, and named custodians of responsibility.

Synthesized, a model policy for living entheogenic collections might include: a written institutional list of psychoactive taxa; accession-level tracking with photos and location data; horticultural staff training on legal status by state; signage and interpretation that treats these plants as ethnobotanical heritage rather than contraband; and a standing relationship with legal counsel for navigating the state-by-state maze.

Collections as Curriculum

There is a countervailing argument worth taking seriously: that these plants belong in public view precisely because they are culturally and scientifically significant, and that hiding them reproduces stigma while doing little to reduce risk. The Memphis episode should not push institutions toward glass cases and secrecy, but toward governance — the same sober accounting zoos already apply to every other hazard in their care.

A psychoactive plant in a living collection is neither a drug stash nor a mere ornamental. It is a specimen with a legal status, a biochemistry, and a human history. Treating it as all three is the minimum standard of stewardship an accredited institution owes its animals, its staff, and its visitors.