As exemplified in Hawaii, the process of obtaining permits for introducing and releasing imported biological control agents can be an arduous exercise in negotiating complex bureaucratic obstacles. The interactions between State and Federal bureaucrats only complicates the process further. An IOBC "Best Practices Certificate" has the potential, in some ways, to help cut through this miasma, but as in many well-intentioned proposals there is also the possibility of unintended consequences. The devil is very much in the details; in order to broadly consider a "Certificate" from the widest perspective, it therefore behooves us to have someone play devil's advocate.