0178 ss ren 080907

SUPPORTING STATEMENT
MARINE MAMMAL STRANDING REPORTS/
MARINE MAMMAL REHABILITATION DISPOSITION REPORT
OMB CONTROL NO.: 0648-0178
A. Justification
1. Explain the circumstances that make the collection of information necessary.
Under the Marine Mammal Protection Act (MMPA) Section 402, the Secretary of Commerce
(Secretary), who has delegated responsibility under this Act to the National Oceanic and
Atmospheric Administration (NOAA) Assistant Administrator for National Marine Fisheries
Service (NMFS) is responsible for collecting information on strandings which the Secretary will
compile and analyze, by region, to monitor species, numbers, conditions, and causes of illnesses
and deaths of stranded marine mammals. The Secretary is also responsible for collection of
information on other life history and reference level data, including marine mammal tissue
analyses, that would allow comparison of the causes of illness and deaths in stranded marine
mammals with physical, chemical, and biological environmental parameters.
Specifically, the collection of this information is authorized and mandated under three provisions
of the MMPA. Under the MMPA, the Secretary is charged with the protection and management
of marine mammals. In addition, determinations must be made on the sustainability of
population stocks, on the impact of fisheries and other human activities on marine mammals and
endangered species, and on the health of marine mammals and related environmental
considerations. NOAA, NMFS has the responsibility to carry out these mandates.
Section 402(b) of the MMPA (16 U.S.C. 1421a) requires the Secretary to collect and update
information on strandings. It further provides that the Secretary shall compile and analyze, by
region, the species, numbers, conditions, and causes of illnesses and deaths in stranded marine
mammals. Section 404 (a) of the MMPA (16 U.S.C. 1421c) mandates that the Secretary respond
to unusual marine mammal mortality events. Without a historical baseline provided by marine
mammal information collected from strandings, detection of such events could be difficult and
the investigation could be impeded. Section 401 (b) of the MMPA (16 U.S.C. 1421) requires
NMFS to facilitate the collection and dissemination of reference data on the health of marine
mammal populations in the wild and to correlate health with physical, chemical, and biological
environmental parameters. In order to perform this function, NMFS must standardize data
collection protocols for health and correlations. Data and samples collected from stranded
animals are a critical part of the implementation of this mandate of the MMPA.
Specifically, the data from the Marine Mammal Stranding Report forms provide NMFS with
information on the morphology, life history, biology, general health, health and stranding trends,
causes of mortality, and distribution of marine mammal species. These data provide reference
information necessary to detect epizootic diseases such as the one implicated in the bottlenose
dolphin die-off in 1987-88, the leptospirosis outbreak in California sea lions in 1984, and the
morbillivirus epizootic in bottlenose dolphins in the Gulf of Mexico in 1994. These data also
provide information which may help in making assessments on the status of population stocks.
Recording data on gross mortalities may serve as an indicator that a particular population is
impacted, threatened or at increased risk, and when provided in a timely manner, may aid in
dynamic management practices. Changes in sex ratios, age composition, or age at sexual
1

maturity may also indicate stressed populations and can be detected with stranding data.
Stranding data also provide an important baseline for detecting and monitoring the impacts of
environmental phenomena, such as El Niño, seen in California sea lions and gray whales in
1998, and Harmful Algal Blooms (HABs) such as domoic acid (repeatedly detected in
California) and brevetoxin or red tide (seen most recently in the 2004 bottlenose dolphin die-off
along the Florida Panhandle).
Stranding records can be a tool for alerting management personnel to changes in incidental
mortality of marine mammals due to human activities such as fisheries by-catch. Evidence of
significant harbor porpoise mortalities due to gill net fisheries off the mid-Atlantic coast was
provided by the Stranding Network in early 1993. This provided fishery managers with clues to
seasonal and geographical information on fishery impact. Information obtained from strandings
can also provide indications of enforcement problems. As an example, in March 1993, large
numbers of dead pinnipeds washed in on the central Washington coast. Stranding Network
information provided proof that over half of the animals had been shot.
Registration of tissues retained from strandings is mandatory under 50 CFR 216.22(c). With
limited exceptions, the MMPA prohibits the purchase or sale of marine mammals or marine
mammal parts. It also prohibits the possession of marine mammals or marine mammal parts
taken in violation of the Act. In order to provide adequate enforcement of the Act while still
allowing legitimate activities, it is necessary to document the inventory of tissues that are legally
held. The Marine Mammal Stranding Report form provides information which may be used for
registration of marine mammal parts taken under stranding authority and for tracking of such
legally obtained samples. The use of these forms assists us in standardizing this procedure.
The Marine Mammal Rehabilitation Disposition Report provides NMFS with information on the
disposition of animals brought in for rehabilitation, the success of medical treatment, and the
number of animals released. This information will assist the Agency in tracking marine
mammals that move into captive display and in the monitoring of rehabilitation and release.
These data will also be used to assess the burden on stranding network centers. This form will be
filled out only in the case of live-stranded marine mammals. The form will be required in all six
NMFS Regions. Each of the NMFS regions approves and issues a Stranding Agreement or other
form of agreement to marine mammal rehabilitation centers under §112(c) of the MMPA, which
allows the Secretary to enter into agreements in order to fulfill the general purposes of the Act,
and under §403 of the MMPA, which provides specific authority to enter into such stranding
response agreements. These data will be monitored as part of the Rehabilitation Facilities
Inspection program to be implemented in 2007.
Under MMPA section 104(c)(10) [16 U.S.C. 1374(c)(10)], NMFS is required to maintain an
inventory of live marine mammals held under permits for rehabilitation or captive display. The
data in the Marine Mammal Rehabilitation Disposition report are required to monitor and track
animals during rehabilitation and during transfer to permanent-captive status licensed under 7
U.S.C. 2131 et seq. For public display facilities, which participate in the program as a
rehabilitation center, reporting becomes a critical record if the animal is retained and put on
display. If that happens, reporting requirements transfer to that mandated under OMB Control
No.: 0648-0084.

2

2. Explain how, by whom, how frequently, and for what purpose the information will be
used. If the information collected will be disseminated to the public or used to support
information that will be disseminated to the public, then explain how the collection
complies with all applicable Information Quality Guidelines.
The Marine Mammal Stranding Network (Network) is made up of individuals authorized by
NOAA Fisheries [i.e., via Stranding Agreement or another official agreement under §112(c) of
the MMPA which allows the Secretary to enter into agreements in order to fulfill the general
purposes of the Act] to collect scientific data and specimens, record information on stranding
events with the NMFS Regional Coordinator, and assist local and Federal authorities in the
response to stranded marine mammals under §109(h)of the MMPA. They are also authorized in
assisting with detection and investigation of marine mammal mortality events. The majority of
Network members are affiliated with academic institutions, aquaria, rehabilitation centers, or
state, federal, and local agencies. Members are requested to submit basic data on all strandings
including date and location, species, condition of animal, sex of animal, length, disposition of the
animal and tissues or specimens, and any personal observations. The Network members will
complete the stranding form as part of their immediate response and forward the form to the
NMFS regional coordinators in a timely manner, as specified in the Stranding Agreement. NonGovernmental members of the Network are exempted from the prohibition on taking marine
mammals through the issuance of a Stranding Agreement under §112(c) of the MMPA, which
allows the Secretary to enter into agreements in order to fulfill the general purposes of the Act,
and under §403 of the MMPA, which provides specific authority to enter into such stranding
response agreements. Researchers may also obtain tissues from stranded marine mammals
through the Network. The Stranding Agreement relieves scientists and responders of the
cumbersome process of applying for scientific research permits, but researchers must obtain an
approval letter from the NMFS Regional Office, signed by the Regional Administrator,
authorizing such collections.
Stranding network participants benefit by gaining access to information, data exchange and
tissue samples, which might otherwise not be available. Analyses of tissues from strandings
by the Network and research laboratories have significantly contributed to the body of
knowledge on which management decisions are made and enhanced our understanding of
marine mammal health. Non-scientists participating in the Network receive the satisfaction of
aiding wildlife, enhancing wildlife conservation, and furthering scientific understanding of
these species. Stranding network members also provide important expertise and involvement
in Unusual Mortality Event (UME) investigations, when an unusual number of animals are
found stranded and an official investigation is launched to determine the factors involved.
As indicated above, the information is used by the Agency in making resource management
decisions and in fulfilling responsibilities under the MMPA. In addition to detecting serious
pathogens, diseases, pollution loads, evidence of anthropogenic impacts on marine mammals,
investigations into UMEs, and providing life history information about marine mammal stocks,
records of mortalities due to fishery by-catch are used in implementing the fisheries management
regime in §118 of the MMPA. This mandates that mortality levels be below the potential
biological removal level of the marine mammal stock. As an example of the value of such
information, stranding reports alerted the Agency to a potentially serious interaction between
harbor porpoise and coastal gillnet fisheries in the Mid-Atlantic region. In addition, the Agency
is continuing to monitor strandings in the Mid-Atlantic to guide observer placement on fisheries.
3

Prior to the receipt of stranding information, NMFS was unaware of the problem.
Section 118 of the MMPA generally provides that Take Reduction Plans be developed through
Take Reduction Teams for strategic stocks of marine mammal that interact with Category I
fisheries (those with frequent incidental mortality and serious injury of marine mammals) and
Category II fisheries (occasional incidental mortality and serious injury of marine mammals).
The data provided by Marine Mammal Stranding Reports may be used by the Take Reduction
Teams to identify gear types, seasons, and geographical locations in which fisheries impact
marine mammals.
Summaries of stranding data are provided to Congress, the media, and the public in the NMFS
Annual Report on the MMPA and posted on the NMFS web page. In addition, the stranding
data serve as the raw database for the Marine Mammal Events Program of the Smithsonian
Institution, which archives data on cetacean strandings. The data obtained are used in
mortality investigations, technical memoranda, and peer reviewed publications.
Scientists, state management agencies, and conservation organizations have used the information
and tissues collected in conjunction with response to stranding events. A substantial number of
publications have resulted from stranding data to include information on basic morphology and
distribution of marine mammals, biochemistry, diseases of marine mammals, and on the
potential for interaction with fisheries.
In 2004, 4,784 strandings were reported by the stranding network (3,123 dead and 1661 live)
The Marine Mammal Rehabilitation Disposition Report provides NMFS with information on the
disposition of animals brought in for rehabilitation, types of disease and other health related
issues upon admission, types of and response to medical treatment, and the number of animals
released. This information assists the Agency in tracking marine mammals that are transferred to
captive display facilities following a determination of nonreleasability and in the monitoring of
rehabilitation facilities and release protocols. The data is used to assess the burden on stranding
network centers. This form is filled out only in the case of live-stranded marine mammals that
are transferred to a rehabilitation facility. The form is used by all six NMFS Regions.
It is anticipated that the information collected will be disseminated to the public or used to
support publicly disseminated information. As explained in the preceding paragraphs, the
information gathered has utility. The NMFS will retain control over the information and
safeguard it from improper access, modification, and destruction, consistent with NOAA
standards for confidentiality, privacy, and electronic information. As stated in the “Data Access”
section found on the rear of the forms, upon written request (including those under the Freedom
of Information Act (FOIA)), certain fields of both reports will be provided to the requestor
provided that credit is given to the Marine Mammal Stranding Network and the NMFS. All
other data may be released to the requestor after permission has been obtained from the
contributing stranding network members and the NMFS. The privacy standards under FOIA,
preventing the release of personal information including home phone numbers and addresses,
will be respected. See response #10 of this Supporting Statement for more information on
confidentiality and privacy. The information collection is designed to yield data that meets all
applicable information quality guidelines. Prior to dissemination, the information will be
subjected to quality control measures and a pre-dissemination review pursuant to Section 515 of
Public Law 106-554.
4

3. Describe whether, and to what extent, the collection of information involves the use of
automated, electronic, mechanical, or other technological techniques or other forms of
information technology.
The Marine Mammal Health and Stranding Response Program National Database, which has
been in development since 2001, is in its initial stages of implementation. Development
occurred with the input and comment by many members of the stranding network, including all
of the Regional Coordinators and a group of network participants who were selected as betatesters. A staggered rollout has been implemented since 2004, with training sessions at regional
stranding network meetings. By the end of 2009, the Database should be fully implemented in
all six NOAA Fisheries regions, and stranding network participants will be entering their data
directly into the database using the internet. In the initial stages of use, we ask that stranding
network members continue to submit paper data forms to their Regional Coordinator (the status
quo procedure), for verification purposes. After the initial phase has passed, the stranding
network participants may solely enter their data online. The database very closely reflects the
paper forms referenced in this collection, the Level A Data form and the Rehabilitation
Disposition form.
4. Describe efforts to identify duplication.
Although some duplication of reporting (multiple users reporting the same event) may result
from the large number of stranding network members responding to and reporting stranding
events, it has not been a problem to date. Regional NMFS personnel eliminate any
duplication during data entry and storage. Centralizing the data in the National Database will
provide the most efficient means to distribute information upon requests from other Federal
agencies (e.g., Navy, Smithsonian Institute, etc.), Network members, state and local
managers. Once the database is completed and functional, data requests will be more
manageable thus decreasing the workload on the NMFS Regional Stranding Coordinators and
Network Members.
5. If the collection of information involves small businesses or other small entities, describe
the methods used to minimize burden.
Collection and centralization of data across areas involving small entities (i.e., typically not-forprofit organizations) should minimize the burden of each organization building and maintaining
on their own independent databases. Since stranding network members can view data from other
groups in a centralized database, communication and cooperation between the Network members
should increase.
6. Describe the consequences to the Federal program or policy activities if the collection is
not conducted or is conducted less frequently.
If the information collection was not conducted by NMFS, either another Federal agency or
private organization would need to act in its place as coordinator for the data. If the material and
data were not collected, the U.S. Government would not be able to implement Title IV of the
MMPA and meet the requirements of the MMPA outlined in response to number 1. In addition,
U.S. Government decisions on the management of marine mammals and the management of
fisheries would not be made from the best available information.
5

Section 404 of the MMPA mandates that the Secretary respond to unusual marine mortality
events. Response time is critical especially in the instance of an unusual mortality event. The
NMFS regional stranding coordinators require near real time data to alert NMFS when an
unusual mortality event is occurring. In addition, without a historical baseline provided by
information collected from strandings, detection and investigation of such events is more
difficult.
7. Explain any special circumstances that require the collection to be conducted in a
manner inconsistent with OMB guidelines.
Because detection and response to mortality events or other problems having an impact on
marine mammals is extremely time sensitive, quarterly reporting is not a viable option.
8. Provide a copy of the PRA Federal Register notice that solicited public comments on the
information collection prior to this submission. Summarize the public comments received
in response to that notice and describe the actions taken by the agency in response to those
comments. Describe the efforts to consult with persons outside the agency to obtain their
views on the availability of data, frequency of collection, the clarity of instructions and
recordkeeping, disclosure, or reporting format (if any), and on the data elements to be
recorded, disclosed, or reported.
A Federal Register Notice was published on April 17, 2007. Comments were received from 4
individuals or groups. These comments are posted as part of the ROCIS submission. Briefly, the
comments focused on clarification of the new terms added to the forms. We clarified the terms
and will provide expanded guidance in the instructions manual that will be posted on the NOAA
website along with the forms. Also, we deleted a field regarding unusual mortality events. This
field will be captured in the Group Event screen completed by NMFS employees.
Agency personnel participate in annual meetings of the regional stranding network members to
discuss stranding events, clarify data requirements, and offer guidance with the reporting
process. In addition, Regional Stranding Coordinators (agency employees) meet more frequently
(annually) with members of their regions, and are always available for questions or comments.
9. Explain any decisions to provide payments or gifts to respondents, other than
remuneration of contractors or grantees.
No payments or gifts are provided to respondents.
10. Describe any assurance of confidentiality provided to respondents and the basis for
assurance in statute, regulation, or agency policy.
The respondents are instructed to not include personal information including phone numbers and
e-mail addresses. In accordance with the Freedom of Information Act (FOIA) and Privacy Act,
any personal information inadvertently included may be redacted from a response to a request for
information by another party depending on the information and circumstances. No assurances of
confidentiality are necessary or provided to respondents.

6

11. Provide additional justification for any questions of a sensitive nature, such as sexual
behavior and attitudes, religious beliefs, and other matters that are commonly considered
private.
The information collection does not require the submission of information of a sensitive nature.
12. Provide an estimate in hours of the burden of the collection of information.
There are 74 organizations who are authorized by NMFS to participate in the Marine Mammal
Stranding Network and about 30 federal, state and local governmental organizations that actively
respond to stranded marine mammals. Thirty of the 74 organizations also rehabilitate animals.
These responders are mandated to file stranding response incidents with NMFS as marine
mammals strand. Therefore, the number of reports filed per respondent varies considerably.
Many Network members do not have an occasion to respond to a stranding during a year;
however, a few may file up to several hundred reports. The Marine Mammal Stranding Network
responded to 3,905 stranded animals in 2001 and 4,620 in 2002. The annual average response is
estimated at 4,000, representing Level A Forms. Approximately 800 live stranded animals will
be taken into rehabilitation annually and will require Rehabilitation Disposition forms. There are
two required forms: the Marine Mammal Stranding Report and the Marine Mammal
Rehabilitation Disposition Report. These forms will be required nationwide; however, the
Marine Mammal Rehabilitation Disposition Report is only required for live animal strandings.
Each form is filled out twice, once on paper and once by entry into the database, at the current
time. In the future, only database entry will be required. It is estimated that the average time
necessary to complete each form is 30 minutes, which is inclusive of both the paper form and for
entry into the national database. The total annual response time for the two forms is shown
below.
Type of report

Level A Form
Rehabilitation
Disposition Report
Totals

Approx. # of
responses annually

Time per
Response

4,000
800

30 minutes
30 minutes

4,800

Approx. #
hours
required
2,000
400
2,400

Using an average wage rate of $20/hour, the annualized cost to all respondents is estimated at
approximately $40,000 and $8000 for the forms, respectively. For all respondents combined, the
total annual cost of reporting is approximately $48,000. For approximately 400 respondents, the
cost to each will vary depending on number of strandings, but is estimated to be $120 to
complete these forms annually.
13. Provide an estimate of the total annual cost burden to the respondents or recordkeepers resulting from the collection (excluding the value of the burden hours in #12
above).
There should be no additional cost to respondents in terms of capital and start-up costs. The sole
cost for operations would involve the cost of reproducing the paper forms, and postage for
7

mailing the completed reports to the appropriate NMFS Regional Office. This cost is estimated
to be approximately $2,448 annually for the entire network, although it should be less because
respondents often submit multiple stranding reports at one time. This cost was calculated using
4,800 forms * $0.10 (photocopying) = $480 and 4,800 forms * $0.41 (postage) = $1,968, totaling
$2,448.
14. Provide estimates of annualized cost to the Federal government.
It is estimated that ten staff months are involved in data processing and analysis. An estimate of
three staff months was provided by the Southwest Region which has the highest number of
strandings. Two staff months has been applied to the Northeast, Northwest, and Southeast
Regions. An estimate of one staff month has been applied to Alaska and the Pacific Islands
Regions, where the total number of reports are considerably less than in other Regions. Two
staff month have been estimated for headquarters staff. The total cost to the Federal government
is estimated at $76,220. This figure includes:
$ 51,272 in salaries
$ 11,746 for leave at a rate of 22.9 percent of salaries
$ 13,182 for employer's contribution to benefits at 25.7% percent of salaries.
15. Explain the reasons for any program changes or adjustments reported in Items 13 or
14 of the OMB 83-I.
Respondents have been redefined to be entities, rather than individuals responding from those
entities. The total burden has not changed. In the future, only online data entry will be required,
but for the first phase of the National Database we are continuing to require the paper form for
Quality Assurance/Quality Control purposes. The number of respondents and the number of
responses per respondent have not changed from the current approval. Costs have increased
slightly due to the increased postage rate.
16. For collections whose results will be published, outline the plans for tabulation and
publication.
Data from the Marine Mammal Stranding form and the Marine Mammal Disposition form will
be entered into the database, reviewed by the NMFS regional stranding coordinators,
summarized, and compiled. The regional stranding coordinators will summarize and provide
data upon written request. Information may also be used as baselines for comparisons of dieoffs and may be included in official NMFS tech memos, peer reviewed publications, and
posted on the NMFS web.
17. If seeking approval to not display the expiration date for OMB approval of the
information collection, explain the reasons why display would be inappropriate.
Such approval is not sought.
18. Explain each exception to the certification statement identified in Item 19 of the OMB
83-I.
There are no exceptions.
8

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
This collection does not employ statistical methods.

9