0178 SS 092010 rev2

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.
This request is a renewal of this information collection.
Under the Marine Mammal Protection Act (MMPA), the Secretary (i.e., Secretary of Commerce,
who has delegated responsibility under this Act to the National Oceanic and Atmospheric
Administration (NOAA) Assistant Administrator for Fisheries is charged with the protection and
management of marine mammals and is responsible for collecting information on marine
mammal strandings, which will be compiled and analyzed, by region, to monitor species,
numbers, conditions, and causes of illnesses and deaths of stranded animals. 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 by physical, chemical, and biological environmental
parameters.
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’s National
Marine Fisheries Service (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
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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, aid in dynamic
management practices. Changes in sex ratios, age composition, or age at sexual 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 impacting bottlenose dolphin 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 bycatch. 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.
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-permitted status*. 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 occurs, reporting requirements
transfer to those mandated under OMB Control No. 0648-0084.
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 NOAA (Agency) in tracking marine
mammals that move into captive display and in the monitoring of rehabilitation and release. The
*The transfer to permanent status means for animals deemed non-releasable, and with the concurrence from
the NMFS Regional Administrator, the animal can be permanently placed in a public display or research
facility or be euthanized. If the animal is to be placed in permanent captivity, the receiving facility must be
registered or hold a license from FDA’s Animal and Plant Health Inspection Service [7 U.S.C. 2131 et seq.]
and comply with MMPA (16 U.S.C. 1374 §104(c)(7)). This is all coordinated with NMFS and the transfer
of the animal is documented on the Marine Mammal Rehabilitation Disposition form.

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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 five
NMFS Regions. Each of the NMFS regions approves and issues a Letter of 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 initiated in 2007 and to be fully implemented in 2011.
. 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 over 100 organizations
authorized by National Marine Fisheries Service [i.e., via Stranding Agreement (SA) 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
to assist with detection and investigation of marine mammal unusual mortality events. The
majority of Network organizations are affiliated with academic institutions, aquaria,
rehabilitation centers, or state, federal, and local agencies. Members are requested to submit
basic data (i.e., Level A data) on the Marine Mammal Stranding Report form, for 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. As specified in their SA (i.e.,
typically within 30 days or more frequently depending on type of case), Members of the Network
complete the stranding forms and forward to their NMFS Regional Stranding Coordinator in a
specified time and/or can electronically enter data into the NMFS Marine Mammal Health and
Stranding Response Stranding Database.
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
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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.
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.
The information and tissues collected in conjunction with response to stranding events have been
used by scientists, state management agencies, and conservation organizations. 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.
The Network responded to over 37,000 stranded marine mammals from 2001-2007, representing
10,090 cetaceans and 27,620 pinnipeds (excluding walrus). A small of fraction of marine
mammals are alive when stranded and are deemed appropriate candidates for rehabilitation and
the Network completes the Marine Mammal Rehabilitation Disposition Report. This 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
non-releasability and in the monitoring of rehabilitation facilities and release protocols.
The Agency 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 back page of the
forms, upon written request (including those under the Freedom of Information Act), 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
NMFS. The privacy standards under FOIA, preventing the release of personal information
including home phone numbers and addresses, will not be released. See response to Question10
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.

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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.
Stranding Network organizations can enter Level A from both forms to the Marine Mammal
Health and Stranding Response Program National Database. The database is password protected
and access is limited to SA Network organizations. Stranding organizations do have access to
their own regional data. NMFS may also require paper copies be submitted to the NMFS
Regional Stranding Coordinators in a timely manner as detailed in their SAs. This requirement
has been useful for periodic data validation. The fillable forms are located on the NOAA
Fisheries Office of Protected Resources Web site
http://www.nmfs.noaa.gov/pr/health/publications.htm .
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. Any duplication is eliminated during data entry and
storage by regional NMFS personnel. Centralizing the data in the National Database provides
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.
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 (typically not-for-profit
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 Question 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.
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. Also, without a historical baseline provided by information
collected from strandings, detection and investigation of such events is more difficult.
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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 information on 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 published on May 14, 2010 (75 FR 27294) solicited public comment
and no comments were received.
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
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.
Personally identifiable information is not requested on the forms. In accordance with the
Freedom of Information Act 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.
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.

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12. Provide an estimate in hours of the burden of the collection of information.
There are approximately 400 institutions authorized by NMFS to participate in the Marine
Mammal Stranding Network. Responses are filed 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 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
required only 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.
Form
Stranding Report
Disposition Report
TOTAL

Approx. # of responses annually

Approx. # hours required

4,000
800

2,000
400

4,800

2,400

Using an average wage rate of $20/hour, the annualized cost to all respondents is estimated at
approximately $40,000 and $8,000 for the forms, respectively, with a combined total annual cost
of approximately $48,000.
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 Question
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
mailing the completed reports to the appropriate NMFS Regional Office. This cost is estimated
to be approximately $2,250 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 * $0.44 (postage) = $2,112. Total costs:
$480 + $2,112 = $2,592.
14. Provide estimates of annualized cost to the Federal government.
It is estimated that twelve 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 each have been applied to the Northeast, Northwest, and Southeast
Regions. An estimate of one staff month has been applied to Alaska and the Pacific Islands
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Regions, where the total number of reports are considerably less than in other Regions. Two
staff months have been estimated for headquarters staff. The total cost to the Federal
government is estimated at $76,220.31. This figure includes:
$ 51,271.76 in salaries
$ 11,745.92 for leave at a rate of 22.9 % of salaries
$ 13,182.08 for employer's contribution to benefits at 25.7% of salaries
15. Explain the reasons for any program changes or adjustments.
There are no changes in responses, hours, or burden time but there is an increase in cost
associated with increased postage.
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 technical memos, peer reviewed publications, and
posted on the NMFS Web site:. http://www.nmfs.noaa.gov/pr/health/publications.htm .
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.
Not Applicable.
18. Explain each exception to the certification statement.
Not Applicable.

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

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