FWS Sea Turtle Permit FAQs and Standard Permit Conditions

FWS Sea Turtle Permit FAQs and Standard Permit Conditions.pdf

Federal Fish and Wildlife Permit Applications and Reports - Native Endangered and Threatened Species; 50 CFR 10, 13, and 17

FWS Sea Turtle Permit FAQs and Standard Permit Conditions

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FREQUENTLY ASKED QUESTIONS ABOUT SEA TURTLE
ACTIVITIES REGULATED BY THE
U.S. FISH AND WILDLIFE SERVICE
UNDER THE ENDANGERED SPECIES ACT
March 12, 2013
 

What activities are prohibited?
Take, import and export, interstate commerce, and possession or transport of unlawfullyacquired specimens. Under the Endangered Species Act (ESA), the term “take” means to harass,
harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt to engage in any
such conduct.
Take can be direct or indirect. Direct take of sea turtles for research or conservation purposes
includes, but is not limited to, the following activities: marking nests, picking up hatchlings,
excavating nests, rescuing stranded turtles, collecting eggs or carcasses, tagging adults or
hatchlings, and other similar activities that directly involve sea turtles.
Incidental take of sea turtles may occur even when an activity does not purposefully involve a
sea turtle. Incidental take can occur due to beach armoring, artificial lighting, beach
nourishment, vehicular traffic, or any coastal activity that might interfere with nesting adults,
nests, or emergent hatchlings. Additional information about incidental take and incidental take
authorizations is available at http://www.fws.gov/endangered/what-we-do/hcp-overview.html. If
incidental take is possible, you should consult the appropriate U.S. Fish and Wildlife Service
(Service) field office for your area (http://www.fws.gov/endangered/regions/index.html).
The following frequently asked questions address only direct forms of take related to sea turtle
research and conservation activities.
Who else regulates activities affecting sea turtle?
States, via their section 6 cooperative agreements with the Service, may conduct their own
conservation programs for federally listed species. State authority is limited for endangered
species as detailed elsewhere in this document.
NOAA National Marine Fisheries Service (NMFS) shares ESA authority with the Service for sea
turtles. Pursuant to a joint memorandum of understanding, the Service has jurisdiction over sea
turtles on land (terrestrial habitat) and NMFS has jurisdiction over sea turtles in their marine
habitats.

The Service’s Division of Management Authority, Branch of Permits, located in our
headquarters office, has authority for Convention on International Trade in Endangered Species
of Wild Flora and Fauna (CITES) import and export permits.
Do I need a permit?
A scientific permit is needed if any form of direct take may occur. As a part of their respective
conservation programs, the States and the Service authorize take of sea turtles when it is
determined that the activities are likely to result in a conservation benefit to the species. Many of
the direct take activities listed above are routinely permitted if they promote species
conservation, but a permit must be issued for the specific activities before they may occur. You
may take sea turtles only as specifically described and authorized by a permit if you are the
permittee, are named as an assistant or co-permittee on the permit, or are assisting under the
direct, on-site supervision of a permittee or co-permittee.
What is the process for obtaining a permit if an investigator wants to conduct scientific
research on captive sea turtles or sea turtles in their terrestrial habitat?
An investigator wanting to conduct scientific research on captive sea turtles or sea turtles on the
nesting beach must consider whether to obtain a Service and/or State permit. A Service permit
may be required for endangered species where State authority may be restricted as described
below.
State applications will be made in accordance with their procedures. An application for a
Service permit requires all applicable information described at 50 CFR Parts 17.22(a)(1) and
17.32(a)(1). Generally, the Service requires a complete and signed application form, 3-200-55
(available at http://www.fws.gov/endangered/permits/how-to-apply.html), a project description,
and documentation demonstrating the sea turtle experience or expertise of the applicants and any
assistants.
The Service must advertise the availability of permit applications for endangered species. These
will appear in the Federal Register for a 30-day comment period. Plan ahead to allow time for
the Service to conduct its intra-agency review, preparation of a public notice and its clearance for
publication, and for preparation of any permit instruments.
The following information should be included with research permit application submissions:
a. For research on captive or rehabilitating turtles, a letter from the veterinarian who is or
will be caring for the turtle(s) stating that the research activity will not compromise the
health of the turtle and its’ survival in the wild.
b. For research on captive turtles or turtles on the nesting beach, a proposal that identifies
the benefit of the research to the conservation of the species in the wild, including
specific Recovery Actions identified in the species’ Recovery Plan.

Under the ESA, is there a difference between live animals versus remains or biological
samples?
No. Under the ESA, eggs, carcasses, remains, products, parts, tissue samples, or similar artifacts
– even when incorporated into manufactured products – are protected and regulated to the same
extent as a living animal. For example, you would need a State or Federal permit regardless of
whether you are simply collecting egg shell fragments or are capturing a live sea turtle for
tagging.
What activities are not prohibited?
The ESA does not prohibit possession and transport of sea turtles that have been lawfully
acquired if the activity does not cause take, no commercial interstate transaction (including
barter) occurs, and no import or export occurs. Lawfully acquired sea turtles include those that
were captured under State or Federal authorization, or that were received (in a non-commercial
transaction) from someone else who holds a capture permit.
Normal animal husbandry of captive specimens, when it meets or exceeds requirements of the
Animal Welfare Act, is not considered to be take (50 CFR 17.3). Because the Animal Welfare
Act addresses only mammals, the Service has had to rely on its experience consulting with
facilities that hold captive sea turtles in order to advise them on healthful and humane measures
that would meet the intent of our regulations. These measures are compiled in the Standard
Permit Conditions for Care and Maintenance of Captive Sea Turtles which the Service
incorporates into our sea turtle permits.
What are the differences between threatened and endangered sea turtles?
States have full authority for management of threatened species, but those authorities are limited
for endangered species. States are not able to authorize take of endangered species that would
result in death or permanent disabling of wildlife, removal from the State where the taking
occurred, introduction of the specimen or any progeny into an area beyond the historic range of
the species, or holding in captivity for a period of more than 45 consecutive days (unless such
holding is necessary to aid sick or injured sea turtles).
Do I need both State and Service permits?
Any activity that exceeds the limits of State authority for an endangered species will require a
Federal permit in addition to the State permit. Examples include the sacrifice or euthanasia of
sea turtles or capture of live sea turtles that may be transported out of the State where collected.
Are sea turtles bred in captivity?
No. Captive breeding is not considered necessary or desirable to promote sea turtle
conservation.

Who are those turtle patrol volunteers and under whose authority do they operate?
States with nesting sea turtle populations authorize volunteers to monitor nesting activity and
assist with management activities. Turtle patrol volunteers typically do not hold Federal permits,
although the Service often cooperates with and advises the volunteers.
What authorizations do I need to hold a sea turtle in a rehabilitation facility or educational
display facility?
A permit is not usually required to receive and hold a lawfully acquired sea turtle in captivity.
A permit from the State or the Service is needed to capture or remove sea turtles from the wild.
That permit may allow retention of specimens in captivity and, if so, sea turtles may be
transferred by the permittee to a facility for holding in accordance with their authorization.
States may issue permits for capture and retention of sea turtles under the auspices of their ESA
section 6 agreements with the Service. However, a Service permit will be needed for endangered
species in the following circumstances:
1. The death or permanent disabling of a sea turtle;
2. The removal of a sea turtle from that State; or
3. The holding of a sea turtle in captivity for a period of more than 45 consecutive days.
NOTE: Under the Emergency provisions of their section 6 cooperative agreements with the
Service, States can authorize holding endangered sea turtles for more than 45 consecutive days if
such holding is necessary to aid sick or injured turtles.
If the original permit for taking a sea turtle from the wild allows for it, the specimen may be
transferred between the original holding facility to others, even out of State, without additional
authority from the Service. Note that both parties of a transfer should generate and maintain
documentation to demonstrate that a sea turtle has been taken and possessed lawfully. Copies of
applicable permits should be enclosed with shipments of sea turtles.
Interstate transfers, for ESA purposes, are considered commercial if there is an exchange of
money, goods, or services in return for ownership or control of the sea turtle. Regardless of
anything stated above, any interstate commerce of a threatened or endangered species will
require a permit from the Service. States do not have authority for interstate commerce. Note,
however, that the Service has not issued any interstate commerce permits for sea turtles.
Interstate commerce permits have to satisfy the same conservation purposes as a research and
recovery permit. At this time, we are not aware of any factors that would lead us to believe that
interstate commerce of sea turtles would benefit their conservation.
What conditions will be required of facilities wishing to apply for a permit to hold a sea
turtle?
The Service’s Standard Permit Conditions will be required for all Service permittees to ensure
the best care of a turtle. Even if your facility does not require a permit, we recommend following

the Standard Permit Conditions to ensure that you avoid take (see above, “What activities are not
prohibited?”).
What is the process for holding threatened loggerhead hatchlings or threatened green
turtle hatchlings for public display?
If threatened loggerheads or threatened green turtles, proposed for public display, are obtained as
hatchlings, the facility must obtain a State permit (or a Federal permit only if the State where the
turtle is located does not issue sea turtle permits). A “Hatchling Plan” must be submitted with
the permit application submissions for Service permits. State permits may have additional
requirements. The “Hatchling Plan” must include the following information:
a. A description of the collection method. It is recommended that only those hatchlings that
would not have made it out of the nest (i.e., “the stragglers”) be collected. These
hatchlings are usually found when the nest is excavated 3 days after an emergence is
observed in order to assess hatching and emerging success. Manipulating nests and/or
hatchlings to obtain hatchlings for public display is not allowed as it interferes with the
“frenzy” period. This period is critical for hatchlings to move from their nest to the surf
and through the surf zone and continue swimming away from land for approximately 20
to 30 hours (Carr 1982, Wyneken and Salmon 1992, Witherington 2002).
b. A justification that identifies the benefit of taking hatchlings from the wild for public
display to the conservation of the species in the wild, including specific Recovery
Actions identified in the species’ Recovery Plan. The permit application should include a
justification for the minimum number of hatchlings needed to achieve the specific
Recovery Actions.
c. Information on the quantity and type of food that will be fed to the hatchling(s) for the
entire time the hatchling(s) will be kept in captivity. The diet must be reviewed and
approved by the facility veterinarian.
d. Information on the tank(s) and location at the facility where the hatchling(s) will be
housed for the entire duration.
e. A written plan for the release of the hatchlings that is coordinated with the Service and/or
State agency. The timing and location of the release will be based on the best scientific
information for that size class by State. Include information on the diet that will be given
to the turtle(s) to ensure sufficient foraging capabilities upon release.
f. A commitment to provide periodic reports on the turtle(s). At a minimum, annual
reporting (quarterly reporting may be required) on the current weight, straight carapace
length, and condition of each hatchling must be emailed to the Service and/or State
agency as appropriate.
NOTE: The requirement for a “Hatchling Plan” does not apply to hatchlings or post-hatchlings
that are washed back during storm events and most often are released shortly thereafter.

What is the process for obtaining sea turtle parts from another facility (in or out-of-State)
for research or educational purposes?
Just as for the transfer of a live specimen, if the original permit for taking sea turtles allows for it,
specimens may be transferred between the current holder to others, even out of State, without
additional authority from the Service. Note that both parties of a transfer should generate and
maintain documentation to demonstrate that sea turtle specimens have been taken and possessed
lawfully. Copies of applicable permits should be enclosed with shipments of sea turtle
specimens.
Specimens to be transferred may not be sold or offered for sale in interstate commerce. This
includes bartering goods or services in exchange for specimens.
Often, specimens have been in collections for many years and their origin may be uncertain. As
much as can be known about when, where, and by whom such specimens came into possession
should be gathered and retained with such specimens.
The States or the Service will provide technical guidance for specific situations where the origins
of a specimen are in doubt.
What is the process if a sick or injured sea turtle is found?
Upon locating a sick or injured sea turtle, initial notification must be made immediately to the
appropriate State Sea Turtle Stranding and Salvage Network coordinator
(http://www.sefsc.noaa.gov/species/turtles/strandings.htm). The coordinator will specify
appropriate authorized facilities to receive sea turtles for treatment or rehabilitation.

LITERATURE CITED
Carr, A. 1982. Notes on the behavioral ecology of sea turtles. Pages 19-26 in Bjorndal, K.A.
(editor). Biology and Conservation of Sea Turtles. Smithsonian Institution Press,
Washington, DC.
Witherington, B.E. 2002. Ecology of neonate loggerhead turtles inhabiting lines of
downwelling near a Gulf Stream front. Marine Biology 140:843-853.
Wyneken, J. and M. Salmon. 1992. Frenzy and post frenzy activity in loggerhead, green,
leatherback hatchling sea turtles. Copeia 1992(2):478-484.

 

STANDARD PERMIT CONDITIONS
FOR CARE AND MAINTENANCE
OF CAPTIVE SEA TURTLES
February 13, 2013
The following conditions must be met for all species of sea turtles held in captivity in the United
States under the authority of a U.S. Fish and Wildlife Service (Service) permit issued in
accordance with section 10(a)(1)(A) of the Endangered Species Act of 1973, as amended.
Conditions are also included for the transport, rehabilitation, and disposition of sea turtles.
The individual/institution to whom a Service permit has been issued must notify the appropriate
Service Field Office or Regional Office (http://www.fws.gov/endangered/regions/index.html)
that issued the permit in writing of any inability to meet or maintain these conditions within 60
days. This notification must include a description of all shortcomings and emergency provisions,
back-up systems, and filtration if not previously submitted. Failure to do so maybe considered
a violation of the Service permit.

TYPES OF CAPTIVE MAINTENANCE
Education
Depending upon the display capabilities of a facility and proper justification (specific benefit to
the conservation of the species in the wild), threatened loggerhead turtles (Caretta caretta)
and/or threatened green turtles (Chelonia mydas) may be displayed for educational purposes by a
facility that is primarily educational in nature. Education facilities include those open to the
general public at least 5 days a week and receive no less than an average of 100 visitors per
week. Public encounters (e.g., feeding, touching, swimming, etc.) with turtles is not allowed.
Note: Limited interactive programs may be permitted if specifically reviewed and approved by
the Service. 
Educational Display of Captive Turtles:
1. Turtles on display must be accompanied by interpretive signage or other interactive methods
of communications such as live lectures, displays, and self-guided audio tours. These
displays must include the following: species identification, protection status under the
Endangered Species Act, general life history, and current conservation issues (e.g., incidental
capture in fisheries, boat strikes, ingestion of debris, ocean dumping, loss of nesting beaches,
loss of developmental habitats and adult foraging grounds, beachfront lighting, etc.).
2. For any rehabilitating turtle proposed for public display, the veterinarian responsible for the
care of the animal must deem that the turtle is stable and the additional stress associated with

 

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public display will not affect the turtle’s health. The release of the turtle must not be delayed
or expedited to facilitate the public display.
3. It is the responsibility of the individual/institution to which a permit is issued to ensure that
their facility has the necessary tank space to accommodate the sea turtles until it is ready for
release. Turtles obtained as hatchlings should not need to be moved to another facility
because of inadequate tank space.
4. Any facility holding sea turtles for educational display must also meet all conditions that
follow under Care and Maintenance Requirements.
Educational Tours of Captive Turtles:
1. Tours must only be conducted during hours when the turtles would normally be exposed to
light.  The light exposure can be modified for seasonal photoperiods but must have
consecutive hours of darkness as found in the natural environment during that period.
2. Educational topics must include species identification, protection status under the
Endangered Species Act, general life history, and current conservation issues (e.g., incidental
capture in fisheries, boat strikes, ingestion of debris, ocean dumping, loss of nesting beaches,
loss of developmental habitats and adult foraging grounds, beachfront lighting, etc.).
3. Each tour must have at least one staff/volunteer present at the time of the tour for every 15
guests. More staff/volunteers may be needed as appropriate to ensure guests are not in
contact with the tank or medical equipment.
4. Visitors must be given clear instructions to minimize disturbance and stress to turtles,
including no touching of turtles or their tanks, minimal noise, and no flash photography.
5. Tanks must be half covered or have a hiding spot for turtles to decrease stress from tours.
6. The following information must be included in the annual report – number of tours; number
of people, dates, and times of the tours; medical condition of each turtle involved in the
tours; and the release date of the turtles.
Additional Requirements for Educational Tours of Rehabilitating Turtles:
Educational tours and the display of rehabilitating animals are not authorized for turtles in
critical care. The veterinarian responsible for the care of a turtle must deem that the turtle is
stable and that the tours will not affect the turtle’s health. The release of the turtle must not be
delayed to facilitate the tours. To conduct tours, facilities must meet the following conditions:
1. The timing of the tour must not interfere with the treatment and care of the turtle.

 

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2. Tours may be conducted while a turtle is in treatment if the veterinarian responsible for the
care of the turtle approves, and guests are kept at a far enough distance from the turtle and
staff working with the turtle so as to minimize the potential for additional stress and not
interfere with treatment.
Research
Unless a specific exception is granted because of research conditions, anyone holding turtles for
scientific research must follow all conditions listed below under Care and Maintenance
Requirements. The release of rehabilitated turtles must not be delayed to obtain permits or to
facilitate a research project unless authorized in a Service permit.
Rehabilitation
Any facility holding sea turtles for rehabilitation must meet all conditions listed below under
Care and Maintenance Requirements. All facilities conducting rehabilitation must obtain a
Service and/or State permit for euthanasia or have access to a veterinarian that has a Service
and/or State permit for euthanasia. Note: Euthanasia of endangered turtles may only be
authorized by the Service.
Transport:
1. Sea turtles must be transported in a climate-controlled environment, protected from extremes
of heat and cold, and kept moist. In general, the best range of temperatures for transport is
between 21°C and 27°C (70°F and 80°F; see additional conditions for cold-stunned turtles
below). If a turtle is transported at temperatures greater than or equal to 23.9°C (75°F), it must
be cooled by keeping a wet towel on the carapace and by periodically applying water. Water
and wet towels must not be used when transporting turtles at temperatures less than 23.9°C
(75°F) or at any time they are exposed to an air-conditioned environment (exception: open
wounds must be kept moist with clean freshwater regardless of temperature). At temperatures
less than 23.9°C (75°F), juvenile turtles (less than 30 cm straight carapace length) may be kept
from drying out during transport by applying a thin layer of a water-based, water soluble, nonpetroleum lubricant (e.g., K-Y Jelly) to the carapace and all the soft tissues (except the eyes and
any open wounds). Larger turtles (≥30 cm straight carapace length) do not need a lubricant
because they are less likely to dry out due to their low surface to volume ratio: use of a lubricant
should be avoided to minimize handling injuries. If transport is longer than 45 minutes,
ophthalmic gel may be used to maintain moisture in the turtle’s eyes to avoid eye damage.
2. During transport, housing, and/or subsequent treatment, cold-stunned turtles must be exposed
to gradually rising air and water temperatures over many days, and not exposed to
temperatures that would thermally shock them.
3. Turtles must be placed in closed containers with sufficient holes for adequate ventilation
during transport. Turtles must not be transported in water. The containers housing turtles
during transport must be padded and must not contain any material that could be accidentally

 

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ingested. Hatchlings (sea turtles with a straight carapace length ≤ 4 cm) must be transported in
a container with moist sand. Post-hatchlings (sea turtles with a straight carapace length > 4 cm
and ≤ 6 cm for all species except leatherbacks) must be transported in a container with a damp
towel or cloth at the bottom of the container. The containers must be secured during transport
so they do not slide around or tip over. The Service permit must accompany turtles during
transport.
CARE AND MAINTENANCE REQUIREMENTS
Facility Construction
Tank Size Requirements:
Holding tank sizes for turtles must be based upon the size of the largest specimen in the tank as
described below. Use straight carapace measurements to determine the appropriate tank size.
Note: For a long-term, non-releasable turtle, the facility must have a tank or tanks of sufficient size
to accommodate the turtle through all life stages. If a facility cannot hold the non-releasable turtle
as it grows, it must provide the following information to the Service: (a) a letter from another
facility that has agreed to permanently hold the turtle once it reaches a size that the facility can no
longer accommodate, (b) a description of how the turtle will be transported to the other facility, and
(c) tank size(s) of the facility where the turtle will be transported and remain.
 
1. Hatchlings and post-hatchlings (up to 6 centimeters straight carapace length) – for one
hatchling, a tank or sub-section of a tank with a surface area of at least five times the shell length
by two times the shell straight carapace width of the turtle plus a minimum water depth of 1
foot. The minimum tank width must be no less than two times the shell width. Hatchlings must
be housed separately.
2. Turtles greater than 6 centimeters and up to 50 centimeters straight carapace length – for one
turtle, a tank with a surface area of at least seven times the shell length by two times the shell
straight carapace width of the turtle plus a minimum water depth of 2½ feet. For each additional
turtle, increase the original surface area by 50%. The minimum tank width must be no less
than two times the shell(s) width (i.e., for multiple turtles, the sum of the shell straight
carapace widths must be multiplied by two to determine the minimum tank width).
3. Turtles greater than 50 centimeters and up to 65 centimeters straight carapace length – for one
turtle, a tank with a surface area of at least seven times the shell length by two times the shell
width of the turtle plus a minimum water depth of 3 feet. For each additional turtle, increase the
original surface area by 50%. The minimum tank width must be no less than two times the
shell(s) straight carapace width (i.e., for multiple turtles, the sum of the shell straight
carapace widths must be multiplied by two to determine the minimum tank width).
4. Turtles with a straight carapace length greater than 65 centimeters – for one turtle, a tank with a
surface area of at least nine times the shell length by two times the shell straight carapace width

 

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of the turtle plus a minimum water depth of 4 feet. For each additional turtle, increase the
original surface area by 100%. The minimum tank width must be no less than two times the
shell(s) width (i.e., for multiple turtles, the sum of the shell straight carapace widths must be
multiplied by two to determine the minimum tank width).
Exceptions:
a. Sick or injured turtles may be held in a smaller isolation tank if determined by a
veterinarian to facilitate treatments. Any turtles held for this purpose must be protected
from desiccation and moved to an appropriate tank as soon as health allows.
b. If necessary, healthy turtles may be held in a tank with dimensions less than those
required for no more than 1 week every 3 months. The tank must be large enough to
allow complete submergence and unimpeded turning.
c. If necessary, hatchlings or post-hatchlings being held short term (to allow time to arrange
safe release to the wild) may be held in a tank with dimensions less than those required
above. They must be separated if aggression is observed between the hatchlings.
Tank Condition Requirements:
1. The inside surfaces of any holding tank must be non-abrasive, free of burrs or projections
that could cause harm to turtles, and free of toxic heavy metals and organics, such as lead or
copper paints. Any tank with painted surfaces must be free of biological hazardous material
and must not be actively chipping or flaking. The tank must also be free of anything small
enough to allow turtles access to bite or swallow. Use of non-finished concrete tanks must
be avoided.
2. A holding tank must not contain any non-food items that may be ingested by a turtle or any
items that would obstruct a turtle’s ability to surface either to breathe or to float.
3. A holding tank must not contain entangling materials. Rock ledges or other habitatmimicking items in the tank are encouraged to allow turtles to rest. However, these items
must be constructed or placed in a manner that ensures a turtle cannot become tightly wedged
or trapped underwater. Sea turtles must demonstrate the ability to maneuver safely around
all tank items. Enrichment objects especially for resident/non-releasable turtles must be used
for the quality of life and prevention of conditioning/pacing behavior. A tank must be
designed to ensure the turtle stays within the tank at all times unless removed by facility
personnel.
4. A holding tank must use railings/barriers to prevent the public from reaching into the tanks.
If it is determined that public presence causes unnecessary stress, turtles must not be
accessible to the public.

 

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5. The drains or intakes of a holding tank must be constructed or securely shielded to prevent
accidental entrapment. Inflows and drains must be placed to ensure appropriate water
turnover and flow rates throughout all areas of the tank.
6. To help prevent the water temperature from becoming too warm (> 30°C/86°F), any outdoor
holding tank must be at least 30% shaded. If water is recirculated, shading must be increased
to at least 50% shaded.
Lighting
1. All the tanks in which sea turtles are housed must have enough lighting (sunlight and/or
artificial lighting) to allow for easy viewing of the animals in all areas of the tank.
2. If artificial lighting is used as a primary light source, regular veterinary evaluation must
address any lighting and/or dietary supplement needs based on clinical assessment and best
available medical/husbandry information. Good quality full spectrum bulbs (UVA/UVB)
(wavelength of UVB -280 nm to 320 nm) must be used to promote general health and avoid
potential metabolic problems. If “diffusers” are used, care must be taken to ensure
appropriate full spectrum exposure.
3. The photoperiod of captive sea turtles must be similar to a natural photoperiod and mimic the
summer and winter season daylight hours. Tanks must not be artificially illuminated to
provide a photoperiod of more than 14 hours per 24-hour period to represent the natural
seasonal photoperiods.
4. Dark/shaded areas must be provided to allow turtles a choice. Artificial light must not be
excessive so as to cause sensitivity.
5. Lights above the top of the tank must have shield guards to prevent accidental breakage.
Water Quality
Good water quality is essential to the health of sea turtles in captivity. Facilities must have
written procedures for monitoring and maintaining water quality in all enclosures. At a
minimum the following specific parameters must be met:
1. The salinity must be maintained between 20 ppt and 35 ppt. If necessary, sea turtles may be
maintained in more or less saline water for up to 24 hours per week. Sick or injured sea
turtles may be kept at salinities below 20 ppt or above 35 ppt as prescribed by a veterinarian.
2. Water pH must be maintained between 7.2 and 8.5.
3. Water temperature must be maintained between 20°C and 30°C (68°F and 86°F). High and
low extremes may induce disease (particularly fungal), injury, or even death and must be

 

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avoided. However, rehabilitation of cold-stunned turtles may require that turtles be placed in
waters below 20°C (68°F) to allow them to warm gradually.
4. Chlorine can be used to treat the water to reduce bacterial and algae growth, but levels must
be kept below 1.0 part per million (ppm). Chlorine levels greater than 1.0 ppm may cause
irritation to turtle eyes. No other chemical may be used to treat water in a tank housing sea
turtles if the chemical is not safely ingestible by turtles at the dilution that would be needed
for effective treatment.
5. Coliform bacteria must not exceed 1,000 MPN (most probable number) per 100 ml of water.
Steps must be taken to prevent the conditions in which coliform bacteria proliferate. Testing
for coliforms is a simple, cheap, preventative/proactive measure; it is recommended testing
be conducted monthly on all systems. The steps to prevent coliform proliferation include
adequate filtration (removing suspended material and larger pieces of feces and leftover
food) and the use of an appropriate sanitizing chemical such as chlorine, or a high turnover
rate with fresh, uncontaminated seawater. The Service reserves the right to request total
coliform counts monthly or more frequently if conditions warrant it.
6. If ozone is used for water treatment, the oxidation-reduction potential must be monitored and
maintained below 400 millivolts (mV) if possible to reduce the potential for irritation.
7. The water must be clear enough to allow easy viewing of sea turtles in any part of the tank to
assess health and activity.
8. Facilities holding turtles for rehabilitation must have tanks that maintain water quality by
filtration or flow through. Tanks that require complete or near complete water changes as the
sole means of maintaining water quality, such that the water level is dropped to the point
where the turtle is sitting on the tank floor (“dump and fill”), may only be used for
rehabilitation on a “temporary” (defined as an event where the turtle is expected to be
medically cleared and ready for release within a 45-day period) or on an “emergency”
(defined as an acute mass stranding event or an equipment-related failure at the facility such
as power outages) basis as these conditions are not acceptable for long-term rehabilitation
due to the additional stress caused by frequent maintenance.
The ultimate goal for a rehabilitating turtle is a return to and survival in the wild. The
additional husbandry needs for a rehabilitating turtle in a “dump and fill” tank may
unnecessarily acclimate a turtle to captivity. Therefore, if a turtle held in a “dump and fill”
tank is not medically cleared within 45 days; the facility must contact the Service on a caseby-case basis to determine the appropriate course of action for the turtle.
9. Facilities that use “dump and fill“ tanks for rehabilitation on a “temporary” or “emergency”
basis must:

 

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a. Ensure there are available tanks nearby so that a turtle can be quickly moved to a clean
tank while the dirty tank is dumped, cleaned, and filled. This prevents the turtle from
being out of the water for very long and reduces handling;
b. Remove food that is uneaten. If food must be left unattended, it is recommended that the
uneaten food be removed within an hour unless it is live prey; and
c. Evaluate the turtle skin and shell daily for any abnormalities or worsening of the turtle’s
condition.
10. Facilities that are expected to hold turtles longer than 45 days with preexisting “dump and
fill” tanks for rehabilitating turtles must contact the Service for additional husbandry
conditions to reduce stress to the animals during water changes, as well as provide a
projected timeline (not to exceed 1 year) for the retrofit of these tanks.
11. Any flow-through seawater system must be maintained to facilitate sufficient turnover of
seawater. At a minimum, any flow-through system must have a filtration system on intake.
For closed or semi-open systems, filtration must be incorporated into the system to ensure
appropriate water quality of recirculated water. Filtration and flow through systems must be
able to maintain the minimum water quality parameters.  
12. The facility must have the ability to (1) monitor and operate within the parameters described
in this document, (2) correct any situation in which the parameters are not met, and (3)
properly care for the sea turtles while corrective measures are being taken.
13. Water disposal must be in accordance with all applicable local, State, and Federal laws.
14. Treatment or pre-filtration of fresh seawater is recommended to remove infectious cercariae
(parasitic larva of a trematode worm).
15. Facilities that make sea water must ensure that the appropriate variety of salt (without
anticaking agents) is used to make and maintain the water quality standards for marine life.
Water Quantity
1. Any facility housing sea turtles must have the ability to provide adequate water quantity
under normal and emergency conditions to allow complete submergence and unimpeded
turning. In an emergency, sea turtles may be kept out of water for a maximum of 4 hours per
week. During this time, they must be kept moist and protected from sun, heat, temperature
extremes, and physical damage. This situation should occur only very rarely, if ever.
Treatment of seriously ill or injured sea turtles may require they be out of water for more
than 4 hours per week (e.g., during anesthesia, when administering fluids, or to ensure they
do not drown if too weak to surface to breathe).

 

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2. If sea turtle tanks are regularly drained and cleaned, adequate holding tanks must be available
to house the turtles safely during this time.
Food and Feeding
1. Without exception, the food fed to sea turtles must always be of human quality or
comparable quality of food that is reflective of their diet in the wild. Food must either be
fresh, flash frozen and glazed, or frozen in some other manner that ensures the quality of the
food. Any frozen food must be completely thawed in cool air, preferably, or cool water,
prior to feeding and used entirely or discarded. Under no circumstances may food be
refrozen. If the quality of the food is questionable, it cannot be used as food for sea turtles.
This does not prohibit commercially prepared diets (e.g., dry, pelletized, floating or sinking
formations), but they must be fresh or stored frozen to maintain nutritional value and to
prevent deterioration or microbial growth.
Reasonable efforts must be made by the holding facility to develop proper diets for sea
turtles. Feeding of oily or fatty fish can lead to obesity and cause fatty degeneration of the
liver in sea turtles and must be minimized. Also, the quantity of food must be rigidly
controlled so turtles do not become obese. It is the responsibility of the holding facility to
ensure and justify the adequacy of its feeding regimen for each species and size class.
Turtles must be weighed and measured monthly (4-6 times a year for non-releaseable turtles)
to ensure they are not overfed. See Whitaker and Krum (1999) for additional information on
feeding recommendations.
2. Hand feeding of turtles that will eventually be released is prohibited except when absolutely
necessary for rehabilitation. In the latter case, the turtle must be allowed to feed on its own
as soon as possible. The use of bottom feeders or other tools mimicking the natural feeding
environment is encouraged.
3. Food for groups must be broadcast around the tank to avoid competition and possible injury.
Special precautions and vigilant oversight are required when using broadcast feeding for
large numbers of turtles.
4. Prior to release, turtles of species that routinely feed on live prey in the wild must be
provided with and observed capturing live food prior to release to ensure sufficient foraging
capabilities. Live prey that is an immediate host for parasites such as snails must be avoided.
Behavior and Intermixing
1. Some species of sea turtles, especially loggerheads and Kemp’s ridleys, may be very
aggressive toward their own and other species, particularly while feeding. Whenever the
situation dictates that sea turtles be placed together, they must be closely observed until it is
established that they display no aggressive behavior that might result in injury or death.
Turtles must be separated at the first sign of aggression. Tank dividers can be used. Small

 

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sea turtles must not be housed with larger turtles, especially of another species, as larger
animals can injure or kill smaller animals.
2. Male and female adult turtles must be separated to prevent captive breeding. The
approximately adult sizes are as follows: loggerhead turtle straight carapace length ≥ 80cm,
green turtle straight carapace length ≥ 83 cm, Kemp’s Ridley turtle (Lepidochelys kempii)
straight carapace length ≥ 58 cm, hawksbill turtle straight carapace length ≥ 71cm.
3. Turtles on exhibit may be housed with other species that are present in their natural
environment. The other species housed with a turtle must be reviewed and approved by the
Service. NOTE: In some cases, the permanent injury of a turtle or the size of a turtle may
restrict the species that will be authorized for inclusion in the exhibit with a turtle.
Intermixing of Wild and Captive Stock:
1. Existing captive sea turtles must not be exposed to seawater in which newly wild-caught or
live-stranded sea turtles are kept without an adequate period of quarantine to prevent disease
or parasite transmission. The quarantine period must be at least 60 days.
2. Rehabilitation facilities must provide separate tanks or a tank with a separation for long-term
and temporary captive turtles, not only in the physical plant but in seawater maintenance and
treatment systems. This will prevent injury due to aggressive behaviors, or sickness or death
through transfer of pathogens or parasites.
3. If a female deposits eggs in an exhibit or shows signs of stress in an attempt to leave the
exhibit, the facility must contact the Service that issued the permit under which the turtle is
being held within 24 hours to discuss the best course of action for the eggs and/or female.
Fibropapillomatosis:
Fibropapillomatosis (FP) is an infectious disease and the preponderance of scientific evidence
supports that a herpesvirus is the causative agent. The high incidence of FP in green turtles in
Florida waters is of special concern. Turtles with FP must be isolated from turtles that are not
known to have the disease. FP growths are highly vascular when large and appear to be
extremely sensitive due to the presence of nerve bundles, especially around the eyes. Facilities
that admit turtles with FP must have the capacity for strict biosecurity, including disinfection of
equipment, separate water handling systems, and education of staff and caregivers on biosecurity
measures. Only experienced veterinary personnel should be treating these individuals.
Veterinary Care
Any facilities holding sea turtles in captivity must have access to a veterinarian who:

 

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1. Has an active veterinary license in the United States (means a person who has graduated
from a veterinary school accredited by the American Veterinary Medical Association
Council on Education, or has a certificate issued by the American Veterinary Graduates
Association’s Education Commission for Foreign Veterinary Graduates).
2. Will be on-call 24-hours a day or identify at least one backup veterinarian or have a
contingency plan for when the attending veterinarian is not available.
3. Has documented 1-year clinical experience working with sea turtles and clear demonstration
of clinical proficiency or have a written consulting agreement with an experienced sea turtle
veterinarian, which assures availability of consultation when needed.
4. Has access to a list of veterinarians with experience working with sea turtles to contact for
assistance.
A properly permitted facility may receive for treatment or rehabilitation any sea turtle that is sick
or injured. Upon receiving a sick or injured sea turtle, the attending veterinarian is to examine
the turtle within 24 hours. If this is not possible, the Service must be contacted to make
alternative arrangements, which could include consulting an approved veterinarian at a remote
location.
The diagnosis of disease, surgical intervention, and the prescription of medications must be
carried out only by a qualified veterinarian. Measures must be taken to preserve the health of
captive sea turtles and to prevent injury or spread of disease. Injured or diseased sea turtles must
receive appropriate medical care under the supervision of a qualified veterinarian in a method
that prevents cross-contamination to other animals. Injured or diseased animals should be
physically separated with their own clean seawater source, and all reasonable efforts made to
avoid cross-contamination to unaffected animals.
Health records must be kept for each animal. These should include all examination and clinical
data, as well as an assessment of the findings. For guidance on veterinary care, see Leong et al.
(1989), Campbell (1996), and Whitaker and Krum (1999).
Biological Samples for Diagnostics and Health Assessments of Turtles Associated with a Law
Enforcement Case or Litigation
1. Samples must remain in the legal custody of the facility holding the Service permit.
2. Only samples specifically taken for diagnostic tests may be sent to laboratories to assist in
health assessments.
3. The transfer of biological samples from the facility to any location or individual other than
those identified in the facility’s permit requires written approval from the Service.

 

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4. Sea turtles may be transported off-site for specific tests such as Magnetic Resonance Imaging
(MRI) or Computed Tomography (CT) scans to assist diagnosis for health assessments
provided it is a test prescribed by the qualified veterinarian treating the turtle, and the
laboratory is listed in the facility’s permit.
Euthanasia
All facilities conducting rehabilitation must obtain a Service and/or State permit for euthanasia
or have access to a veterinarian that has a Service and/or State permit for euthanasia. Euthanasia
is authorized only if, in the judgment of a veterinarian, a turtle’s recuperation is unlikely, if an
illness or injury is terminal or untreatable, if an illness is communicable and likely to pose a
threat to wild populations or captive turtles, or if a turtle’s wounds would preclude survival in the
wild or a self-maintaining life in captivity. Note: Euthanasia of endangered turtles may only be
authorized by the Service.
Release
The final determination of an individual’s fitness for survival in the wild will be made with input
from the facility’s veterinarian, animal care personnel, and other persons with sea turtle
expertise, as necessary. The attending veterinarian must perform a hands-on physical
examination of the turtle prior to the release determination. The attending veterinarian must
review the turtle’s complete history including all stranding information, last treatment, and
diagnostic test results. When a facility’s veterinarian has determined that the turtle has recovered
sufficiently from its illness or injury and is ready for release, the principal permit holder, or a
designee, must contact the Service that issued the permit under which the turtle is being held
within 24 hours to discuss the appropriate time and site for the release. The site for release must
be determined based on the latest scientific information on turtle movements and regional
knowledge. Failure to notify the permitting agency of the releasable status of a turtle or the
unnecessary retention of turtles in captivity following medical clearance may be considered a
violation of the Service permit and could result in the permit being suspended. Unless there
are additional complications, turtles are expected to be released within 2 weeks of medical
clearance.
Non-releasable Turtles: Non-releasable turtles are defined as turtles (bycaught, stranded, or
congenitally deformed) that have been rehabilitated, but which have permanent handicapping
injuries or defects that preclude their potential survival in the wild. Many injuries, when healed,
will not hamper a turtle’s existence in the wild. For example, the loss of a flipper does not
prevent a turtle from being able to survive in the wild. Flipper damage is not an unusual
occurrence and is often documented in nesting turtles on the beach. Examples of conditions that
result in declaration of non-releasable status include blindness in both eyes, loss of more than
75% of three or four flippers, or abnormal buoyancy that prevents normal foraging behavior.
Release of Cold-stunned Turtles: The criteria for determining whether turtles that were cold
stunned with no other medical conditions can be released must be based on behavior and
activity of the turtle. If a turtle is alert, swimming strongly, not on medication(s), and otherwise

 

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behaving normally, it must be released as soon as possible in the vicinity of where it was found
cold stunned. The ideal release water temperature is approximately 18°C (65°F) and above;
however, circumstances may necessitate a release at a lower water temperature. Turtles have
been reported to cold stun in water that is approximately 10°C (50°F) (Schwartz 1976). If a
turtle has been cleared for release, but the water temperatures in the capture location are still too
low, the Service must be contacted to coordinate the release timing and location. Prior to
release, turtles must be held in water temperatures that are gradually adjusted to mimic those
found in the natural environment so the turtle does not have a shock response upon entering a
cooler or warmer natural water temperature.
Release of FP Turtles: Turtles with FP can be released when a facility’s veterinarian has
determined that the turtle has recovered sufficiently from its illness or injury and is ready for
release. The principal permit holder, or a designee, must contact the Service that issued the
permit under which the turtle is being held within 24 hours to discuss the appropriate timing and
site for the release. The site for release must be determined based on the latest scientific
information on turtle movements and regional knowledge regarding prevalence of FP.
All sea turtles must be measured and weighed prior to release following the protocols listed at
http://accstr.ufl.edu/cmttp_tag_&_measure_protocols.html. The release protocol or procedure
and the release location must be approved in advance by the Service.
External Flipper Tags and Passive Integrated Transponder (PIT) Tags: Flipper and PIT tags
must be inserted prior to release only under the following conditions:
1. The turtle is size appropriate for receiving a flipper and/or PIT tag.
2. Tagging does not delay the release of the turtle.
3. The turtle is tagged by animal care staff that has demonstrated tagging expertise and is
specifically permitted by the Service to conduct this activity.
4. The turtle is tagged following the protocols listed at
http://accstr.ufl.edu/cmttp_tag_&_measure_protocols.html.
Satellite Transmitters: An investigator or facility wanting to attach a satellite transmitter to a sea
turtle due for release must first obtain a modification to their Service permit. Each request must
be reviewed on a case-by-case basis by the Service. These requests can be submitted prior to
obtaining the turtles with appropriate parameters to support the proposal as described below.
The release of a turtle must not be delayed to obtain permits or to facilitate the attachment of a
satellite transmitter. Failure to obtain a Service permit modification is considered a violation of
the original Service permit.
The following information must be included with satellite transmitter permit application
submissions:

 

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1. A letter from the veterinarian caring for the turtle stating that the attachment of the satellite
transmitter will not compromise the health of the turtle and its’ survival in the wild.
2. A proposal that identifies the benefit to the conservation of the species in the wild including
specific Recovery Actions identified in the species’ Recovery Plan.
3. A compilation of information for all satellite tagged rehabilitated turtles already released by
the facility within the State waters for the species proposed to be tagged. Include the
identification of the turtles, date(s) released, information obtained from the previous tagging
event(s), and information needs/gaps expected to be gained from the proposed tagging.
4. The species, size, and weight of the turtle that is being proposed for satellite tagging.
5. The size and weight of the transmitter proposed for the turtle.
6. The method of attachment.
7. Information about the individual who will be performing the attachment, including their
contact information and a history of their sea turtle transmitter attachment experience.
NOTE: This information will be used to evaluate the benefit to the conservation of the species in
the wild with respect to the additional energy cost to that specific animal as a result of the drag of
the transmitter.
Necropsy and Disposal of Carcasses
1. Necropsies must be performed on any turtles that die at a captive facility. Necropsies must
be performed by or in consultation with a veterinarian, veterinary diagnostic clinic, qualified
pathologist of a college or university, or qualified State/Federal resources agency staff. For
guidance on conducting necropsies, see Wolke and George (1981), Rainey (1994), and
Wyneken (2001).
2. The following documents must be sent to the Service that issued the permit(s):
a. The Sea Turtle Stranding and Salvage Network - Gross Necropsy report
(http://www.seaturtle.org/groups/ncwrc/STSSN.necropsy.pdf), and
b. A copy of any necropsy report that includes the results of pathological, histological,
microbiological, virological, and parasitological studies.
Following necropsy, the carcass of any sea turtle that dies while in the custody of a Service or State
permitted/authorized facility must be completely destroyed (in accordance with State and local
laws) or, subject to the approval of the Service, be offered to a museum, university, or other
educational or research facility. Under NO circumstances may a dead sea turtle, or any part thereof,

 

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be salvaged for any purpose other than Service or State-approved education and/or research
activities.
Conclusion
Inspection:
In order to ensure that facilities holding live sea turtles for rehabilitation, education, and/or
research are maintaining the requirements for care and maintenance, and are in compliance with
all applicable laws, rules, and guidelines, all facilities are subject to inspection at any time by
Service or State personnel. Facilities may be asked to provide a current coliform bacteria count
and water quality data upon inspection. Facilities will be provided with a copy of the report
generated from the inspection. If the facility does not meet the requirements of their permit,
which include the above Care and Maintenance Requirements, it will be considered a violation
of the Service permit and could result in the permit being suspended.
Reporting:
Quarterly reports (Quarterly Report: Appendix A) of the number and species of sea turtles taken
to a permitted rehabilitation facility for treatment, and their diagnosis must be emailed to the
Service at seaturtle@fws.gov. Information must be emailed on the following dates (April 15,
July 15, and October 15) each year.
In addition, an annual report must be submitted no later than January 30 of each year and must
include the following:
i. A January through December summary of the number and species of sea turtles taken to the
permitted rehabilitation facility for treatment, their diagnosis and current disposition
(including those that died, were transferred, or were released).
ii. An account of euthanized specimens along with a description of the circumstances of their
capture and reasons for euthanasia.
iii. Evaluations of all non-releasable (resident) turtles (Non-Releasable Turtle Report:
Appendix B) and current information regarding the care of the turtles including the size and
weight.
iv. A list of veterinarians and animal care staff that worked under the Service permit along
with a summary of their sea turtle experience.
v. A summary of the number and species of sea turtles in the facility that was collected prior
to listing under the Endangered Species Act. Include information confirming that adult
male and adult female turtles are maintained separately.
For Service permits, annual reports must be submitted to the office of the Service’s National Sea
Turtle Coordinator, 7915 Baymeadows Way, Suite 200, Jacksonville, Florida 32256-7517.

 

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LITERATURE CITED
Campbell, T.W. 1996. Sea Turtle Rehabilitation. Pages 427-436 in Mader, D.R. (editor).
Reptile Medicine and Surgery. W.B. Saunders Company, Philadelphia, PA.
Leong, J.K., D.L. Smith, D.B. Revera, Lt. J.C. Clary III, D.H. Lewis, J.L. Scott, and A.R.
DiNuzzo. 1989. Health care and diseases of captive-reared loggerhead and Kemp’s ridley
sea turtles. Pages 178-201 in Caillouet, Jr., C.W. and A.M. Landry, Jr. (editors).
Proceedings of the First International Symposium on Kemp’s Ridley Sea Turtle Biology,
Conservation and Management. October 1-4, 1985, Galveston, TX.
(http://galveston.ssp.nmfs.gov/publications/pdf/875.pdf).
Rainey, W.E. 1994. Guide to sea turtle visceral anatomy. NOAA Technical Memorandum
NMFS-SEFSC-82. 82 pages. (http://www.sefsc.noaa.gov/turtles/TM_82_Rainey.pdf).
Schwartz, F. 1976. Behavioral and tolerance responses to cold water temperatures by three
species of sea turtles (Reptilia, Cheloniidae) in North Carolina. Florida Marine Research
Publications Number 33:16-18.
Whitaker, B.R. and H. Krum. 1999. Medical management of sea turtles in aquaria. Pages 217231 in Fowler, M.E. and R.E. Miller (editors). Zoo and Wild Animal Medicine: Current
Therapy (4th edition). W.B. Saunders Company, Philadelphia, PA.
Wolke, R.E. and A. George. 1981. Sea turtle necropsy manual. NOAA Technical
Memorandum NMFS-SEFC-24. 20 pages.
(http://www.sefsc.noaa.gov/turtles/TM_24_Wolke_George.pdf).
Wyneken, J. 2001. The anatomy of sea turtles. NOAA Technical Memorandum NMFSSEFSC-470. 172 pages. (http://www.sefsc.noaa.gov/turtles/TM_470_Wyneken.pdf).
Wyneken, J. and M. Salmon. 1992. Frenzy and post frenzy activity in loggerhead, green,
leatherback hatchling sea turtles. Copeia 1992(2):478-484.

 

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