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By Learn Laws®
Published 10/21/2026 Updated 10/21/2026

NOAA Seeks OMB Review for Revised International Dolphin Conservation Program Data Collection


On October 21, 2026, the Department of Commerce, through its National Oceanic and Atmospheric Administration, formally submitted a revised information collection request concerning the International Dolphin Conservation Program to the Office of Management and Budget for review and approval. This submission initiates an additional 30-day public comment period, following an earlier 60-day opportunity, allowing stakeholders and the general public to weigh in on data collection efforts vital to marine mammal protection and the regulation of tuna fisheries.

Foundations in Federal Law

This information collection, identified under OMB Control Number 0648-0387, is mandated by several foundational federal statutes. Central among these is the International Dolphin Conservation Program Act (IDCPA), 16 U.S.C. 1414, which amended both the Marine Mammal Protection Act (MMPA), 16 U.S.C. Ch. 31, and the Dolphin Protection Consumer Information Act (DPCIA), 16 U.S.C. 1385. The IDCPA empowers the Secretary of Commerce to establish regulations for implementing dolphin-safe labeling standards in the United States. This includes collecting documentation on the dolphin-safe status of tuna imports and domestic processing, verifying that tuna originates from nations not under embargo, and allowing U.S. vessels to participate equitably in the yellowfin tuna fishery in the eastern tropical Pacific Ocean.

Beyond marine mammal protection, the collection also ensures compliance with the Tuna Conventions Act (TCA), 16 U.S.C. 951 et seq., as amended by the "Illegal, Unreported, and Unregulated Fishing Enforcement Act of 2015" (Pub. L. 114-81). The TCA grants the Secretary of Commerce authority to enforce regulations requiring member states to maintain and provide the Inter-American Tropical Tuna Commission (IATTC) with comprehensive lists of vessels authorized for tuna fishing, including details on their characteristics, ownership, and operators. This information is critical for monitoring the size and composition of fishing fleets within the IATTC Convention Area for both compliance and scientific assessment.

The Scope of Information Collected

NOAA, specifically its National Marine Fisheries Service (NMFS) West Coast Region, gathers a wide array of information through this program. The data ensures the verification of conditions required for tuna imports and domestic products to be deemed "dolphin-safe" or "non-dolphin safe" from catch through their journey to the U.S. market. This involves collecting details that allow for effective tracking and verification. The current collection includes permit applications, various notifications such as transit waivers, vessel departure notifications, and changes to permit operators. It also covers reports for experimental fishing activities and requests for dolphin mortality limits, force majeure exemptions, and vessel status updates like sunk or aging fleet requests.

This information is not solely for NOAA's use. NMFS collaborates closely with the United States Coast Guard and the IATTC, utilizing these data to monitor vessel activity, enforce regulations, and conduct scientific research. The aggregated information on vessel numbers, characteristics, ownership, and gear types is fundamental to managing the U.S. purse seine fleet capacity in the eastern tropical Pacific Ocean, ensuring sustainable practices and international cooperation.

Streamlining and Modernization Efforts

The current submission to OMB reflects a strategic revision aimed at streamlining information management. Five of the twenty-one information collections previously under OMB Control Number 0648-0387 have been reassigned to a separate, but related, collection: OMB Control Number 0648-0335, titled "Tuna Tracking and Verification Program." This separate program, sponsored by the NMFS Office of International Affairs, Trade, and Commerce, consolidates vessel arrival notifications, tuna tracking forms, processing reports, and chain of custody documentation. This reorganization seeks to clarify how information is managed across different NMFS offices, ensuring greater efficiency. The remaining sixteen information collections under 0648-0387 are being renewed without substantive modification, confirming their continued necessity for the program's objectives.

Public Participation and Future Outlook

With an additional 30-day public comment period now open, stakeholders have a further opportunity to provide feedback on this vital data collection effort. Comments can be submitted through www.reginfo.gov by searching for OMB Control Number 0648-0387. The ongoing maintenance and periodic review of such information collections underscore the federal government's commitment to robust marine mammal protection and responsible fisheries management. The data collected remains indispensable for upholding international agreements, enforcing domestic laws, and advancing the scientific understanding necessary for the long-term health of marine ecosystems and the sustainability of crucial commercial fisheries.

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