**U.S. Tuna Tracking and Verification Plan**

• To ensure that the "dolphin-safe" label is accurate for tuna purchased
by the public, the

National Marine Fisheries Service (NMFS) has developed a plan for
tracking and

verifying the dolphin-safe or non-dolphin-safe condition of tuna caught
in the eastern

tropical Pacific Ocean (ETP). The tracking system is based on keeping
dolphin-safe

tuna separated from non-dolphin safe tuna from capture through
processing.

• To do this, NMFS regulations require that dolphin-safe tuna be stored
only in designated dolphin-safe storage wells aboard purse seine fishing
vessels, and that non-dolphin-safe tuna will be stored only in
designated non-dolphin-safe wells identified by well number throughout
unloading, transshipping, weigh in, storage, and canning at processing
plants.

• Every purse seine tuna vessel greater than 400 short tons carrying
capacity fishing for

yellowfin tuna in the ETP must have an Inter-American Tropical Tuna
Commission

(IATTC) observer aboard the vessel to oversee every fishing trip. In
addition to other

duties, the observer records information on one of two Tuna Tracking
Forms (TTFs)

every time the purse seine net is set on a school of tuna, depending on
whether the set

is dolphin-safe or not (a set in which dolphin are seriously injured or
killed). The

information recorded after each set includes: 1) date and time of the
set; 2) well number;

3\) dolphin-safe or non-dolphin safe status of the set; 4) estimated
weights of yellowfin,

skipjack, bigeye, and other fish caught in the set; 5) comments if any;
and 6) initials of

the observer and the chief engineer of the vessel. At the end of the
trip, the observer

and the vessel captain sign the completed forms certifying that the TTFs
are complete

and accurate to the best of their knowledge.

• NMFS is notified of the location and expected time of arrival of all
U.S. vessels

completing fishing trips in the ETP. A NMFS representative meets the
vessel at the dock

to oversee offloading if there are any non-dolphin-safe tuna on board.
If the entire catch

is dolphin-safe, NMFS may or may not meet the vessel at the dock. The
vessel owner or

management is responsible for sending the TTFs to the NMFS tuna tracking
and

verification program office. Upon receipt and review of the TTFs, NMFS
issues a

dolphin-safe certificate to the vessel owner/management that can be
supplied to foreign

as well as domestic canners requesting such documentation.

**REQUIRED MONTHLY REPORTS**

[Domestic Tuna Processors]{.underline}

• U.S. tuna processors are required to provide monthly reports on all
tuna received and processed at their plants. These reports include: 1)
date of delivery; 2) catcher vessel name and flag; 3) trip number and
dates; 4) dolphin safe designation of the delivery; 5) species; 6) ocean
area of harvest; 7) received weight; 8) disposition of finished
products; and 9) a copy of the NOAA Form 370, Fisheries Certificate of
Origin (FCO) for all imported raw tuna received during the reporting
period.

[Tuna Product Imports]{.underline}

• To track the dolphin-safe status of tuna imports, all tuna products
except fresh tuna that

are imported or sold into the United States must be accompanied by a
properly certified

FCO. In some cases, an additional certification signed by a
representative of a nation participating in the International Dolphin
Conservation Program is required to document the dolphin-safe status of
the shipment. Approximately 13,000 FCOs are received and reviewed
annually.

**Dolphin-Safe Verification**

• Verification procedures for all required information submissions are
included in the

NMFS tuna tracking regulations. The United States may verify fishing
reports by the use

of IATTC data. U. S. tuna processors are subject to on-site reviews as
necessary, at a minimum of every two years, and document reviews are
performed on all cannery reports. All NOAA Form 370 documents are
reviewed and routine follow-up of documents is conducted on an as-needed
basis. Importers are required to provide backup documentation (invoices,
packing lists, etc.) as requested by the NMFS tuna tracking team.

Random purchases of canned tuna in various locations around the country
are made to

trace them back through processing and ultimately to harvest to verify
the dolphin-safe

condition of the tuna. To date, spot checks have been performed for tuna
products

randomly purchased in all 50 states.