Guidelines for Oil Spill Response and Natural 

Resource Damage Assessment: Sea Turtles

Brian A. Stacy

Bryan P. Wallace

Tom Brosnan

Sara M. Wissmann

Barbara A. Schroeder

Ann Marie Lauritsen

Robert F. Hardy

Jennifer L. Keene

Stacy A. Hargrove

U.S. Department of Commerce

National Oceanic and Atmospheric Administration

National Marine Fisheries Service 

NOAA Technical Memorandum NMFS-OPR-61

May 2019

Guidelines for Oil Spill Response and Natural Resource 

Damage Assessment: Sea Turtles

Brian A. Stacy

Bryan P. Wallace

Tom Brosnan

Sara M. Wissmann

Barbara A. Schroeder

Ann Marie Lauritsen

Robert F. Hardy

Jennifer L. Keene

Stacy A. Hargrove

NOAA Technical Memorandum NMFS-OPR-61

May 2019

U.S. Department of Commerce

Wilbur Ross, Secretary

National Oceanic and Atmospheric Administration

Neil Jacobs, Under Secretary for Oceans and Atmosphere (Acting)

National Marine Fisheries Service

Chris Oliver, Assistant Administrator for Fisheries
ii

Recommended citation:

Stacy, B. A., B. P. Wallace, T. Brosnan, S. M. Wissmann, B. A. Schroeder, A. M. Lauritsen, R. F. Hardy, J. L. 

Keene, and S. A. Hargrove. 2019. Guidelines for Oil Spill Response and Natural Resource Damage 

Assessment: Sea Turtles. U.S. Department of Commerce, National Marine Fisheries Service and National 

Ocean Service, NOAA Technical Memorandum NMFS-OPR-61, 197 p.

Copies of this report may be obtained from: 

Office of Protected Resources 

National Marine Fisheries Service 

National Oceanic and Atmospheric Administration 

1315 East-West Highway, Room 13657 

Silver Spring, MD 20910 

Or online at: 

https://response.restoration.noaa.gov/oil-and-chemical-spills/research-publications.html

Disclaimers: The views in this Technical Memorandum do not necessarily represent those of the U.S. 

Fish and Wildlife Service, National Park Service, the U.S. Geological Survey or the U.S. Department of the 

Interior. The National Marine Fisheries Service (NMFS) does not approve, recommend or endorse any 

proprietary product or material mentioned in this publication. No reference shall be made to NMFS, or 

to this publication furnished by NMFS, in any advertising or sales promotion which would indicate or 

imply that NMFS approves, recommends or endorses any proprietary product or proprietary material 

herein or which has as its purpose any intent to cause directly or indirectly the advertised product to be 

used or purchased because of NMFS publication. 
iii

Preface ................................................................................................................................. vi

Acknowledgements ............................................................................................................. vii

Acronyms used in guidelines............................................................................................... viii

Executive Summary................................................................................................................1

Introduction: Intent and organization of the guidelines..........................................................2

1. Sea turtle biology and potential vulnerabilities to oil and related contaminants .................4

1.1. Sea turtle biology and status ...................................................................................................4

1.2. Sea turtle life stages and habitat use .......................................................................................6

1.3. Oil spills and sea turtles...........................................................................................................8

2. Government agency roles and responsibilities for sea turtles during an oil spill ................ 12

2.1. Laws and regulations.............................................................................................................12

2.1.1. Oil Pollution Act: spill response and Natural Resource Damage Assessment..........................12

2.1.2. Endangered Species Act ...........................................................................................................16

2.1.3. National Environmental Policy Act...........................................................................................17

2.1.4. National Marine Sanctuaries Act..............................................................................................17

2.1.5. System Unit Resource Protection Act ......................................................................................18

2.1.6. State resource agencies and applicable legislation..................................................................19

2.2. Sea turtle stranding networks................................................................................................19

2.2.1. Atlantic, Gulf of Mexico, and U.S. Caribbean ...........................................................................20

2.2.2. Pacific Islands, Hawaii, and American Samoa ..........................................................................20

2.2.3. Pacific coast, continental U.S. ..................................................................................................20

3. Key elements of oil spill response and operational considerations for sea turtles.............. 21

3.1. General.................................................................................................................................21

3.2. Notification, activation, response structure ...........................................................................22

3.2.1. Incident reporting and resource activation..............................................................................22

3.2.2. Incident Command System.......................................................................................................24

3.3. Quick reference: oil spill response considerations for sea turtles by life stage and habitat.......28

3.4. Operational guidelines ..........................................................................................................37

3.4.1. General evidence collection and handling ...............................................................................38

3.4.2. Basic sampling considerations..................................................................................................39

3.4.3. Handling digital media..............................................................................................................40

3.4.4. Documentation of sea turtles...................................................................................................41

3.4.5. Collecting external samples of oil or suspicious material ........................................................42

3.4.6. Stranding response...................................................................................................................42

3.4.7. Live turtle intervention.............................................................................................................45

3.4.8. Postmortem examination (necropsy).......................................................................................51

3.4.9. Nesting beach activities............................................................................................................52

3.4.10. Directed capture.....................................................................................................................55

3.4.11. Aerial surveys .........................................................................................................................57

3.4.12. Vessel-based surveys..............................................................................................................59

3.4.13 Basking turtles (Hawaii)...........................................................................................................59

Table of Contents
iv

4. Natural Resource Damage Assessment (NRDA) and sea turtles: conceptual model, 

integrating response data, and tools for assessment ............................................................ 61

4.1. Assessing exposure and injury to sea turtles: conceptual model .............................................61

4.2. Oil spill response and NRDA...................................................................................................63

4.2.1. NRDA considerations for the terrestrial zone ..........................................................................63

4.2.2. NRDA considerations for turtles in the oceanic zone...............................................................65

4.2.3. NRDA considerations for turtles in the neritic zone.................................................................68

4.3. Prioritizing exposure and injury assessment tools for NRDA for sea turtles.............................70

4.3.1. Special considerations for approaches to determining exposure and injury...........................70

4.3.2. Evaluation of tools and metrics for determining sea turtle exposures and injuries................72

4.3.3. Summary of NRDA tools and approaches for sea turtles.........................................................84

4.4. Nexus between injury and restoration ...................................................................................84

4.4.1. Coordination between injury and restoration planning ..........................................................85

4.4.2. Injury and restoration metrics..................................................................................................86

4.4.3. Possible types of restoration for sea turtles ............................................................................87

4.5. Data management in NRDA...................................................................................................88

5. Literature cited ................................................................................................................ 90

Appendices.......................................................................................................................... 97

Appendix 1: Important web-based resources................................................................................97

Appendix 2: Maps of species distributions, nesting locations, and basking locations for sea turtle 

populations found in the U.S. and its territorial waters.................................................................98

Species distributions...........................................................................................................................98

Nesting locations and densities........................................................................................................105

Basking locations..............................................................................................................................112

Appendix 3: Temporal presence of different life stages (adults, juveniles, hatchlings) for each 

species in each U.S. region. ........................................................................................................ 115

Appendix 4. Nesting beach activity by state................................................................................ 118

Appendix 5: General information for miscellaneous operations .................................................. 119

General at-sea protocol: retrieval of oiled, dead, or debilitated sea turtles...................................119

General shoreline protocol: oiled, dead, or debilitated sea turtles.................................................120

Definition and qualifications of wildlife observers...........................................................................122

Appendix 6: Chain of custody and evidence handling.................................................................. 125

Chain of custody (COC).....................................................................................................................125

Handling of evidence........................................................................................................................131

Primary COC Form............................................................................................................................133

Subsample COC Form.......................................................................................................................134

Example Freezer Log.........................................................................................................................136

Appendix 7: Collecting external samples of oil or suspicious material.......................................... 137

Instructions for making sampling kits...............................................................................................137

Collection of external samples.........................................................................................................138

Appendix 8: Stranding response................................................................................................. 139

Required equipment for stranding response ...................................................................................139

Outline protocol for turtle retrieval from oil spill response zones ..................................................140

Visibly oiled or suspect oiled sea turtles: .........................................................................................140

Instructions for completing a Sea Turtle Stranding and Salvage Network (STSSN) Report Form 

(Atlantic, Gulf of Mexico, Caribbean)...............................................................................................141
v

Sea Turtle Stranding and Salvage Network (STSSN) Report Form (Atlantic and Caribbean) ...........144

U.S. West Coast Sea Turtle Standing Report....................................................................................146

Pacific Islands Sea Turtle Standing Report .......................................................................................148

Appendix 9: Directed capture..................................................................................................... 150

Required equipment for directed capture operations.....................................................................150

Sea turtle directed capture protocol................................................................................................151

Directed capture ancillary procedures.............................................................................................152

At-Sea Turtle Data Sheet..................................................................................................................153

At-Sea Effort Log...............................................................................................................................154

Appendix 10: Transport of sea turtles......................................................................................... 156

Live sea turtles..................................................................................................................................156

Dead sea turtles................................................................................................................................156

Appendix 11: Rehabilitation and release .................................................................................... 157

Outline protocol for admitting sea turtles .......................................................................................158

Intake and treatment protocol (developed during DWH spill) ........................................................159

Criteria for medical clearance of oiled sea turtles for release .........................................................160

Initial supply procurement list for rehabilitation of oiled sea turtles..............................................161

Live Oiled Sea Turtle Intake Form.....................................................................................................164

Live Sea Turtle Intake Log.................................................................................................................165

Dead Sea Turtle Intake Log...............................................................................................................167

Appendix 12: Necropsy (postmortem examination) .................................................................... 169

Decontamination of non-disposable instruments............................................................................169

Photodocumentation during necropsy ............................................................................................170

Supply procurement list for sea turtle necropsies...........................................................................171

Gross Necropsy Form .......................................................................................................................172

Necropsy Sample Checklist...............................................................................................................176

Appendix 13: Release of de-oiled and non-oiled sea turtles ........................................................ 177

Release options, discussion, and evaluation....................................................................................177

Safe handling and release protocols ................................................................................................178

Appendix 14: Nesting beaches.................................................................................................... 179

Sea turtle nesting beach survey and turtle/nest protection protocols............................................179

Sea turtle hatchling encounter protocol for beach clean-up crews.................................................182

Nest Inventory Data Sheet ...............................................................................................................183

Appendix 15: Best management practices to protect sea turtles during response operations....... 184

Best management practices to protect sea turtles during in-situ burn operations.........................184

Best management practices to protect sea turtles during skimming operations............................185

Best management practices to protect sea turtle nests from beach clean-up operations .............186

Appendix 16: Memoranda of Understanding/Agreements relevant to sea turtles and oil spill 

response activities..................................................................................................................... 190

Memorandum of Agreement: Oil spill planning and response and the Endangered Species Act of 

1973..................................................................................................................................................190

Memorandum of Understanding: National Marine Fisheries Service and U.S. Fish and Wildlife 

Service joint jurisdiction over sea turtles.........................................................................................192
vi

The principal purpose of this document is to provide updated and practical information to personnel 

charged with protecting, assessing, and restoring sea turtles injured by oil spills, under provisions of the 

Oil Pollution Act of 1990. These guidelines specifically cover actions that may be undertaken during 

emergency response to oil spills or subsequent Natural Resource Damage Assessment (NRDA). 

Individuals involved in spill response and NRDA may include a diverse body of governmental and nongovernmental personnel, thus this document is written to be understandable to a broad audience with 

different areas of expertise and various degrees of knowledge and experience related to oil spills and 

sea turtles.

The circumstances of each oil spill vary significantly (e.g., type of oil, volume spilled, duration, 

location, resources at risk, season), thus the information in this document is not meant to be strictly 

prescriptive. Rather, it is intended to supplement existing rules, regulations, policy or guidance and to 

accomplish the following:

 inform oil spill response to be protective of sea turtles and their habitats;

 inform federal and state oil spill coordinating bodies and the development of and updates 

to Area Contingency Plans;

 foster understanding, communication, and coordination among federal and state agencies 

that are responsible for protecting sea turtles and their habitats during oil spills; 

 serve as a starting point for the development of conceptual models and sampling plans in 

coordination with sea turtle experts and permit holders and NRDA case teams; and

 provide a list of potential scientific tools to evaluate exposure and injury to sea turtles 

resulting from oil spills.

Other investigations may take place in parallel with oil spill response and NRDA, including 

enforcement actions and requirements under the Endangered Species Act, National Marine Sanctuaries 

Act, System Unit Resource Protection Act, state laws, and Executive Orders. Studies, samples, and 

information gained from activities included in these guidelines may also be useful for these other 

actions. Actual restoration of lost sea turtle resources and services is beyond the scope of this document 

and is not covered in detail; however, considerations during the damage assessment process that are 

important for planning and development of restoration activities are reviewed.

Preface
vii

Many reviewers provided valuable input for these guidelines including Mark Dodd, Alyce Fritz, 

Simeon Hahn, Kristen Hart, Holly Herod, Amy Hanley, Dennis Klemm, Ed Levine, Danya McLamb, Shawn 

Murakawa, Matthew Parry, Michelle Pate, Christopher Plaisted, Kate Sampson, Jeff Seminoff, Donna 

Shaver, Gary Shigenaka, Benjamin Shorr, Jeff Smith, Laurie Sullivan, Carrie Upite, Diane Wehner, Gina 

Ylitalo, and Sarah Wilkin. We especially thank Allen Foley, Branden Blum, Jill Bodnar, Simona Ceriani, 

Barry Forsythe, T. Todd Jones, Clare Lee, Chip Wood, Meghan Koperski, Robbin Trindell, Michael 

Ziccardi, and Tracy Collier for their in-depth review, helpful comments, and important content additions. 

Cara Field, Lydia Staggs, and Secret Holmes contributed to elements of these guidelines related to care 

and treatment of oiled sea turtles and preparation of rehabilitation facilities. Much of the information 

included in these guidelines would not have been possible without the efforts of the many dedicated 

individuals that responded to the Deepwater Horizon (DWH) oil spill of 2010, contributed to the Natural 

Resource Damage Assessment, and served various other roles related to the DWH spill. In addition to 

some of those listed above, this group includes Blair Witherington, Sandy MacPherson, Tomo Hirama, 

Jane Provancha, Mandy Tumlin, Jonathan Gorham, Michael Bresette, Nicole Stacy, Robert MacLean, 

Michelle Kelly, Rob DiGiovanni, Julika Wocial, Alexis Gutierrez, Trent McDonald, George Graettinger, Eric 

Ruder, Tracy Collier, Carys Mitchelmore, Christine Bishop, Gina Ylitalo, Kristy Juaire, Lance Garrison, 

Wendy Teas, Michael Hooper, and Kevin Reynolds.

Acknowledgements
viii

Note: If an acronym is specific to or part of a department or agency (for the purposes of this document), the name 

of that organization is provided in parentheses.

Departments, agencies, and bureaus

DOC Department of Commerce

DOI Department of the Interior

EPA Environmental Protection Agency

NMFS National Marine Fisheries Service (NOAA)

NOAA National Oceanic and Atmospheric Administration (DOC)

NOS National Ocean Service (NOAA)

NPS National Park Service (DOI)

USCG U.S. Coast Guard

USFWS U.S. Fish and Wildlife Service (DOI)

USGS U.S. Geological Survey (DOI)

Offices within federal agencies

OEPC Office of Environmental Policy and Compliance (DOI)

ONMS Office of National Marine Sanctuaries (NOAA)

OPR Office of Protected Resources (NOAA-NMFS)

ORR Office of Response and Restoration (NOAA-NOS)

ORDA Office of Restoration and Damage Assessment (DOI)

Other acronyms

ACP Area Contingency Plan

AST Aspartate aminotransferase

BMP Best Management Practices 

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act OF 1980

CFR Code of Federal Regulations

COC Chain of custody

CNMI Commonwealth of the Northern Mariana Islands

CBC Complete blood cell count 

CITES Convention on International Trade in Endangered Species

CPK Creatine phosphokinase 

CYP1A Cytochrome P450, family 1, subfamily A, polypeptide 1 

EEZ Exclusive economic zone

ESA U.S. Endangered Species Act of 1973

ERD Emergency Response Division (NOAA-NOS)

FSRC Field Spill Response Coordinator (USFWS)

FWC Florida Fish and Wildlife Conservation Commission 

DARRP Damage Assessment, Remediation and Restoration Program (NOAA)

DARTS Damage Assessment and Restoration Tracking System (DOI)

DIVER Data Integration Visualization Exploration and Reporting (NOAA)

DWH Deepwater Horizon

DPS Distinct population segment

Acronyms used in guidelines
ix

ERMA Environmental Response Management Application (NOAA)

FOSC Federal On-Scene Coordinator 

HAZWOPER Hazardous Waste Operations and Emergency Response

IAP Incident Action Plan

ICS Incident Command System

IAC Inter-American Convention for the Protection and Conservation of Sea Turtles

IUCN International Union for the Conservation of Nature

JIC Joint Information Center 

MTBAP Marine Turtle Biology and Assessment Program (NOAA-NMFS – Pacific Islands)

MOU Memorandum of Understanding

NEPA National Environmental Policy Act of 1970

NIMS National Incident Management System 

NMS National Marine Sanctuaries

NMSA National Marine Sanctuaries Act of 1972

NCP National Oil and Hazardous Substances Pollution Contingency Plan

NPFC National Pollution Funds Center (USCG)

NRA Natural Resource Advisors (DOI)

NRC National Response Center (USCG)

NRDA Natural Resource Damage Assessment

NRDAR Natural Resource Damage Assessment and Restoration program (DOI)

NRT National Response Team

OPA Oil Pollution Act of 1990

SCAT Shoreline Clean-up and Assessment Technique 

PPE Personal protection equipment

PRFA Pollution Removal Funding Authorization (PRFA)

PAH Polycyclic aromatic hydrocarbon 

REO Regional Environmental Officer (DOI)

RO Regional Office (NOAA-NMFS)

RRT Regional Response Teams

RSRC Regional Spill Response Coordinators (USFWS)

READS Resource Advisors (DOI)

RAR Resources at risk 

RP Responsible Party

STSSN Sea Turtle Stranding and Salvage Network 

SC Science Center (NOAA-NMFS)

SSC Scientific Support Coordinator

SST Scientific Support Teams 

SSP Site Safety Plan

SEFSC Southeast Fisheries Science Center (NOAA-NMFS)

SOSC State On-Scene Coordinator 

SCL Straight carapace length 

SURPA System Unit Resource Protection Act of 1996

TWG Technical Working Group

UC Unified Command

UAV Unmanned aerial vehicle

1

Sea turtles are vulnerable to oil spills on land and at sea. All six species found within U.S. and 

territorial waters are listed as threatened or endangered under the Endangered Species Act of 1973, as 

amended (16 USC § 1531 et seq.). Sea turtles have complex life histories and rely on a variety of habitats 

that may be negatively affected by oil and response to oil spills. Effective response to oil spills and 

assessment of injury under Natural Resource Damage Assessment (NRDA), as provided by the Oil 

Pollution Act of 1990, should integrate the unique biology of each species and consider the specific risks 

to each life stage. Oil on nesting beaches can affect adult female turtles, eggs, and hatchlings, whereas 

sea turtles of all sizes, from hatchlings to adults, can be exposed to oil at sea. Smaller life stages of 

turtles (i.e., post-hatchlings and oceanic phase juveniles) spend much of their time at the surface and 

associate with oceanographic features that tend to accumulate oil, making them especially at-risk during 

some spills. Exposure to oil and dispersants occurs via direct contact, inhalation, or ingestion. Many of 

the demonstrated effects of oil on sea turtles are related to physical fouling. High rates of oil ingestion 

documented during previous spills and high risk of inhalational exposure are concerns with regard to 

toxicological effects. Response activities, such as controlled burns, shoreline cleaning, oil boom 

deployment, use of dispersants, oil skimming, and vessel traffic, pose additional hazards. 

Effective response to oil spills requires early identification of species and life stages at risk, timely 

deployment of knowledgeable personnel and other assets, efficient preparation of emergency 

responders, and judicious collection of information that will only be available during and shortly 

following a spill. These measures also are critical for informing a damage assessment. Tools available to 

understand the magnitude of potential injuries to sea turtles as a result of an oil spill include: surveys of 

nesting beaches and marine habitats (e.g., vessel-based and aerial) to document sea turtle presence, 

abundance, and oil exposure; evaluation of oiled turtles and nests encountered during rescue efforts, 

stranding response, and other activities to document exposure and effects (including those caused by 

response activities); and for larger spills, integration of field observations, remote sensing data, and 

other information over time to evaluate the magnitude and persistence of injuries to sea turtles and 

their habitats. 

These guidelines provide an in-depth review of considerations for response and NRDA for sea turtles 

and incorporates knowledge gained from previous oil spills, especially the 2010 Deepwater Horizon

(Macondo 252) spill within the northern Gulf of Mexico. Included in this document are essential tools 

and information pertinent to sea turtles found within U.S. waters to aid preparations for future oil spills, 

promote an effective spill response, and facilitate damage assessment.

Executive Summary
2

Thousands of oil spills occur in U.S. waters each year. While most are small (less than one barrel of 

oil), there have been at least 44 oil spills over 10,000 barrels (420,000 gallons) since 1969 that affected

U.S. waters (Figure I-1). Even relatively small spills can cause major environmental and economic harm, 

depending on location, time of year, sensitivity of environmental resources, amount and type of oil, 

duration of the release, and effectiveness of response actions (i.e., clean-up and/or containment). A 

wide variety of wildlife have been impacted by these spills, including sea turtles, their habitats, and food 

resources. 

Federal agencies, in cooperation with states and parties liable for the spill, are responsible for 

protection and restoration of natural resources impacted by oil spills. These responsibilities include 

providing scientific support for response operations, including protection, capture, and rehabilitation of

wildlife (if warranted). Additionally, federal agencies, states, and tribes have authority to pursue a 

Natural Resource Damage Assessment (NRDA) and seek damages for natural resources and their 

services that the government’s own, manage, or control that are injured or lost. The National Oceanic 

and Atmospheric Administration (NOAA) and agencies within the Department of the Interior (DOI)

(including the U.S. Fish and Wildlife Service [USFWS] and the National Park Service [NPS] with support 

from U.S. Geological Survey [USGS]) have responded to oil spills for over 25 years under a variety of 

authorities (see Section 2). However, experience in responding to and assessing effects of oil spills on

sea turtles is limited compared to that of other resources such as marine mammals, fish, shellfish, birds, 

corals, and wetlands. The life history of sea turtles presents a number of challenges related to 

documenting exposure and effects of oil. 

Introduction: Intent and organization of the guidelines

Figure I-1. Significant oil spills (>10,000 barrels (420,000 gallons) affecting U.S. waters since 1969. Modified from:

http://response.restoration.noaa.gov/oil-and-chemical-spills/oil-spills/largest-oil-spills-affecting-us-waters-1969.html.
3

This document focuses on response to oil spills and possible techniques for conducting a NRDA 

within areas inhabited by threatened and endangered sea turtles managed by NOAA’s National Marine 

Fisheries Service and DOI. Although oil spill response and NRDA have different objectives, as reviewed 

herein, their missions are closely related and benefit from regular communication and coordination. The 

overarching purposes of this document are to: 1) reduce impacts to sea turtles in the event of a spill by 

identifying and implementing key response measures; and 2) support documentation of exposure and 

injuries to sea turtles, if any, as a result of the oil and/or oil spill response in order to inform the NRDA, 

including injury determination and restoration of injured sea turtles.

Each section of these guidelines provides important information for the variety of people that may 

be involved with oil spill response and NRDA, from high level coordinators to field responders, including 

governmental and non-governmental personnel. This diverse group is the target audience of these 

guidelines. A description of each section is provided in Table I-1 for ease of reference. The reader can

determine which content is most relevant to their specific role or immediate needs.

Table I-1. Quick reference section descriptions.

Section Description Page

1 Sea turtle biology and potential vulnerabilities to oil, related contaminants, and 

spill response: Review of sea turtle biology, life history, and distribution within the U.S.

and territories with an emphasis on vulnerability to oil spills.

4

2 Roles and responsibilities of government agencies for sea turtles during an oil 

spill: Principal federal laws and regulations that dictate responsibilities of governmental 

agencies related to oil spills, sea turtles, and protected areas.

12

3 Key elements of oil spill response and operational guidelines for sea turtles:

1) Process for initiation of an oil spill response, incident command structure, and

important response considerations for different sea turtle species and life stages.

2) Specific operational guidelines for common activities, including field response,

stranding response, decontamination and rehabilitation of oiled turtles, postmortem

examination (necropsy), sampling, and evidence collection and handling.

21

4 NRDA and sea turtles: conceptual model, integrating response data, and tools for 

assessment: Assessment of exposure and injury for sea turtles under NRDA, including 

important types of data, resources, and studies. 

61

Appendices Information resources and protocols for sea turtle related activities during oil 

spills: These materials can be modified, if needed, based on the specific needs of future 

spills.

97
4

1.1. Sea turtle biology and status

There are seven species of sea turtles worldwide. Most species have global distributions, with 

nesting beaches restricted to the tropics and subtropics, and marine ranges extending into high latitudes 

and cold water (typically not less than 10–15°C/50–60°F), as in the case of the leatherback turtle (Eckert

et al. 2012). Six species of sea turtles inhabit the United States’ (U.S.) Exclusive Economic Zone (Figure 1-

1), including overseas territories: Kemp’s ridley (Lepidochelys kempii), olive ridley (Lepidochelys 

olivacea), hawksbill (Eretmochelys imbricata), green turtle (Chelonia mydas), loggerhead (Caretta 

caretta), and leatherback (Dermochelys coriacea) (See Appendix 2). The National Marine Fisheries 

Service (NMFS) and U.S. Fish and Wildlife Service (USFWS) have designated U.S. Endangered Species Act 

(1973, ESA) critical habitats in U.S. territorial waters for loggerheads, green turtles, hawksbills, and 

leatherbacks.

All sea turtle species that occur within U.S. jurisdiction are listed as either threatened or endangered 

under the ESA (Table 1-1). Some species have distinct population segments (DPSs), which are the 

smallest divisions of a taxa recognized under the ESA. Kemp’s ridleys, hawksbills, and leatherbacks are 

listed as endangered. Loggerheads in the Northwest Atlantic Ocean and Gulf of Mexico belong to the 

Northwest Atlantic Ocean DPS and are listed as threatened, while loggerheads in the North Pacific 

Ocean DPS are endangered. Six green turtle DPSs occur within waters of the U.S. and its territories. The 

Central South Pacific (American Samoa) and Central West Pacific (Guam and Commonwealth of the 

Northern Mariana Islands) DPSs are endangered and the Central North Pacific (Hawaii), East Pacific 

1. Sea turtle biology and potential vulnerabilities to oil and

related contaminants

Figure 1-1. Sea turtle species found in U.S. waters (to scale by average adult size): (A) leatherback (Dermochelys coriacea), (B) green

turtle (Chelonia mydas), (C) loggerhead (Caretta caretta), (D) hawksbill (Eretmochelys imbricata), (E) Kemp’s ridley (Lepidochelys kempii), 

(F) olive ridley (Lepidochelys olivacea). Original illustrations by Thomas McFarland, used with permission.
5

(California), North Atlantic (SE U.S. including Puerto Rico), and South Atlantic (U.S. Virgin Islands) DPSs 

are threatened. In addition, the U.S. is a party to several international conservation treaties and 

agreements that provide further protections for sea turtles, including the Inter-American Convention for 

the Protection and Conservation of Sea Turtles (IAC), Convention on International Trade in Endangered 

Species (CITES), and International Union for the Conservation of Nature (IUCN).

Table 1-1. Current status of sea turtles under the U.S. Endangered Species Act (ESA). Distinct population segments (DPSs) 

have been designated and assessed for green turtles and loggerheads; ESA listing status for each of these DPSs is shown. 

DPSs have not been designated for other species, although the Pacific Mexico population of olive ridleys was assessed 

separately from other populations of this species.

Species Threatened Endangered ESA listing reference

Green turtle

(Chelonia mydas)

Central North Pacific, East IndianWest Pacific, East Pacific, North 

Atlantic, North Indian, South Atlantic, 

Southwest Indian, Southwest Pacific

Central South Pacific, 

Central West Pacific, 

Mediterranean

81 FR 20057

Hawksbill

(Eretmochelys imbricata)

All 35 FR 8491

Kemp’s ridley

(Lepidochelys kempii)

All 35 FR 18319

Leatherback

(Dermochelys coriacea)

All 35 FR 8491

Loggerhead

(Caretta caretta)

Northwest Atlantic, South Atlantic, 

Southeast Indo-Pacific, Southwest 

Indian

NE Atlantic, 

Mediterranean, North 

Indian, North Pacific, 

South Pacific

76 FR 58868

Olive ridley 

(Lepidochelys olivacea)

All other populations Pacific Mexico 43 FR 32800

Although sea turtles are geographically widespread, human threats have significantly reduced many 

sea turtle populations in recent centuries (Bjorndal and Jackson 2003). Important anthropogenic threats 

to sea turtles include bycatch in fishing gear; human consumption of turtle eggs and meat (and other 

turtle-derived products) for subsistence and commercial purposes; coastal development; as well as

pollution and other forms of habitat degradation, including oil spills (Bolten et al. 2011; Wallace et al. 

2011). Sea turtle populations are particularly vulnerable to the effects of increased mortality from 

human activities because they grow slowly, take many years to mature (one to several decades

depending on species), have long life spans, and do not reproduce every year (Musick 1999). These life 

history traits make their populations prone to rapid declines with slow recoveries from significant losses.

Therefore, sea turtles require long-term, consistent, effective protection to prevent further population 

declines and encourage recovery.
6

1.2. Sea turtle life stages and habitat use

The sea turtle life cycle includes both marine and terrestrial life stages (Figure 2-2). Despite spending 

the vast majority of their lives at sea, sea turtles remain tied to sand beaches for reproduction. 

Approximately every two to four years, female sea turtles haul out on sand beaches to dig their nests 

and lay their eggs; individuals lay multiple clutches per season. Embryos obtain oxygen, water, and heat 

from the surrounding sand in order to develop (Ackerman 1997). After around 45 to 60 days of 

incubation (depending on temperature and location), hatchlings emerge from their nests, quickly crawl 

to the surf, and begin a marathon swim to find refuge within offshore areas. Following hatching, male

sea turtles spend their entire lives at sea. Pacific green turtles are an exception. Juveniles and adults of 

both sexes crawl onto shore to bask in the Hawaiian Islands and other areas of the Pacific.

What happens next with regard to where sea turtles go to 

grow and mature, and the habitats they use, varies by species 

and region. The following is intended as a general description.

For most hard-shelled species (i.e., those other than 

leatherbacks, including green turtles, loggerheads, hawksbills, 

and ridleys), small post-hatchling turtles that have left their 

nesting beach live in the oceanic zone during what is called 

the oceanic or surface-pelagic juvenile life stage. This life stage 

is so named because these turtles remain at or near the 

surface and often associate with convergence fronts and other 

oceanographic features, where they feed, grow, and evade 

predators for several years (Bolten 2003). After this oceanic juvenile phase, turtles move (recruit) into 

the neritic zone where they continue growing to maturity, which requires several years or even decades, 

as in the case of loggerheads, green turtles, and hawksbills (Bolten 2003). The transition from oceanic to 

neritic habitat usage may involve a period of multiple movements back and forth between these zones 

(McClellan and Read 2007; Mansfield pers. com.).

Large juvenile and adult hard-shelled turtles mostly remain in neritic areas, from shallow coastal 

habitat to deeper waters over continental and insular shelves, but may also inhabit the oceanic zone to 

some degree for foraging and migration, and during seasonal movements (e.g., Hawkes et al. 2007). In 

temperate areas, sea turtles also may move in to warmer oceanic waters during cold months (Williard et 

al. 2017). In contrast, leatherback turtles and olive ridleys in the Pacific frequent both shelf and oceanic

waters. 

Sea turtles have evolved extremely accurate navigational systems that allow them to migrate 

between sometimes widely separated feeding grounds and breeding areas. Adult females return to nest 

in the same region or even the same beaches where they hatched (i.e., natal beaches), decades after 

imprinting on those areas as hatchlings (Lohmann et al. 1997). Neritic juveniles and adults can also 

exhibit site-fidelity to specific foraging grounds (Hart et al. 2014; Shaver et al. 2013).

Oceanic zone: open ocean where water depths are 

greater than 200 m (Bolten 2003).

Neritic zone: inshore waters less than 200 m depth, 

which encompasses areas over continental and insular 

shelves and includes bays, sounds, and estuaries 

(Bolten 2003).

Convergence fronts: boundary between two water 

masses that forms as a result of wind, currents, or the 

Coriolis forces. These fronts tend to accumulate floating 

material and organisms, such as Sargassum seaweed.
7

Because sea turtles occupy different habitats depending upon species, life stage, and reproductive

phase, these aspects of their life history influence their vulnerability to oil spills. Therefore, different 

approaches for responding to oil spills and assessing effects are necessary for the various species and 

life stages and must consider how sea turtles are distributed in both time and space as related to threats 

posed by spills. 

Within U.S. waters and on coastlines, presence and relative abundance of different life stages and 

species of sea turtles vary seasonally and regionally (Table 1-2). Identifying the species and life stages 

that are present in a given area at the time of a spill is a fundamental first step to developing and 

implementing appropriate response and NRDA activities. Although abundance of different species and 

life stages is variable, sea turtles are generally present to some extent year-round in all U.S. regions 

except Alaska. Leatherbacks are an exception, although their occurrence in sub-arctic and polar latitudes 

is rare. For regions where water temperatures consistently remain below around 10-15 ̊Celsius during 

winter months, turtles tend to exhibit strong seasonal movements, migrating to warmer areas (Benson 

et al. 2007; Dodge et al. 2014). In the Northeast U.S., sea turtles are most common within nearshore 

waters from April to November and are infrequently encountered or absent during winter months. Sea 

turtles are consistently present throughout the year in the Southeast U.S., Gulf of Mexico, Caribbean, 

and Pacific Islands region. Within these regions, reproduction occurs in the spring/early summer, peaks 

Figure 1-2. Generalized sea turtle lifecycle. 1) The lifecycle starts with egg laying. 2) Hatchlings then leave nesting beaches and 

swim away from the coast to reach oceanic (i.e., offshore, depths typically > 200 meters) areas, where they remain for several 

years as oceanic juveniles associated with surface habitats (3) (e.g., Sargassum seaweed). 4) After growing larger, they move 

into waters of the continental (or insular) shelf closer to shore (including bays, sounds, and estuaries) as neritic juveniles until 

reaching adulthood. 5) Adults undergo breeding migrations to the areas where they were born, sometimes across oceanic areas, 

to find mates. Adult male turtles return to foraging areas after mating, while adult females remain near nesting beaches (6) where 

each turtle lays multiple clutches over a period of around 1–2 months. Hatchlings emerge from eggs laid on sandy beaches, 

which initiates a new cycle. Illustration by Kate Sweeney for NOAA.
8

during the summer months, and decreases in late summer and early fall. A summary of temporal 

presence and relative abundance of sea turtles by species, life stage, and region is provided in Appendix 

3 as a guide for response and NRDA personnel. 

Table 1-2. Summary of sea turtle life stages and habitats discussed in this section. See Appendix 3 for tabular 

representation of presence of various life stages by species in each U.S. region

Life stage Habitat in the U.S. Behavioral characteristics Seasonality

Nesting 

females, eggs, 

hatchlings

Sandy beaches mainly in the 

Southeast U.S., Hawaii, and 

overseas territories

Females nest on beaches; embryos develop 

while buried in sand; hatchlings emerge and 

enter the ocean

Southeast U.S. and Hawaii: mating occurs 

between March-June, nesting occurs between 

March-October, hatchlings emerge between 

May-November

Post-hatchlings 

and small 

juveniles

Open ocean; including surface 

habitats throughout Atlantic 

Ocean (including the Gulf of 

Mexico) and Pacific Ocean

Spend more than 80 percent of their time at or 

near the sea surface; limited diving ability; tend 

to associate with floating Sargassum in the 

Atlantic and Gulf of Mexico; drift and swim to 

remain in surface currents

Year-round

Large juveniles 

and adults

Continental and insular shelves; 

nearshore and inshore habitats; 

and beaches (basking, Hawaii

only)

Use the entire water column, from surface to 

bottom; active swimmers; dive frequently and 

typically deeper than 20 meters; spend on 

average 10 percent of time at the surface; exhibit 

seasonal and non-seasonal migrations; 

individuals consistently use the same breeding 

and foraging areas; in Hawaii, green turtles bask 

on beaches

Turtles are present in many areas year-round, 

but in higher densities near nesting beaches, 

foraging areas, and along reproductive 

corridors prior to and during the nesting season

(summer months), and lower densities at 

higher latitudes during winter months; female 

turtles remain in the vicinity of the nesting 

beach until they have nested multiple times in a 

season

1.3. Oil spills and sea turtles

An oil spill poses myriad threats to sea turtles in both terrestrial and marine environments. Dangers 

result from exposure to oil (including petroleum, fuel oil, sludge, oil refuse) as well as from the various 

response methods used to minimize the extent and harm resulting from an oil spill, such as collection of 

oil from shorelines and water, in situ burning, use of various forms of oil booms, and application of 

dispersants. A number of factors influence risks to sea turtles, including the seasonal timing and location 

of the spill, the volume and nature of spilled product, environmental conditions, and response tactics 

employed. The distribution of different turtle life stages and seasonal movements related to 

reproductive status, foraging strategies, and environmental factors influence the scale and nature of any 

resulting spill-related impacts. 

Sea turtles, their habitats, and prey/forage can be exposed to oil in multiple ways (Figure 1-3). 

Turtles may be exposed by contact with their skin, ingestion, or inhalation. Developing embryos may be 

exposed within nests through their eggshells or, potentially, by passage of oil-related compounds from 

females during egg development (Shigenaka 2003). Sea turtles do not appear to avoid oil slicks and may
9

ingest oil because they either mistake it for food or incidentally as they consume contaminated food or 

water (Vargo et al. 1986). Sea turtles feed upon a variety of organisms found on or within the sea floor 

and water column that may contain oil or related compounds. Because sea turtles must surface to 

breathe air, they may be exposed to volatile compounds and aerosolized oil. Potential for exposure 

continues as long as oil persists in the environment. Sea turtles do not avoid oil and will continue to 

forage in oiled areas (Vargo et al. 1986; Vander Zanden et al. 2016).

The sea turtle life stages affected by a spill depend on the ecological zone(s) that is impacted. 

Oceanic juvenile turtles found in offshore areas rely upon ephemeral convergence fronts, which collect 

anything floating at the surface. In the Atlantic Ocean and Gulf of Mexico, these fronts aggregate rich 

biological communities associated with floating seaweed (Sargassum species). Spills within or reaching 

offshore waters may cause surface oil to accumulate within these habitats, posing an especially acute 

risk to these small turtles. Larger, older neritic turtles may be exposed to oil within waters of continental 

or insular shelves and nearshore habitats as they forage, breed, or migrate within this zone. When oil 

comes ashore on turtle nesting beaches, females, eggs, hatchlings, and nesting habitat are at risk. 

Section 3 and Section 4 describe how life history traits and habitat types should be considered when 

planning and implementing an oil spill response and conducting a NRDA.

Although oiling of sea turtles and resulting mortality have been documented during previous spills in 

various locations around the world, detailed information, especially with regard to sublethal effects of 

oil, was generally sparse prior to the Deepwater Horizon (DWH) oil spill in 2010 (see Shigenaka 2003 for 

review). The most readily apparent, acute effects of oil on sea turtles documented during the DWH spill 

were caused by physical fouling in oil (Stacy 2012; DWH NRDA Trustees 2016; McDonald et al. 2017;

Figure 1-3. Potential routes of 

exposure to oil and effects in marine 

and terrestrial habitats. Illustration by 

Kate Sweeney for NOAA
10

Stacy et al. 2017). Those turtles encountering the most heavily oiled areas were unlikely to have 

survived without intervention. Observed effects included direct mortality from aspiration of oil, 

impeded movement, physical exhaustion, and dehydration aggravated by hyperthermia from contact 

with thick, dark, hot oil at the surface under summer conditions (Stacy 2012). High rates of oil ingestion 

also were documented (Stacy 2012). 

Toxicological effects of oil exposure on sea turtles have not been demonstrated as clearly as physical 

effects (Shigenaka 2003; DWH NRDA Trustees 2016). Similarly, the effects of dispersants and various oil

constituent compounds on sea turtles are poorly understood. This is partially due to a general lack of 

empirical studies and controlled experiments (for review see Shigenaka 2003 and Mitchelmore et al. 

2017). Developmental effects and embryo mortality have been demonstrated in multiple species of 

turtles, including sea turtles, under different circumstances, but results have been quite variable (e.g., 

Fritts and McGehee 1982). With regard to effects of oil on sea turtles after they hatch, mortality 

resulting from oil toxicity has not been documented conclusively, and sublethal physiological effects 

vary widely and can be difficult to evaluate (Lutcavage et al. 1995; Camacho et al. 2013; Harms et al. 

2014; Mitchelmore and Rowe 2015; Mitchelmore et al. 2017; Stacy et al. 2017). For example, blood 

abnormalities in oiled turtles admitted to rehabilitation centers during the DWH spill included 

nonspecific metabolic and physiological abnormalities attributable to stress, dehydration, and exertion 

caused by oiling, capture, and transport (Stacy et al. 2017). Freshwater turtles (i.e., surrogates for 

federally protected sea turtles) orally exposed to crude oil on a daily basis for 14 days did not show 

severe, life-threatening physiological derangements or mortality (Mitchelmore and Rowe 2015). Shortterm exposure of loggerhead hatchings to dispersant (Corexit 9500A) and a mixture of oil/dispersant 

affected hydration and weight gain (Harms et al. 2014). Potential effects of longer exposures and 

chronic effects remain a concern in sea turtles based on observations in other animals, but remain 

largely unexplored. Section 4.3 reviews in more detail study selection and design considerations related 

to toxicological effects of oil exposure on sea turtles. 

In addition to effects from oil exposure, sea turtles are also at-risk from response activities 

undertaken during oil spills (Figure 1-4). For example, oil removal via skimming or burning can 

incidentally entrap and kill sea turtles. In addition, increased vessel traffic servicing a spill response can 

result in greater numbers of turtles struck and killed by watercraft (Stacy 2012, 2015; Stacy and 

Schroeder 2014). On beaches where sea turtles nest, response activities are associated with increased 

artificial lighting at night, increased human presence, and mechanized clean-up operations to physically 

remove contaminated sand which can interfere with nesting females (Michel et al. 2015). Additionally, 

placement of booms at the waterline to protect beaches from oil can interfere with nesting females and 

hatchlings attempting to move onto or off the beach. Alterations of the beach profile and composition 

during oil recovery can have undetermined effects on subsequent nesting. As with exposure to the oil 

itself, the potential adverse effects on sea turtles caused by oil spill response activities vary depending 

on the presence and abundance of sea turtles in affected areas. For example, spills that occur near 

nesting beaches during the nesting season have great potential to affect multiple life stages 

concentrated within these areas (Table 1-2 above).
11

Figure 1-4. Potential injuries caused by spill response activities. Modified from illustration by Kate Sweeney for NOAA.
12

2.1. Laws and regulations

2.1.1. Oil Pollution Act: spill response and Natural Resource Damage Assessment 

The Oil Pollution Act of 1990 (OPA) was enacted largely in response to the Exxon Valdez oil spill 

(Prince William Sound, AK, 1989) to strengthen the Nation’s ability to prevent and respond to oil spills. 

OPA provides key planning and response elements, including: 1) requirements for contingency planning 

by government and industry; 2) the creation of the Oil Spill Liability Trust Fund (OLSTF), which is 

managed by the U.S. Coast Guard (USCG); and 3) a liability scheme that was designed to ensure that, in 

the event of a spill or discharge of oil, or the substantial threat of a discharge of oil, into or upon U.S. 

waters, the Responsible Party(ies) (RP) is liable for the response costs and damages that result from the 

incident. The National Contingency Plan (NCP) provides that federal departments and agencies, 

including the National Oceanic and Atmospheric 

Administration (NOAA) within Department of 

Commerce (DOC) and agencies under the 

Department of the Interior (DOI), may be called upon 

during response to provide assistance in their areas 

of jurisdiction and/or special expertise, consistent 

with agency legal authorities and capabilities.

Under OPA, agencies with jurisdictional authority for natural resources, which include NOAA and 

agencies under DOI, have three key roles as outlined in the National Oil and Hazardous Substances 

Pollution Contingency Plan (NCP, 40 CFR § 300.145):

 serve as scientific advisors to the Federal On-Scene Coordinator (FOSC), with duties including oil 

trajectory predictions, overflight observations of oil on water, identification of high value or 

sensitive habitats or resources, and shoreline surveys of oil to determine clean-up priorities;

 represent the interests of their respective Departments in oil spill response planning and 

decision-making through National Response Teams (NRTs) and Regional Response Teams (RRTs).

Through this process, resource agencies are involved in the development of oil spill response 

planning documents, including Area Contingency Plans (ACPs) and Wildlife Response Plans 

(including sea turtle and marine mammal response considerations), at both regional and area 

levels; and

 serve as natural resource Trustees for impacted resources and, as appropriate, conduct a 

Natural Resource Damage Assessment (NRDA), jointly with other Trustees (i.e., state resource 

agencies, tribal nations), with the goal of restoring resources and their services harmed by the 

spill.

2. Government agency roles and responsibilities for sea 

turtles during an oil spill 

Oil - under OPA, means “oil of any kind or in any form, 

including petroleum, fuel oil, sludge, oil refuse, and oil 

mixed with wastes other than dredged spoil, but does 

not include any substance which is specifically listed or 

designated as a hazardous substance [under the] 

Comprehensive Environmental Response, 

Compensation, and Liability Act (42 USC 9601).”
13

Oil spill emergency response

The USCG’s or the Environmental Protection Agency (EPA)’s FOSC oversees response to oil spills in 

U.S. waters, as that term is defined by the U.S. Army Corps and EPA. Oil spill response activities follow 

the Incident Command System (ICS) structure specified by the National Incident Management System 

(NIMS), modified for oil spill response by the NRT; all response activities are coordinated by the Unified 

Command (UC). Funding for response activities is provided through a Pollution Removal Funding 

Authorization (PRFA) from the Oil Spill Liability Trust Fund, which is administered by the USCG’s National 

Pollution Funds Center (NPFC).

If an oil spill occurs in an area that sea turtles are known to inhabit, the FOSC requests NOAA-NMFS

Office of Protected Resources (typically through the NOAA SSC) and USFWS Ecological Services to 

participate in wildlife response. The notification process; integration of sea turtle interests into the spill 

response organizational structure; and cooperative engagement of federal, state, and nongovernmental personnel in oil spill response are reviewed in Section 3. 

Natural Resource Damage Assessment and Restoration

Under OPA, responsibility for acting on behalf of the public lies with designated federal, state, tribal, 

and foreign natural resource Trustees. These Trustees are authorized to assess and restore natural 

resource injuries resulting from a discharge of oil, or the substantial threat of such a discharge (e.g., 

vessel groundings), and associated response activities. Under the NCP, DOC and DOI are designated as 

Federal Trustees for a wide variety of coastal resources, including fisheries, migratory birds, protected 

species, and habitats (e.g., wetlands, mangroves, mudflats, 

beaches, and reefs). Federal and state resource agencies serve 

as Co-trustees for sea turtles.

Within NOAA, NRDA is conducted by the Damage 

Assessment, Remediation, and Restoration Program (DARRP), 

comprised of ORR’s Assessment and Restoration Division 

(ARD), NMFS Restoration Center, and the Natural Resources 

Section of the NOAA General Counsel’s Office. More information on DARRP, including information on 

current and past cases can be found at the DARRP website. Within DOI, the Office of Restoration and 

Damage Assessment (ORDA) is the lead for DOI’s Natural Resource Damage Assessment and Restoration 

(NRDAR) program, which is conducted by employees of affected bureaus with trustee jurisdiction (e.g., 

Fish and Wildlife Service, National Park Service, Bureau of Indian Affairs, Bureau of Land Management, 

and Bureau of Reclamation). In addition, DOI NRDAR case managers can be supported by DOI’s Office of 

the Solicitor; economists from DOI’s Office of Policy Analysis, or an affected bureau; the U.S. Geological 

Survey; and/or ORDA’s Restoration Support Unit. More information on NRDAR, including information on 

current and past cases, can be found at the Damage Assessment and Restoration Tracking System 

website as well as manuals provided by the USFWS and National Park Service (NPS).

Injury - an observable or measurable adverse change 

in a natural resource or impairment of a natural 

resource service. Injury may occur directly or 

indirectly to a natural resource and/or service. Injury 

incorporates the terms “destruction,” “loss,” and “loss 

of use” as provided in OPA (OPA regulations at 15 

CFR § 990.30).
14

OPA authorizes Trustees to conduct a NRDA to: 1) return injured natural resources and services they

provide to baseline, the condition they would have been in if the incident had not occurred; and 2) 

implement additional restoration to compensate for interim losses of such natural resources and 

services (15 CFR § 990.10). NRDA is a restoration-focused, statutorily-based process for the 

identification, evaluation, and quantification of injuries to natural resources and services, and 

development and selection of restoration actions for injured resources and their services. A NRDA is not 

necessarily initiated for all oil spills, e.g., if outside of jurisdiction, if injuries unlikely to result, or 

response actions are likely to address injury (15 CFR § 990.41-42).

The NRDA process encourages cooperation between the parties to promote expeditious and costeffective restoration. The affected Co-trustees make decisions through consensus. In addition, under 

OPA NRDA regulations, Trustees are required to invite the RPs to participate in the NRDA. If the RP is 

amenable to a cooperative NRDA, the degree of RP participation is determined by the Trustees, varies 

from case to case, and is based on Trustees considering such factors as the willingness of the RP to fund 

assessment activities and to conduct assessment activities, including restoration planning, in a 

technically sound and timely manner. The intent of this cooperation is to allow NRDA studies to be 

conducted in a more efficient and cost-effective manner and to facilitate the resolution of legal claims, 

essentially expediting restoration. 

A NRDA claim is not punitive. The damages recovered by the Trustees from the RP (i.e., funds 

recovered in a settlement or litigation) may include the reasonable costs incurred conducting the 

assessment, restoration planning costs, and restoration funds. Restoration funds may only be used to 

restore resources injured and services lost as a result of the oil spill. If a RP is not cooperative or there is 

no viable RP, assessment and restoration funds may be secured through the OSLTF that is administered 

by the USCG’s National Pollution Funds Center (NPFC). In the case of an uncooperative RP, the NPFC will 

then pursue reimbursement for assessment and restoration costs from the RP.

Under OPA, there are three general phases of NRDA: 1) Preassessment; 2) Restoration Planning; and 

3) Restoration Implementation (Figure 2-1, 15 CFR § 990.12). During the Preassessment phase, the 

Trustees determine whether they have jurisdiction to pursue restoration under OPA (15 CFR § 990.41) 

and, if so, whether to conduct restoration planning by proceeding with the injury assessment and 

restoration planning process (e.g., to ascertain whether or not response actions to the oil spill 

adequately addressed injuries resulting from the spill) (15 CFR § 990.42). In addition, Trustees may 

collect and analyze data during the Preassessment Phase that is likely to be lost (ephemeral data), that is 

pertinent to determination of jurisdiction or the decision whether to proceed with restoration planning, 

or that is necessary to design or implement anticipated assessment procedures. Within the Restoration 

Planning phase, Trustees evaluate and quantify potential injuries to natural resources and their services 

from exposure to oil and/or response actions and use that information to determine the need for and

scale of restoration actions (15 CFR § 990.50). Generally, this process includes: 1) demonstration of 

exposure (and pathway) of natural resources to the oil discharged during the spill (15 CFR § 990.51[d]); 

2) determination and quantification of injury/injuries resulting from exposure to the discharged oil (15 

CFR § 990.51 [c] and [e-f]; § 990.52); and 3) identification and evaluation of a reasonable range of 

restoration alternatives and selection of preferred alternative(s) to compensate the public for the 
15

injured and/or lost natural resources and services (15 CFR § 990.53-990.55). In addition, the Trustees 

may consider injury to natural resources and services caused by response activities, such as closure of 

beaches (15 CFR § 990.51[e]). Based on this assessment, the Trustees determine damages. This injury 

assessment process is the focus of the NRDA element of these guidelines and is covered in detail in 

Section 4. OPA requires that damages be based on a plan developed with opportunity for public review 

and comment. To meet this requirement, Trustees must develop a Draft and Final Restoration Plan (15 

CFR § 990.55[a]). In the Restoration Implementation phase, the Trustees seek to recover the damages, 

including reasonable costs of assessment, from the RP or, in the event of no RP or an uncooperative RP, 

present a claim to the OSLTF or file a judicial action for damages (15 CFR § 990.62 and § 990.64). Once 

damages are recovered, the Trustees implement their plan for restoration, rehabilitation, replacement, 

or acquisition of the equivalent of injured or lost resources and services (e.g., recreational use). It is in 

the best interest of resource recovery to consider restoration options early in the case, and to select 

assessment endpoints and options for measuring (quantifying) injury that most effectively inform 

restoration. 

Depending on the size and complexity of the spill, the NRDA phases may overlap to various degrees, 

but it is more common for Restoration Implementation to follow completion of the Restoration Planning 

Phase. The entire assessment process may take months to years, depending on the intricacies of the 

case and other factors. Restoration Planning typically begins early during the course of a spill and 

Restoration Implementation generally continues as the longest phase.

NRDA planning and activities may be concurrent with oil spill response activities (see above). 

Communication and coordination among those engaged in both of these efforts allows for timely data 

collection and sharing, maximizes information gathering efficiency, saves time and money, allows

prompt notification of trustee agencies and the RP, and may result in earlier completion of restoration

(BLM 2008). For example, rescue of oiled sea turtles during response provides direct evidence of 

exposure and can be used to demonstrate injury. 

Figure 2-1. Three phases of OPA 

Natural Resource Damage 

Assessment. As part of injury 

assessment, Trustees conduct 

studies to demonstrate the 

pathway by which oil was 

released, exposure of natural 

resources to the oil, and injuries 

caused by the release.
16

2.1.2. Endangered Species Act

The Endangered Species Act as amended (ESA; 16 USC § 1531 et seq.) of 1973 provides for the 

conservation of species that are endangered or threatened with extinction, and the conservation of the 

ecosystems on which they depend. A species is considered endangered if it is at risk of extinction 

throughout all or a significant portion of its range. If a species is likely to become endangered in the 

foreseeable future, it is listed as threatened. 

All species of sea turtles found in the U.S. are listed as either endangered or threatened under the 

ESA and therefore are afforded its protections. NOAA-NMFS and USFWS have joint jurisdiction for sea 

turtles in accordance with a Memorandum of Understanding (MOU) between the two agencies 

(Appendix 16). NOAA-NMFS primarily oversees ESA-related responsibilities for sea turtles in the marine 

domain, whereas USFWS has primary responsibility in the terrestrial environment; however, efforts 

expended by both agencies frequently overlap (e.g., recovery planning, stranding response).

The listing of a species as endangered makes it illegal to "take" that species. “Take” is broadly 

defined as to “harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or attempt to 

engage in any such conduct” (16 USC § 1532[19]). Similar prohibitions extend to threatened sea turtle 

species. Notably, ESA also protects against the adverse modification of critical habitat (§ 4), which 

includes designated areas (land or water) with physical and biological features necessary to recover 

species listed under the ESA. Section 7 of the ESA requires consultation by federal agencies conducting 

activities that may affect listed species. Section 7 consultations may result in the issuance of a Biological 

Opinion which may include an Incidental Take Statement that specifies the anticipated take (lethal 

and/or non-lethal) that is expected to occur during the action. Section 10(a)(1)(A) of the ESA may 

authorize take for scientific purposes or to enhance the propagation or survival of the listed species

through 10(a)(1)(A) permits. Section 10(a)(1)(B) of the ESA may authorize take incidental to (not the 

purpose of) otherwise lawful non-federal activities through a 10(a)(1)(B) permit and an associated 

Habitat Conservation Plan.

Many of the oil spill response actions involving sea turtles and their habitats fall under ESA 

prohibitions. The USCG or EPA serve as the FOSC, and have full oversight over oil spill response, thus 

making it a federal action. Therefore, the federal action agency, represented by the FOSC, is responsible 

for initiating ESA Section 7 consultation (including emergency consultation) with NOAA-NMFS and 

USFWS for any response activities that might affect sea turtles. In such emergencies, consultation is 

expedited so that federal agencies can complete their missions in a timely manner, while still 

maintaining compliance with the ESA and providing protections to listed species. Oil spill planning and 

response duties under the ESA are addressed specifically in a Memorandum of Agreement (Appendix 

16) among the USCG, EPA, USFWS, and NOAA (NMFS and NOS). 

Section 7 consultation does not stand in the way of oil spill response. An emergency response action 

is the only circumstance under which federal agencies may initiate ESA consultation after an action is 

implemented. For example, during the Deepwater Horizon (DWH) spill, the USCG coordinated with 

federal agencies to obtain recommendations for avoiding and minimizing adverse effects of response 

activities to listed species and critical habitats. The USCG Biological Assessment of the Action, which 
17

accompanied its request to initiate consultation, described how these recommendations were 

implemented, and assessed the effects of the action after-the-fact. A typical Biological Opinion for a 

proposed federal action prospectively examines whether an action is likely to jeopardize species or 

destroy or adversely modify critical habitat. In contrast, a post-incident response consultation assesses

whether the completed action jeopardized species or destroyed/adversely modified critical habitat, 

examines how the action changed the status of the listed species and critical habitats, and provides 

conservation recommendations to inform planning for responding to future oil spills. All discretionary 

USCG involvement is terminated when the action is concluded. 

Emergency Section 7 consultation only includes take related to response activities, not take resulting 

from the oil spill itself. In addition, activities beyond oil spill response actions that involve sea turtles, 

such as projects implemented or studies undertaken under NRDA, may require an ESA Section 7 

consultation or an ESA Section 10 permit. This permitting process may include review and comment 

periods; thus, the need for ESA permits should be anticipated early in NRDA planning. Furthermore, 

authorizations from USFWS (or state if under delegated authority) also are required for the 

transportation and possession of sea turtles (live or dead) or any parts of sea turtles (e.g., biological 

samples). The relevant permitting offices should be consulted to determine permit requirements and 

the most appropriate, efficient means of application preparation and review.

In addition, under the ESA, enforcement actions may be taken against a RP for unauthorized take 

associated with an oil spill. These actions may result in civil or criminal charges. ESA enforcement 

investigations are performed and funded separately from both the OPA response and the NRDA, 

although information may be used for both NRDA and ESA enforcement actions.

2.1.3. National Environmental Policy Act 

The National Environmental Policy Act (NEPA) of 1970 establishes a policy to “foster and promote 

the general welfare, to create and maintain conditions under which man and nature can exist in 

productive harmony, and fulfill the social, economic, and other requirements of present and future 

generations of Americans” (42 USC § 4331). NEPA's basic policy assures that federal agencies give 

proper consideration to the environment prior to undertaking any major federal action that will have 

significant environmental effects and to encourage and facilitate public involvement in decisions which 

affect the quality of the human environment (40 CFR § 1500.1). NEPA applies to restoration actions by 

Federal Trustees, except where a categorical exclusion or other exception to NEPA applies (15 CFR § 

990.23).

2.1.4. National Marine Sanctuaries Act 

The National Marine Sanctuaries Act (NMSA) of 1972 gives the Secretary of Commerce the authority 

to designate and protect areas of the coastal and marine environment that prove to be of special 

national significance due to their conservation, recreational, ecological, historical, scientific, cultural, 

archeological, educational value, or for esthetic qualities. Living marine resources, including sea turtles, 

are included under NMSA. Sites designated as national marine sanctuaries are managed by NOAA’s 
18

Office of National Marine Sanctuaries (ONMS). ONMS also manages/co-manages two of four Marine 

National Monuments designated under the Antiquities Act and one Coral Reef Ecosystem Reserve.

NMSA provides regulations for each sanctuary that specify which activities are allowed and which 

are prohibited. The Act has a consultation requirement under § 304(d) for any federal activity that could 

impact site resources. The NMSA also provides for both civil penalties (under § 307) and for NRDA 

damages (under § 312). The NRDA authority parallels those found in OPA, the Comprehensive 

Environmental Response, Compensation, and Liability Act (CERCLA), and the System Unit Resource 

Protection Act (SURPA). Under § 310 of the Act, NMSA permits are issued for otherwise prohibited 

activities. Sanctuary superintendents hold permits for a range of activities within sites that generally 

include those that may occur during an oil spill response.

It is unlawful to destroy, cause the loss of, or injure any sanctuary resource. Site-specific regulations 

may include “enter and injure” provisions. Federal agencies are required to consult on actions that 

would harm sanctuary resources under § 304(d). Site-specific exemptions are found in site regulations. 

Emergency response activities are generally exempt.

During oil spills that affect marine sanctuaries, ONMS is active in the planning and operations 

section of the response protocol to provide information on avoiding or minimizing harm to sanctuary 

resources. ONMS may participate as part of the NRDA, depending on the complexity of the spill, 

resources affected, and expertise available. 

Six National Marine Sanctuaries (NMS) have significant sea turtle presence for at least part of the 

year, including Gray’s Reef NMS (Atlantic), Florida Keys NMS (Gulf of Mexico), Flower Garden Banks 

NMS (Gulf of Mexico), Papahānaumokuākea Marine National Monument (Pacific), Hawaiian Islands 

Humpback Whale NMS (Pacific), and the NMS of American Samoa (Pacific). Sea turtles also are present 

to some degree (either in lower numbers or transiently) in sanctuaries off the coast of California, 

including Monterey Bay, Cordell Bank, Channel Islands, and the Greater Farallones, as well as Stellwagen 

Bank NMS (Atlantic) and Monitor NMS (Atlantic). A map of these sanctuaries and monuments can be 

found at https://sanctuaries.noaa.gov/.

2.1.5. System Unit Resource Protection Act

Similar to the NMSA for marine resources under the DOC, the SURPA (54 USC 100721-100725) of 

1996 requires the Secretary of the Interior to assess and monitor injuries to resources within the 

National Park System. Response costs and damages may be recovered from the RP to reimburse for 

expenses created by a spill and restore, replace, or acquire resources and/or their services equivalent to 

those that were lost. A large number of federally protected coastal and insular lands are under the 

jurisdiction of the NPS and are covered under SURPA, such as the Padre Island National Seashore, 

Canaveral National Seashore, Dry Tortugas National Park, and U.S. Virgin Islands National Park. A 

complete list of national parks can be found at https://www.nps.gov/hfc/cfm/carto.cfm.
19

2.1.6. State resource agencies and applicable legislation

Sea turtles also are protected by certain state laws and local regulations, which may be similar 

to or exceed protections of the ESA. For example, Florida has the Marine Turtle Protection Act, which 

provides explicit protections to sea turtles and their habitats, similar to ESA, and requires a state-issued 

permit for all conservation activities and provides a framework for review of coastal construction that 

may affect sea turtles, their nests, or hatchlings. Some of the other states have similar laws. In addition, 

the USFWS has entered into a cooperative agreement, in accordance with Section 6 of the ESA, with 

state resource agencies in Florida, Georgia, Florida, South Carolina, and North Carolina to carry out the 

activities identified in their sea turtle conservation programs.

2.2. Sea turtle stranding networks

Oil spills affecting sea turtles likely will require engagement of stranding networks, which respond to

and document dead and impaired sea turtles in coastal areas. Under their shared jurisdiction and MOU, 

NOAA-NMFS and USFWS oversee operations of these stranding networks. NMFS has the primary 

coordination role to ensure that data are collected in a manner sufficient for conservation management, 

monitoring, and research purposes and to facilitate its use to meet ESA recovery objectives. The USFWS 

(or state resource agency in accordance with 50 CFR § 17.21[c][3]) issues the actual authorization 

(designation of agents) for stranding response and rehabilitation activities. Three sea turtle stranding 

networks cover the geographical areas included in these guidelines and are described below. These 

networks involve both governmental and non-governmental participants (including volunteers), 

depending on the area. Responders undergo training in procedures and methodologies as part of the 

permit authorization requirements. Some organizations and individuals participate in both sea turtle and 

marine mammal stranding response, but mammal and sea turtle networks generally function as 

separate entities in most instances. Stranding networks likely 

continue to operate during an oil spill, although additional human 

safety, documentation, and reporting requirements typically are 

required (see Section 3.4.6).

Under standard operations (outside of a spill event), 

disposition of stranded sea turtles varies among and within networks according to resources and 

management needs. Unless there are extenuating circumstances, all live turtles are recovered for 

medical evaluation and possible rehabilitation. With regard to sea turtles that are found dead, generally 

only those with minimal or no decomposition are collected for necropsy under laboratory conditions. In 

some circumstances, decomposed turtles and/or those in which collection is impractical (e.g., large 

animals, remote locations) receive examinations in the field and are then buried on-site or disposed of 

by other means. Decisions on which animals are salvaged for a more thorough necropsy, including those 

that are more decomposed, are often dictated by management priorities or characteristics of sea turtle 

mortality within a given region. Note that the convention used to designate the condition of stranded 

sea turtles (i.e., live, degree of decomposition) may be different than that used by mammal stranding 

networks. 

Stranding– refers to any sea turtle found on 

land or in water that is either dead or 

incapable of normal activity or behavior (e.g., 

swimming, diving, foraging) due to any 

illness, injury, or other problem.
20

Standardized stranding report forms are completed for all documented turtles. These data forms 

document stranding location, date, species, biomorphometrics, samples collected, condition (live or 

degree of decomposition), presence of any identifying tags, and major external abnormalities (see 

Appendix 8). 

2.2.1. Atlantic, Gulf of Mexico, and U.S. Caribbean 

The Sea Turtle Stranding and Salvage Network (STSSN) operating in the Gulf of Mexico and along the 

U.S. Atlantic coast (and U.S. Caribbean) officially came into existence in the early 1980’s. The STSSN is 

coordinated nationally by the STSSN Coordinator (located at the NOAA-NMFS Southeast Fisheries 

Science Center, Miami Laboratory), NOAA’s National Sea Turtle Coordinator (NOAA-NMFS Office of 

Protected Resources, OPR), and NOAA’s Sea Turtle Veterinary Medical Officer (NMFS-OPR). In addition, 

a Northeast Regional STSSN Coordinator is housed at the NMFS Greater Atlantic Regional Fisheries 

Office. Each state, as well as Puerto Rico and the U.S. Virgin Islands, is served by one or more State 

Coordinators who manage the day-to-day operations of the STSSN in their respective state. Many of 

these coordinators are federal or state resource agency personnel that coordinate networks comprised 

of other agency employees, non-governmental organizations, and volunteers. The data collected in each 

state are contributed to the national database housed at NOAA-NMFS (managed by STSSN Coordinator).

2.2.2. Pacific Islands, Hawaii, and American Samoa

The NOAA-NMFS Pacific Island Fisheries Science Center, Marine Turtle Biology and Assessment 

Program (MTBAP) coordinates the sea turtle stranding program in the Hawaiian Archipelago. This 

activity is in partnership with NOAA-NMFS Pacific Islands Regional Office, the state of Hawaii 

Department of Land and Natural Resources, local universities, other organizations such as the Hawaii 

Marine Animal Response network and the Maui Ocean Center Marine Institute, and volunteers. In 

American Samoa, the Department of Marine and Wildlife Resources of the American Samoan 

government coordinates strandings mainly on Tutuila island with opportunistic reporting from the 

Manua Islands (Ofu, Olosenga, and Tau), and Rose Atoll by USFWS and the MTBAP when surveys are 

performed. In Guam, the Department of Aquatic and Wildlife Resources of the Guam government 

coordinates the stranding response program in collaboration with other federal agencies such as the Air

Force and Navy. In the Commonwealth of the Northern Mariana Islands (CNMI), the Department of Land 

and Natural Resources of the CNMI government coordinates stranding response on the islands of 

Saipan, Tinian, and Rota.

2.2.3. Pacific coast, continental U.S.

The NOAA-NMFS West Coast Regional Office (based out of Seattle, Washington and Long Beach, 

California) coordinates the stranding network for the Pacific coast of the continental U.S. As in other 

regions, this network relies on non-governmental participants, including personnel affiliated with 

aquaria and rehabilitation organizations. NOAA’s Southwest Fisheries Science Center is also involved in 

responding to strandings and provides rehabilitation facilities with recommendations on timing and 

location of sea turtles releases following treatment. This region typically has less than 50 strandings per 

year (compared to the thousands on the Atlantic and Gulf coasts and hundreds in the Pacific Islands).
21

3.1. General

As described in Section 2, there are a number of statutes that govern how the planning and 

response to oil spill incidents occur in the U.S. and its territories. The National Oil and Hazardous 

Substances Pollution Contingency Plan (NCP) provides key planning and response elements, including 

the establishment of a three-tiered contingency planning process, which consists of the National or 

Regional Response Teams (NRT and RRT, respectively), Area Committees (required to develop Area 

Contingency Plans [ACPs]), and owners and operators of vessels and other facilities that hold or 

transport oil (required to develop Facility Response Plans). It is important for planning efforts to 

consider wildlife concerns, including sea turtles, so that appropriate, timely actions are taken in the 

event of a spill.

Efforts to avoid and minimize harm to wildlife during an oil spill and collect information related to 

exposure and injury are pursued to the extent feasible in the context of broader response activities, 

which include halting and containing the discharge, recovering as much oil as possible from the 

environment, and securing human health and safety in the process. The reality of response to an oil spill

means that allocation of effort and response assets must be well-organized and prioritized to ensure 

maximum effectiveness, especially during the initial period when there is the greatest potential to avoid 

or minimize negative effects. Thus, it is imperative for individuals responsible for wildlife response to 

understand the framework of spill response operations in order to clearly and effectively communicate 

needs and animal concerns. In addition, clear explanation of the need for specific response measures 

and timely, effective communication of observations and their importance are necessary to justify 

expenses. Human and material resources available for wildlife during an oil spill are not limitless. 

This section is divided into three additional subsections. Subsection 3.2 outlines the process of 

alerting government agencies in the event of a spill, mobilizing resources, and response operations.

Subsection 3.3 introduces key elements of response to a spill within areas inhabited by sea turtles and 

discusses important considerations for the different sea turtle life stages and their habitats. Subsection 

3.4 presents operational activities that may be undertaken to rescue, protect, and document sea turtles 

and their nests during an oil spill. In addition, specific protocols and data forms are provided as 

references in the Appendices and are referred to throughout Subsection 3.4. These materials are based 

on experience obtained from previous spills and can be modified if necessary to meet the specific needs 

of future incidents. It is important to note that every oil spill is different. Some are smaller and relatively

manageable; others are larger or more protracted and present many challenges. This section 

comprehensively reviews various aspects of response that are relevant to sea turtles, but efforts 

inevitably should be appropriately scaled and adapted to the unique circumstances of each oil spill.

3. Key elements of oil spill response and operational 

considerations for sea turtles
22

Information collected during response may be crucial for the Natural Resource Damage Assessment

(NRDA). Although individuals working on oil spill response may not necessarily be involved with NRDA, 

and vice versa, it is important for these efforts to be closely coordinated. Section 4 provides detailed 

discussion of NRDA considerations for sea turtles.

3.2. Notification, activation, response structure

3.2.1. Incident reporting and resource activation 

When an oil spill occurs within waters of the U.S., there are specific reporting requirements 

mandated by the Federal Government, through the National Response Center (NRC). Once the NRC 

receives the report, notification is made to a U.S. Coast Guard (USCG) or Environmental Protection 

Agency Federal On-Scene Coordinator (FOSC), who determines whether further federal action is 

required. If the FOSC determines that federal involvement is required, he/she assumes control of all spill 

response operations at the site as part of the initial Incident Command System (ICS), and obtains and 

directs all needed resources. If adequate personnel, equipment, and other necessary support are not 

available through the Responsible Party (RP), the FOSC can activate additional spill contractors using 

funds from the Oil Spill Liability Trust Fund (OSLTF, administered by the USCG’s National Pollution Funds 

Center [NPFC]), as well as activate the RRT to provide broader technical advice, equipment, or 

personnel. As part of this activation process, the FOSC notifies federal and state agencies about the 

potential impact to natural resources under their ownership, management, or control. Oil spill 

notification schemes within agencies vary. Those for the National Oceanic and Atmospheric 

Administration (NOAA) and U.S. Fish and Wildlife Service (USFWS) are presented in the next subsection.

Once agency notification has occurred, NMFS-OPR, USFWS, and other DOI bureau (as appropriate) sea 

turtle programs coordinate on response activities and stranding response needs under their joint

jurisdiction over these species. Each agency will obtain a Pollution Removal Funding Authorization 

(PRFA) from the FOSC to support response costs. These OSLTF monies are then tracked by each agency 

and amendments and cost documentation reports submitted to the NPFC.

Notification

For NOAA, notification of spills potentially impacting marine animals, including sea turtles, will most 

likely occur through the Scientific Support Coordinator (SSC) who is within NOAA’s Emergency Response 

Division (ERD) and provides directed support to the FOSC. NOAA staff also may be notified by the FOSC 

directly, or through a Liaison Office, or through a party or mechanism designated within the ACP or the 

RP’s response plan. If the USCG is not involved or NOAA-ERD is not activated, NOAA staff sometimes 

also find out about developing incidents from state and federal colleagues, members of the public, or 

the media. Once NOAA-ERD is involved, an incident is created in the internal NOAA website

ResponseLink, which provides current information and updates about the spill and response. Email 

notification via ResponseLink is another means by which NOAA staff may be notified of spills.
23

With regard to agencies within the DOI, which include USFWS and the National Park Service (NPS), 

the FOSC is obligated to notify the Regional Environmental Officer (REO), from the Department's Office 

of Environmental Policy and Compliance (OEPC). The REO then relays the notification to each affected 

bureau. The REO will then notify affected USFWS Regional Spill Response Coordinators (RSRCs) and Field 

Spill Response Coordinators (FSRCs).

For an oil spill within areas inhabited by sea turtles (see Chapter 1), four key groups should be 

notified: 1) National Sea Turtle Program staff within NOAA/National Marine Fisheries Service (NMFS) 

Office of Protected Resources (NMFS-OPR), 2) USFWS local Ecological Services Field Office and the 

USFWS Field or Regional Spill Response Coordinator, 3) the nearest NOAA-NMFS Regional Office (NMFSRO) and Science Center (NMFS-SC) and 4) the state natural resource agency(ies) that manage sea turtles

within the area of the spill (Figure 3-1). Additional confirmatory notification among NMFS-OPR, USFWS, 

and other DOI bureaus (including but not limited to NPS and USGS), NMFS-RO/NMFS-SC leads, and state 

agency leads should be undertaken to ensure awareness of a spill. NMFS-OPR and the USFWS Field Spill 

Response Coordinator coordinate an agency assessment of the need for wildlife response and 

determines the optimal protection methods. Notification of the NMFS-RO and the USFWS local 

Ecological Services Field Office is required for Endangered Species Act Section 7 consultation. For a 

larger spill, the neighboring RO/SC also may be notified. NMFS-OPR ensures notification of the National 

Stranding Coordinator, regional coordinator, and relevant state stranding coordinators. These 

individuals also may be notified through other means depending on their agency affiliation. Depending 

on the type of response required (i.e., deployment of vessels, initiation of aerial surveys, enhancement 

of stranding response, preparation of rehabilitation facilities, or enhanced efforts on nesting beaches), 

NMFS-OPR and USFWS also contact other state and federal agencies, organizations, and institutions for 

assistance, as needed. A link to an updated web-based directory of personnel and contact information is 

provided in Appendix 1.

Figure 3-1. Personnel notification for threatened and endangered 

sea turtles in the event of a marine oil spill. Note that notification of 

specific personnel within or associated with these entities should be 

included in internal protocols and Area Contingency Plans. Note: the 

Department of the Interior should be consulted for prefered 

notification of its bureaus and personnel.
24

Once the appropriate regional stranding network is alerted, it is placed on standby for possible 

mobilization under wildlife operations as part of the ICS, as outlined in the next section. If a state agency 

or stranding network organization is contacted directly by a RP or their representative regarding a spill, 

they should immediately contact their stranding coordinator, who should then notify the NMFS-OPR 

National Sea Turtle Program to ensure coordination within the ICS, across the range of the spill, and 

across levels of responsible governmental authorities.

In some instances, individual oiled sea turtles may be encountered by the public and/or wildlife 

professionals without a spill being reported (e.g., from illegal discharges, unreported spills, natural 

seeps, animals entering waste facilities, non-petroleum oils from fishing activities). The presence of 

these oiled sea turtles does not normally necessitate activation of an oil spill response, yet the sea turtle 

stranding response community is often placed in a situation where recovery and rehabilitation is 

warranted. Additionally, these turtles may be the first evidence that a spill has occurred or is occurring, 

so these data may be important for subsequent response. At a minimum, individual oiled sea turtles will 

be documented according to standard regional stranding protocols and collected for further 

examination and sampling whenever possible. Multiple strandings of oiled sea turtles occurring within a 

short period of time (days to weeks) will be immediately reported to the NMFS-OPR National Sea Turtle 

Program by the state or regional stranding coordinator who will report the incident to the National 

Response Center (1-800-424-8802) to determine whether further investigation or other action is 

warranted.

3.2.2. Incident Command System 

All oil spill responses in the U.S. are managed under an ICS structure as standardized by the National 

Incident Management System (NIMS) and modified for oil and hazardous substance spill response by the 

NRT (USCG 2014). The ICS is modelled after military chain of command and was originally developed for 

fighting wildfires. Leading the response is the Unified Command (UC) made up of the FOSC (usually a 

Coast Guard Captain of the port for the affected area), a State On-Scene Coordinator (SOSC), and a 

qualified individual from the RP, if known and applicable. The NRT may be activated in addition to RRTs

to support the FOSC. When appropriate, tribal or local government representatives also are included in 

the UC. The FOSC has the ultimate responsibility for directing the oil spill response if a consensus cannot 

be reached among the members of the UC. Directly assisting the UC are several individuals or groups 

serving in Command Staff functions. These include: 

 Information Officer: responsible for developing and releasing information about the incident, 

often generated through a Joint Information Center (JIC) that he/she manages. 

 Liaison Officer: responsible for coordinating input from, and delivering information to, those 

agencies that are not represented within the UC. These responsibilities also include functions 

that are not necessarily represented within the response structure, such as NRDA, law 

enforcement, and land management agencies (e.g., refuges and parks). 

 Safety Officer: responsible for developing and recommending measures for assuring personnel 

safety, including the drafting of Site Safety Plans (SSPs).
25

 Scientific Support Coordinator (SSC): principal advisor to the FOSC for scientific issues. Generally,

SSCs and their Scientific Support Teams (SSTs) are provided by NOAA in the coastal zones and by

EPA in the inland zones. The FOSC can request SSC support directly from the SSC assigned to the

area or from a RRT member. Responsibilities of the SSC include: determine resource needs,

identify resources at risk, facilitate issues related to protected species (including Section 7

consultation), integrate knowledge from governmental and non-governmental sources, facilitate

coordination between response and NRDA, and serve other roles. Within USFWS, the Spill

Response Coordinator or other positions also can provide similar support.

Key activities within the spill’s ICS are broken down into the following four discrete Sections, each with a 

Section Chief that acts as General Staff to the UC: 

 Planning: responsible for the collection, evaluation, dissemination, and use of incident

information, including maintaining status of assigned assets. This is primarily accomplished

through the completion of Incident Action Plans (IAPs), which describe project plans and human

and physical resources needed for the next operational period. The Environmental Unit is

included within the Planning Section. The SSC coordinates with the Environmental Unit Leader.

 Operations: responsible for all tactical operations, including recovery/protection, air support,

and wildlife operations.

 Logistics: responsible for providing facilities, services, and material in support of the incident.

 Finance/Administration: responsible for all financial, administrative, and cost analysis aspects of

the incident.

Figure 3-2. Organizational chart of an Incident 

Command Structure showing the location of the Wildlife 

Branch and Environmental Unit. Members of Unified 

Command are shown in blue, Command Staff are in 

yellow. The primary sections of response are in orange.
26

Coordination of response activities directed at wildlife – including reconnaissance, deterrence of 

wildlife from affected areas, capture and care of affected wildlife – usually occurs within the Wildlife 

Branch, which works under the Operations Section within the ICS (Figure 3-2). Notably, other actions 

related to wildlife, and sea turtles specifically, may occur within the Environmental Unit of the Planning 

Section. These activities include identification of natural resources at risk, assessment of ESA Section 7 

issues, GIS/mapping services, provision of trained wildlife observers (including Resource Advisors 

(READs) on federal lands, and Natural Resource Advisors (NRAs) on non-federal lands) to monitor 

response operations and collection of oiled shoreline information. The Environmental Unit also provides

Best Management Practices (BMPs) for minimizing impacts from response and it is the role of READs and 

NRAs to ensure compliance with BMPs by response personnel. Data management also is within the 

Planning Section and determines procedures related to handling, collection, and storage of the many 

types of data that may be generated by wildlife operations (e.g., photographs, data forms, records). The 

Logistics Section enlists and deploys equipment and personnel.

Guidance for dealing with oiled wildlife is not specifically provided in the National Oil and Hazardous 

Substances Pollution Contingency Plan; therefore, the Wildlife Branch operational plan is developed 

uniquely within each Regional and Area Contingency Plan based on the specific natural resources 

present locally and with federal agency involvement.

The principal objectives of the Wildlife Branch are to: 

 conduct all operations in a safe manner for people and wildlife;

 minimize injuries to wildlife and habitats from the contamination;

 help minimize injuries to wildlife and habitats from the response effort;

 provide the best achievable care to impacted and/or threatened wildlife;

 collect all data, samples, and animals in a manner that fulfills legal requirements;

 document for the UC (and potentially other efforts) the immediate impacts to wildlife of the oil

spill and response operations;

 report to the UC (via the Operations Section Chief) in a timely and complete manner all

pertinent data and information necessary to ensure clarity of wildlife operations; and

 support the efforts of the JIC in disseminating information (much of which may be real-time) to

the media, public, and other interested parties.

To ensure that these objectives are achieved with maximum efficiency, the Wildlife Branch manages 

and coordinates the activities of the federal, state, and local agencies along with commercial and nonprofit organizations responsible for sea turtle protection and management who fall under the authority 

of the UC during spill response. In addition, for sea turtles, coordination with permit holders who may 

already be conducting studies in the area potentially impacted from the oil spill may be helpful.

Development and implementation of a sea turtle response plan ensures timely mobilization of 

dedicated staff, equipment, and volunteers. The size of the wildlife response effort is flexible and 

scalable to the magnitude of the oil spill such that only those positions necessary and appropriate for a 

specific spill incident are filled. Once the UC activates the Wildlife Branch, several components of oiled 

wildlife response targeting sea turtles may be initiated: reconnaissance to determine what sea turtle 
27

Figure 3-3. Example organizational chart 

of an Incident Command Structure for an 

oil spill affecting sea turtles. A Personnel 

Coordinator may be needed for large 

units and is shown here under the 

Rehabilitation Unit as an example.

species and habitats are at greatest risk; search and rescue for live and dead oiled sea turtles;

reconnaissance of sea turtle nesting and protection of nests; treatment and rehabilitation of oiled sea 

turtles; release and monitoring of recovered sea turtles; and other response activities, as needed.

Depending on the size and scope of the spill, NOAA or DOI may determine that physical presence in 

the Incident Command Post is necessary to effectively and efficiently communicate information 

regarding sea turtle concerns to the FOSC. If not, the response will be operated remotely with NMFSOPR and DOI serving a lead coordination role. The command structure may be relatively simple for 

smaller spills or complex for larger ones. Figure 3-3 shows a hypothetical structure of a designated Sea 

Turtle Group within the Wildlife Branch and identifies lead positions that coordinate primary types of 

operations. A Veterinary Officer may act as an assistant to the Group Supervisor because medical and 

medicolegal issues related to animal welfare, treatment, and postmortem examination are inherent to 

most types of operations. In addition, a Data Coordinator also assists the Sea Turtle Group Supervisor by 

managing and summarizing sea turtle-related information collected under field operations, creating 

products necessary to inform these operations (e.g., maps, oil forecast information, prohibited areas), 

coordinating with the Response and NRDA Data Management Leads to share agreed-upon data with 

other responders, and fulfilling any data reporting required by the UC. For a large-scale spill, additional 

coordinators to oversee units for stranding response, directed capture efforts, rehabilitation activities,

nesting activities, and observer functions may be added to organize logistical support and liaise with 

other operations. Also, additional coordinators may be necessary to organize enlistment and 

deployment of personnel for functions that require larger numbers of people. In smaller spills, these 

units can be combined as appropriate. 
28

Although different wildlife taxa might be grouped under the command structure for some purposes, 

it is important to note that different groups (i.e., birds, mammals, sea turtles) draw upon different types 

of resources and experts that are not necessarily universal or well-known to those that do not work with 

these taxa. Therefore, for larger spills taxa-specific groups within the Wildlife Branch are strongly 

recommended as the most effective. Branch positions that address sea turtle needs should be staffed by 

individuals familiar with sea turtles and ICS from federal and state resource agencies. All groups still 

report to the Wildlife Branch Director.

The Wildlife Branch coordinates response activities and information collection across resources to 

the extent feasible, particularly where response activities are implemented in areas where multiple 

types of wildlife co-occur and might be affected simultaneously. Wildlife operations targeting specific 

taxa (e.g., birds) may opportunistically assist or document other animals and should have the necessary 

operational flexibility and appropriate instructions. Similarly, efforts to contain and remove oil from the 

marine or terrestrial environments should include trained wildlife observers (see definition in Appendix 

5) from the onset of response activities. It can be difficult to find sufficient numbers of properly trained 

observers for a large spill. The need for observers should be identified early in the planning process so 

that appropriate training can be accommodated.

3.3. Quick reference: oil spill response considerations for sea turtles by life stage

and habitat

This subsection provides a quick reference for response considerations for sea turtles during an oil 

spill by ecological zone and life stage that may be impacted. Specific bulleted response elements

discussed herein (Table 3-1) are covered in additional detail under Operational Guidelines in Subsection

3.4. The colored tabs within the right margin provide hyperlinks and page references for specific 

sections where more information can be found. In addition to the specific considerations provided for 

each ecological zone, response to an oil spill involving any of these zones typically entails early 

preparation of the relevant stranding network and area rehabilitation facilities, which is covered in 

Subsections 3.4.6 and 3.4.7, respectively.

As discussed in Section 1, sea turtles exhibit complex life history traits, population characteristics, 

and differential habitat use patterns that must be accounted for when planning and implementing oil 

spill response and NRDA activities. Below, specific considerations are discussed for life stages found in 

three primary ecological zones that may be affected by an oil spill: the terrestrial zone (nesting beaches), 

the oceanic zone (offshore areas greater than 200 m deep), and the neritic zone (continental and insular 

shelves/nearshore waters less than 200 m deep) (Bolten 2003). In addition, the temporal occurrence of 

different life stages of the sea turtle species within regions of the U.S. and its territories is summarized in 

Appendix 3. Decisions related to intervention, such as capture of turtles or manipulation of nests, 

consider a number of different factors unique to each spill, including the magnitude of the threat posed 

by a spill, risks to specific life stages, potential benefits and negative consequences of different actions, 

and logistics.

See Section 

3.4.6, pg. 42

See Section 

3.4.7, pg. 45
29

Table 3-1. Response considerations for sea turtles by ecological zone and life stage.

Nesting beaches (terrestrial zone) Open ocean (oceanic) zone Nearshore-shelf (neritic) zone

Eggs, hatchlings, nesting females Post-hatchlings, small juveniles Large juveniles, adults

Engage nesting monitoring & stranding 

response programs

 Understand current status & 

location of nests and nesting 

activity

 Monitor beaches for impacted 

nests and turtles

Engage stranding response network

 Respond to reports of oiled, dead, or 

debilitated sea turtles

 Ensure adequate surveillance of spill 

area

Engage stranding response network

 Respond to reports of oiled, dead, or 

debilitated sea turtles

 Ensure adequate surveillance of spill 

area

Prepare rehabilitation facilities

 Respond to any live turtle needs

Prepare rehabilitation facilities

 Respond to any live stranded turtles

 Support rescue operations

Prepare rehabilitation facilities

 Respond to any live stranded turtles

 Support rescue operations

Communicate with shoreline response 

operations

 Minimize disruption of nesting

 Minimize damage to nests; injury 

of nesting turtles

Communicate with offshore response 

operations 

 Minimize impacts on sea turtles & 

habitat

o Controlled burns

o Booming/skimming

Communication with nearshore response 

operations 

 Minimize impacts on sea turtles &

habitat

o Controlled burns

o Booming/skimming

Protect eggs & hatchlings

 In situ

 Ex situ

Deploy response vessels to survey slicks 

& convergence fronts for pelagic turtles

 Rescue any oiled turtles

 Document live and dead sea turtles

(including whether visibly oiled) in 

spill area

Deployment of aerial surveys 

 Inform response operations regarding 

sea turtles & habitat within spill area

Deploy response vessels to survey oiled 

area for turtles

 Rescue of any oiled turtles

 Document live and dead sea turtles

(including whether visibly oiled) in spill 

area

Deployment of aerial surveys 

 Inform response operations regarding 

sea turtles within spill area

Nesting beach (terrestrial) zone

Sea turtle nesting beaches are especially vulnerable to oil spills because spills often occur near shore 

or oil is eventually deposited on shorelines by wind and currents. Oil impacting nesting beaches can 

have a number of harmful effects on sea turtles depending on the timing of the spill relative to egg 

laying, incubation, and emergence of hatchlings. Oil can cause embryo mortality and adversely affect 

development (Fritts and McGehee 1982; Bell et al. 2006; Van Meter et al. 2006). Hatchlings can easily 

become mired in oil as they emerge from their nest and transit to the ocean or as they attempt to swim 

to offshore areas. Nesting females may be exposed (repeatedly) as they crawl through contaminated 

areas or while they remain at sea near their nesting beaches between emergences. Unrelated to 

reproduction, green turtles in the Hawaiian Islands haul out onto beaches to bask and may be similarly 

exposed to oil.
30

Response operations on and adjacent to nesting beaches also pose significant threats to adult 

turtles, nests, and hatchlings (Figure 3-2). Clean-up and removal equipment can destroy nests and injure 

or kill nesting females and hatchlings, or deter nesting females from emerging onto beaches. Activity on 

nesting beaches and deployment of shoreline booms also may deter females from nesting, possibly 

causing them to forego reproduction (Lauritsen et al. 2017; DWH NRDA Trustees 2016). Booming 

material can entangle or otherwise entrap turtles, and lighting associated with clean-up activities can 

deter and/or disorient nesting females and disorient hatchlings. Adult turtles of both sexes may be at 

increased risk of being struck by watercraft involved in oil spill response activities.

With regard to protecting sea turtles, the first step in responding to an oil spill that threatens the 

terrestrial zone is to determine if sea turtle nesting or hatching is occurring within the area during the 

time of the spill. Primary nesting areas and seasons are provided in Appendix 2, Appendix 3, and 

Appendix 4. It is important to take into account ongoing nesting activities, as well as nesting events 

(emergence of females, hatching) that are expected to occur during the course of a spill or clean-up 

operations. In the U.S., nesting beach monitoring programs count and/or monitor nests primarily by 

conducting early morning daytime nesting surveys and evaluating turtle tracks to identify nests and non-

(A) (B)

(C) (D)

Figure 3-2. Examples of threats to sea turtles and nests posed by shoreline spill response activities. Booms (A, B) can 

obstruct access to nesting beaches or the water, and result in entrapment/entanglements. Clean-up by workers and 

heavy equipment (C, D) can destroy nests, injure sea turtles, and deter nesting.
31

nesting emergences (false crawls). Fewer programs conduct nighttime surveys to document nesting.

One notable exception to nighttime nesting is the Kemp’s ridley turtle, which commonly nests during 

the day. Nesting monitoring for Kemp’s ridleys in Texas occurs during daylight hours.

Year-to-year variability in the timing and magnitude of nesting is normal and results from a number 

of potential factors. However, the beginning and ending of nesting and hatching seasons are well 

defined (Appendix 4). Nest-monitoring programs are coordinated by the USFWS and the respective 

federal and state natural resource agency (see Appendix 1) and can provide valuable data and

information for particular locations. In the Pacific Islands region, nest-monitoring programs are managed 

or co-managed by the NMFS and private organizations. It is important to note that nesting surveys may 

only occur periodically, or not at all, on remote beaches or those where nesting is rare (e.g., Mississippi, 

Louisiana). If a spill occurs within a known nesting range and during the nesting season, it is prudent to 

assume nests are present even if nesting surveys have not been conducted.

Specific response measures to consider:

 Communication with shoreline response operations. Regular communication is required 

between the Wildlife Branch and shore-based operations under the Operation Section

(Shoreline Clean-up and Assessment Technique response, SCAT) to ensure BMPs are included in 

the IAP and made available to Operations Team Leaders. Changes to operational activities 

and/or awareness protocols, as necessary, can be made in the IAP typically through liaising with 

the Environmental Unit.

 Protection of eggs and hatchlings in situ. All shoreline operations should be evaluated for the 

need to deploy onsite observers to work directly with response personnel to protect and record 

any observable negative effects to sea turtles and/or their eggs and hatchlings. Sea turtle nests 

within response areas should be regularly monitored (minimum of daily) and clearly marked to 

identify their location and prevent accidental harm or destruction. Accurate GPS mapping of 

nest locations allows coordination of response activities and helps ensure protection of eggs and 

emerging hatchlings. Nests should be left in situ (or otherwise managed according to usual 

practices under non-spill conditions)1 unless there is high likelihood that nests and emerging

hatchlings will be injured by oil or oil spill response activities, and these injuries cannot be 

prevented. If a spill and beach-based response activities occur during hatchling emergence 

(Appendix 4), measures to protect hatchlings may be necessary. 

 Protection of eggs and hatchlings ex situ. Translocation of nests or hatchlings away from 

beaches affected by a spill to unaffected sites by experienced ESA-permitted personnel may be 

required for areas that may be heavily inundated by oil or under conditions where in situ

protection is impractical or unlikely to be effective. Examples include: an inability to protect 

nests from oil or response actions, or the presence of an oil spill in an area where hatchlings are 

expected to traverse (see Box 3-1). Specific execution of translocations, including release 

 

1Ex situ protection is a management practice of last resort in circumstances when threats have not been mitigated. 

These measures are used in some areas of Texas and to a lesser degree in some other states, principally 

because of beach driving.

See Section 

3.4.9, pg. 52
32

location and strategy, will depend on the logistical feasibility, risks to the incubating eggs and 

hatchlings (on the beach and in the water), and the timing of the spill relative to the stage of 

incubation.

 Nesting female considerations. For most sea turtle species, females primarily nest at night and 

are only encountered if nighttime surveys or response actions are conducted. An exception is 

female Kemp’s ridley turtles, which nest during the day and must be considered during response 

actions. Documentation of oiled females, including samples of oil may be desired to assist in 

documentation of the immediate effects of a spill for the UC, as may be relevant to wildlife 

response operations. As subsequently discussed, oiled female turtles are allowed to return to 

the sea unless they are debilitated and unable to do so.

Open ocean (oceanic) zone

Some sea turtle life stages and species are predominantly found in the oceanic zone (Section 1.2).

These turtles also may occur in shallower areas such as continental or insular shelf waters, but they 

most frequently are found distant from shore. The distribution and life history characteristics of sea 

turtles occupying oceanic habitats require specific consideration during an oil spill. In this section, 

threats and response measures are discussed for two general groups of turtles found in the oceanic 

zone: 1) oceanic juveniles and 2) large juveniles and adults.

Oceanic (surface-pelagic) juveniles

Much of this discussion pertains to oceanic juveniles of hard-shelled (cheloniid) species because 

small juvenile leatherbacks are rarely encountered and thus are poorly understood at this time. The 

oceanic juvenile life stage includes post-hatchlings, which are under 10 cm (straight carapace length, 

SCL) and have recently left their nesting beaches, and small juveniles less than 25 cm SCL (Witherington 

et al. 2012). Notably, this life stage for loggerheads in the Northwestern Atlantic Ocean can include 

animals up to about 60 cm in carapace length (Bolten 2003). Within waters of the U.S. and its territories, 

oceanic juveniles have been the most well-studied in the Northwest Atlantic and the Gulf of Mexico.

Box 3-1. Egg translocation during Deepwater Horizon oil spill. The largest nest transrelocation effort in response to an oil spill 

occurred during the DWH spill. Over 28,000 eggs (274 individual nests) were relocated from the Gulf of Mexico to the Atlantic

coast of Florida due to persistent oiling of offshore habitat into which hatchlings would swim. Nests were marked and left in situ

until within approximately 1 week of hatching to minimize movement-related mortality. It proved more logistically feasible to 

coordinate large-scale transport of eggs at the end of the incubation period rather than during the short period of safe-handling

immediately after laying. Eggs were transported in styrofoam 

coolers aboard designated, temperature controlled vehicles 

provided by FedEx. The hatching rate of translocated nests was 

similar to in situ nests (Provancha and Mukherjee 2001). Although

this effort accomplished animal welfare goals by preventing

hatchlings from entering oiled waters offshore from nesting

beaches, the magnitude and duration of the DWH spill required

that turtles be released into a different ocean basin. Therefore,

these hatchlings were considered lost to their natural, genetically 

defined populations under the NRDA. Photo courtesy of FedEx.
33

Although they certainly occur in the Pacific, they are not found in the same densities observed within 

frontal zones and Sargassum communities of the Atlantic and Gulf, at least within U.S. waters. Oceanic

juveniles can be predictably found year-round within offshore habitats of the Atlantic and Gulf. Their 

distribution and numbers vary depending on oceanographic conditions, time of year, and productivity of 

nesting beaches.

This early life stage is extremely vulnerable to oil spills because: 1) oil tends to collect within 

convergence fronts that provide important habitat for these turtles; and 2) the small size of these turtles

limits their ability to extricate themselves from surface oil (Figure 3-3). Small turtles can become heavily 

mired in oil and may not be able to escape, leading to physical exhaustion, inability to thermoregulate, 

and aspiration of oil (Stacy 2012; DWH NRDA Trustees 2016). In addition, as observed during the DWH 

spill, turtles may ingest oil as a consequence of indiscriminant feeding behavior or consumption of 

contaminated food items (Stacy 2012). These small turtles are difficult to see and are at risk from 

response operations during which they may be incidentally captured, injured by activities associated 

with skimming and booming, killed during controlled burns, and exposed to dispersants. Thus, the 

potential presence of these animals must be taken into account when developing any environmental 

benefit analysis or weighing alternative response techniques in open water.

Figure 3-3. Upper left: oil accumulation within a convergence front containing Sargassum seaweed (B. Witherington, 

FWC). Upper right: rescue of a heavily oiled oceanic juvenile Kemp’s ridley (T. Hirama, FWC). Lower left: Oil and 

Sargassum corralled for burning. Lower right: controlled burn of the material shown in the left image (M. Dodd, GADNR).
34

The following are response measures that should be taken to document and prevent (to the degree 

possible) injuries of oceanic juvenile sea turtles. Considering the high abundance of nesting sea turtles 

along the Southeastern U.S. and Gulf of Mexico coastlines, and the well-documented presence of 

oceanic juveniles originating from those beaches and other regions, dedicated effort should be 

considered for any spill that occurs within or enters offshore areas in the Northwestern Atlantic or Gulf of 

Mexico.

Specific response measures to consider:

 Communication with offshore response operations. All offshore operations, especially those

involving skimming and booming vessels and controlled burn teams, should be made aware of the

presence of small sea turtles and should have the means of rescuing animals from oil (Appendix 5).

Any operation that collects oil from the water surface has the potential to incidentally capture and

kill small sea turtles. Per pre-authorizations for burn operations, deployment of wildlife observers is

required to help sight and recover animals prior to igniting oil, especially if knowledge of a given

area and period indicate a high risk of interaction.

 Deployment of dedicated response vessels to survey slicks and convergences (directed capture).

Because oceanic juvenile turtles are primarily found far from shore, they are unlikely to be detected

by shore-based observations, such as stranding response. They are also too small to be seen from

aircraft used in standard aerial surveys. Miring in oil presents a significant threat to health and

survival of these turtles, thus rescue of oiled turtles may reduce mortality and help to address

animal welfare concerns associated with response activities. The co-location of oil and small turtles

within convergence fronts allows search crews to effectively target areas with greatest risk of

interaction. Oiled turtles can be safely collected using dip nets and transported to shore for deoiling, care, and treatment. In addition to instituting a successful rehabilitation effort towards

individual animals, information collected from these oiled turtles and associated sampling

(veterinary evaluations, necropsy findings, forensic analysis of oil) are also extremely valuable for

informing animal care protocols and documenting spill effects (Section 4).

Large juveniles and adults

Large juvenile and adult sea turtles also occur in the oceanic zone. Leatherbacks and olive ridley 

turtles are best known for inhabiting offshore areas, but other species also forage in or seasonally 

inhabit the oceanic zone, or may transit through it as they migrate between breeding areas and neritic 

foraging grounds or between/among foraging areas. Turtles are susceptible to exposure to oil, 

dispersants, and associated effects as they breathe or bask at the surface or potentially as they dive and 

feed within the water column. Density of turtles can be high in offshore areas where certain prey types 

(e.g., jellyfish) are abundant. As with smaller oceanic stage turtles, response personnel involved with 

offshore operations should be made aware of these animals and provided with information on how to 

report sightings and other observations.

See Section 

3.4.10, pg. 55
35

As discussed in the next subsection, feasibility of direct intervention (capture) of large juveniles and 

adults is limited due to their size, dispersed distribution, difficulty of capture in open water, and humanhealth/safety constraints of capture within a spill zone. This is especially true for leatherback turtles, 

which are very large (exceeding 150 cm in length and 400 kg) and difficult to keep in captivity. Dead or 

debilitated oiled individuals are recovered if possible. 

Specific response measures to consider:

 Documentation of large juvenile and adult turtles during a spill and response activities. 

Although direct intervention and capture of free-swimming large juvenile and adult sea turtles, 

particularly leatherbacks, is generally impractical, all observations of turtles within the spill area, 

including time, location, and oiling status, should be recorded as this information is valuable for 

response actions (to minimize potential injury from response actions) and NRDA. Documenting 

instances of turtles in oil or with oil on them, including by photography, is especially important.

 Aerial surveys. Although larger juvenile and adult turtles can be readily sighted from vessels, 

aerial surveys are a more effective method for observing them and should be conducted at 

multiple time points over the duration of a spill, if warranted. In addition to twin-engine aircraft 

that are often used or standard aerial surveys, smaller aircraft or unmanned aerial vehicles 

(UAVs) equipped with cameras may be advantageous under some circumstances (e.g., 

nearshore spills). 

Nearshore-shelf (neritic) zone 

Nearshore and inshore spills in almost all areas of the U.S. and its territories (except Alaska) have 

the potential to affect sea turtles. Sea turtles are found within bays, sounds, estuaries, tidal creeks, and 

open shelf waters, where they forage within many different habitat types, such as hard and soft bottom, 

seagrass beds, and various types of reefs. Man-made structures, such as rock jetties, also are used by 

sea turtles.

Sea turtles within the neritic zone are exposed to oil by many of the same routes discussed for other 

life stages. They are exposed to slicks and fumes when they surface to breathe or while resting or 

basking, they may ingest oil or oil-related compounds through contaminated prey or incidental ingestion 

of oil, and they may be exposed to submerged oil or oil entrained within sediments. The latter may 

occur when species such as loggerheads and Kemp’s ridleys dig into benthic sediments to capture

invertebrate prey (e.g., Burke et al. 1994; Frick et al. 2001). Less is known about the effects of oil on 

larger life stages of sea turtles as harmful effects have not been well documented during previous spills.

They have greater physical ability to escape surface oil compared to oceanic juveniles, but reports of 

sporadic strandings of larger, oiled turtles (Shigenaka 2003; Camacho et al. 2013) indicate that oiling can 

cause significant impairment, at least under some circumstances.

See Section 

3.4.11, pg. 57
36

As with other life stages, response operations can threaten sea turtles in nearshore areas. Increased 

vessel traffic can result in greater numbers of sea turtles that sustain vessel strike injuries. Turtles can 

become entangled in boom material and associated lines. Controlled burns, which typically are 

conducted offshore but may still overlap with neritic areas, also can injure or kill turtles that may remain 

at the surface if they are incapacitated or injured, or as they surface to breathe. 

Response efforts typically focus on providing aid to debilitated turtles that are stranded or found 

floating and collecting observational data that may help avoid injury to sea turtles by response 

operations. Directed capture of free-swimming oiled neritic phase juvenile and adult turtles (as 

performed with smaller life stages) poses a number of challenges and is likely impractical under many

circumstances for the following reasons: 1) turtles are relatively dispersed and spend 80-90% of their 

time submerged; 2) capture techniques within contaminated areas must not risk human health and 

safety from increased exposure to oil, which can preclude some common techniques such as netting and 

in-water hand capture of free-swimming turtles; 3) hard-shelled species often return to the area of 

capture, thus limiting the effectiveness of relocation as a means of deterrence; and 4) capacity to hold 

larger turtles in rehabilitation facilities for a prolonged period is relatively limited. The latter is a concern 

because most sea turtles will significantly injure each other if housed together, especially larger turtles

in close quarters.

Figure 3-4. Large juvenile or adult loggerhead turtle near an oil slick photographed during an aerial survey during the DWH spill.
37

Considering these challenges, the risks and benefits of proposed response actions must be carefully 

weighed. In addition to stranding response, actions targeting sea turtles in neritic habitats that are likely 

to be effective and produce useful data could include the following:

 Communication with clean-up operations. All operations working in inshore areas and 

shorelines should be made aware of the presence of sea turtles and be provided with a 

protocol for contacting Wildlife Branch personnel regarding any sightings of oiled turtles or 

turtles in distress. Specific protected species observers should be considered for any 

operations with a high likelihood of interaction with sea turtles (e.g., booming and collection 

of oil or burning of oil within areas of known high sea turtle density).

Vessel and aerial surveys. Depending on the size of the spill and location, both vessel-based 

and aerial surveys may be needed to document sea turtle presence and inform response 

actions related to sea turtles. Aircraft provide a superior means of detection of animals over 

40-45 cm (Figure 3-4), whereas vessels or other means are needed to detect smaller turtles, 

which often make up a significant proportion of sea turtles within a given area (Rees et al. 

2018; Sykora-Brodie et al. 2018). In addition, vessel observations are needed to aid any 

oiled, debilitated turtles and to document exposures of sea turtles to oil and environmental 

conditions on a finer scale and in more detail than is observable from manned aircraft.

Personnel with experience in capturing and sighting turtles should be deployed as a 

designated sea turtle response effort or embedded within other wildlife operations,

depending on the scale of the spill and response. Vessel crews should have the 

experience and equipment to capture debilitated oiled turtles and recover carcasses.

3.4. Operational guidelines

In this section, guidelines for conducting various common response operations and procedures 

are described, including evidence collection and handling, sampling and documentation, and specific 

response activities focused on documenting, rescuing, and rehabilitating sea turtles during an oil spill. 

These guidelines incorporate aforementioned considerations related to sea turtle life stage and habitat

use, as well as important aspects of collecting information that could be relevant in a NRDA (See Section 

4), should a spill incident advance to that stage.

Personal protection equipment (PPE) and training for different activities is determined or approved 

by the Safety Officer (and their support staff) or existing government agency guidance and standards 

(for government personnel) and must be followed. For handling oiled wildlife or entering oiled areas, 

this generally includes protective outerwear (e.g., Tyvek® suit), nitrile or rubber gloves, oil and water 

resistant footwear, and eye protection.

All participating responders and organizations must be informed of operational protocols, including 

any potential legal requirements involving the collection, use, transfer, or disposal of sea turtles, 

samples, and other data and materials collected in connection with an oil spill. Questions regarding legal 

requirements should be directed to the UC, and the NOAA General Counsel (Natural Resources Section)

and/or DOI’s Office of Solicitor (Environmental Restoration Branch) for matters relevant to NRDA 

See Sections

3.4.10, 

3.4.11, pgs. 

55, 57

See Section

3.4.12, pg. 59
38

(whether occurring during response or afterwards). In addition, any funding or reimbursement that may 

be available to organizations for services, supplies, equipment, and other expenses should be clarified 

prior to their engagement in spill response. Such funding or reimbursement must be consistent with 

applicable law.

3.4.1. General evidence collection and handling

Important data and samples are collected during oil spill response that ultimately may be used to 

assess exposure of sea turtles to oil and injuries resulting from that exposure. This information and 

material ultimately may be used for legal purposes including both criminal and civil proceedings. The 

potential for litigation associated with an oil spill requires specific measures when collecting, handling, 

and transferring samples and data. For the purposes of this document, evidence includes (but is not 

limited to) the following:

 live sea turtles

 carcasses

 samples of oil or suspected oil collected from the skin

 any biological samples collected from turtles (e.g., blood, tissue, fluids, feces)

 digital and hard-copy images, data, and documents (e.g., photographs, data forms, field notes, 

medical records, electronic storage devices)

As protocols may be updated and new technologies become available and applicable over time, the 

latest instructions should be confirmed with NOAA General Counsel (Natural Resources Section) or DOI’s 

Office of Solicitor (Environmental Restoration Branch), as appropriate.

A chain-of-custody (COC) is initiated whenever any of the above are acquired and accompanies the 

animal, sample, or material whenever it changes hands. A complete protocol for COC procedures is 

provided in Appendix 6. Whenever there is any question as to whether COC should be followed, the best 

option is to consult with a supervisor in the appropriate chain of command and follow COC procedures 

in the interim.

There typically are legal prohibitions against disposing of, deleting, or otherwise discarding any 

materials collected during an oil spill without judicial or other appropriate approval. Legal prohibitions 

on disposal of potentially relevant information/documents involving the oil spill frequently also apply to 

field notes and supporting documentation, analytical data, and internal communications regarding the 

spill, responses, and investigations. It is best to assume that any materials, including carcasses, should 

not be discarded unless specific permission has been obtained to do so from: (i) the UC (regarding 

response activities), and (ii) the NOAA General Counsel’s Office and the DOI Office of the Solicitor 

regarding any samples/materials/information potentially relevant to assessing injuries to natural 

resources and associated restoration planning. Logistics needed to store samples and sea turtle 

carcasses (e.g., freezers) may become an issue, depending upon the size of the spill and the number of 

turtles impacted, and should be a relatively immediate consideration if carcass retention is required. 

Moreover, any samples or data collected during spill response (or NRDA) are subject to requests to 

provide them to the Trustees. It is important to have all items clearly labelled, as described in the 

protocols accompanying these guidelines, and to be organized in a manner that allows them to be 

See Appendix 

6, pg. 125
39

readily located. Data are to be managed and archived in a system agreed upon by the UC (or by the 

Trustees with regard to NRDA) to preserve their integrity. See Section 4.5 for details.

Wildlife operations present some unique challenges to evidence handling requirements that often 

must be resolved early in response. For example, most animal care facilities ship samples to commercial 

laboratories for common diagnostic tests, such as blood analyses and microbial cultures. Some of these 

laboratories do not have in-house COC or sample retention procedures and will not accommodate these 

requirements. Moreover, blood samples may be frequently collected from individual patients, resulting 

in a considerable workload to ensure tracking and documentation of samples. Acquisition of important 

clinical information and optimal care are of foremost importance and always take priority over potential 

legal procedure. For example, if the preferred laboratory used by a care facility cannot meet COC or 

other requirements, but provides an essential service needed to ensure optimal care, sample submission 

will not be prohibited. If any aspect of a protocol cannot be followed for any reason, the best approach 

is to communicate the issue through the UC and document any deviation (e.g., within the medical 

record) so that an appropriate solution can be identified and the disposition of any sample or other 

material can be clearly followed.

Materials maintained under COC require close control to ensure that they are not tampered with in 

any way. For individual items, specially designed evidence tape is applied over the opening of containers 

and signed by the collector in a way that will be easily observable if the item is accessed (Appendix 6).

Any access to an item (e.g., for subsequent examination or analysis) must be documented in an evidence 

record. Evidentiary materials must be stored in a locked area accessible only to specifically designated 

individuals. Access to the area must be recorded by a written log that describes the purpose of the 

access and action taken (e.g., removal of sample [including its specific identifier] from a secure freezer 

for analysis). These requirements can be onerous for facilities that do not regularly work with COC and 

must be carefully considered when staffing locations during response. For a larger oil spill involving 

collection of large numbers of samples, personnel may be needed whose specific role is to facilitate 

proper evidence handling.

3.4.2. Basic sampling considerations

There are a number of considerations related to sampling of sea turtles during an oil spill. All species 

found in U.S. waters are protected under the ESA and require specific permits from NOAA-NMFS (inwater) or USFWS or the state agency with delegated authority (on land) to conduct any sampling. Legal 

obligations under OPA may dictate which laboratories perform some analyses. This constraint generally 

does not apply to analyses necessary for medical diagnosis and treatment, but may restrict providing 

samples for oil-related testing and analyses that fall more within the realm of investigational or applied 

research. As such, sampling sea turtles collected during response must be conducted according to 

protocols approved by UC (or under NRDA), as well as with necessary ESA authorizations. In addition, 

sampling of sea turtles should never compromise an animal’s health or the diagnostic value of a sample.

For example, the amount of blood or tissue collected from a live turtle should be the minimum amount 

necessary for the intended objective and well within the margin of safety as determined by the 

attending veterinarian and existing permit(s). Extra blood or tissue should not be collected from live 

turtles strictly to accommodate requests for duplicative sample sets without a clear and ESA-permitted 
40

purpose. In addition, samples should not be divided into duplicative sample sets if doing so will yield an 

insufficient volume for an intended analysis (e.g., chemical testing), or will jeopardize the diagnostic 

value of the sample (e.g., histology). To help guide collection, minimum volumes required should be 

indicated in all sampling protocols, such as provided in the appendices at the end of these guidelines.

3.4.3. Handling digital media

Information collected during response to an oil spill is often recorded on replaceable and 

interchangeable memory cards or hard drives that store digital media. These cards or drives are used in 

digital cameras, GPS units, and other devices. Much of the information related to the history of creation, 

access, and modification of data, whether an image or other type of file, is automatically captured 

within electronic metadata. Personnel working on the response need to take considerable care to 

appropriately preserve data collected onto these digital devices in order to maintain its integrity and 

make the data operationally and legally useful for a variety of purposes. The general considerations 

provided below are intended to preserve a secure, immutable, “original” copy, which is necessary to 

prove the origin of the data or photo for potential litigation.

In addition to the general considerations below, government agency employees should consult 

their agency guidelines and/or legal counsel for any alternative or additional requirements. Also, 

response operations may have a Data Management Lead or group that oversees collection and storage 

of various types of data during a spill. Further instructions related to capture and preservation of specific 

data types may be provided through the UC. 

Please note that technology evolves rapidly. In the event of a spill, if necessary, updated instructions 

must be provided to responders, researchers, and others as quickly as possible to avoid loss or 

compromise of evidentiary materials.

General considerations for handling digital media for purposes of preservation:

1. Do not collect images or data on personal devices (e.g., personal camera, cell phone, tablet). If 

personal devices are used to capture data, there is a potential that those personal devices may 

need to be turned over for evidentiary purposes in the event of litigation.

2. Ensure that the date and time are set accurately on devices. The metadata on when a file was 

created reflects these settings. An accurate date and time will allow the file to be more easily 

corroborated with other information.

3. Do not manipulate, delete, or modify files in any way prior to making evidentiary copies. For 

digital images or other files that are created with sequential file names, all sequential files 

should be present and accounted for. For digital cameras, it is often easiest to keep track of 

images if the camera is set to reset the image numbers every time a blank memory card is 

inserted. This will mean that the file name of the first image taken always ends in “1.”

See Appendix 

6, pg. 125
41

4. Provide geolocation for field photographs. The GPS coordinates of the location should be 

documented within a photographic series using a photo placard or photograph of the actual GPS 

unit unless the camera is GPS-enabled.

5. Avoid using smartphone cameras. Smartphone cameras should not be used because photos 

taken on these devices tend to be easier to manipulate, delete, and accidentally tamper with.

Therefore, it is recommended that field personnel be equipped with dedicated field equipment 

such as a GPS-enabled digital camera or a GPS and camera used together.

The digital data should be kept as an “original” unopened, immutable file copy in its evidentiary 

form that is maintained securely. There are multiple ways in which “original” files may be captured, 

stored, and preserved for evidentiary purposes during an oil spill. The original, unaltered memory card

or drive can be stored in a secure location. Alternatively files can be directly transferred to another 

physical media, such as a designated secure hard drive or other device or non-rewritable CD or DVD, or 

transfer to a secure cloud-based system - the critical point being to securely maintain data identical to 

that which was captured on the original device. A secure cloud-based system eliminates the dependency 

on external media, its storage, and inevitable inability to be accessed as it ages and technology changes.

Each individual should consult his or her agency’s guidelines - or the guidelines of the receiving agency -

when selecting a means to transfer and store data.

To copy digital media onto a non-rewritable CD or DVD. Digital files are transferred directly to a data 

CD or DVD using a computer equipped with a disk recording device. At least two disk copies are made 

and each is viewed to ensure that the data were transferred. Disks are labelled with indelible ink or a 

proper adhesive label to clearly identify the source of the data and are stored in a secure location. 

If a means of creating unaltered copies is unavailable or a device does not have a memory card, 

keep the memory card or device in a secure location and contact a supervisor or team/group leader for 

further instructions. After digital files are preserved in the designated evidentiary form, the user should 

follow agency policy or guidance related to creation of "working" copies and reuse of memory cards or 

devices. Such instructions are subject to vary among spills and government agencies.

3.4.4. Documentation of sea turtles

During response to an oil spill, sea turtles may be encountered by three general groups of response 

personnel (depending on the size and location of the spill): 1) stranding personnel that respond to and 

document turtles that are found on or near the coastline; 2) personnel participating in directed at-sea 

wildlife operations (surveys, directed capture, and rescue of oiled animals); and 3) field personnel 

(including protected species observers) that opportunistically encounter turtles during the course 

of other operations (e.g., skimming/booming vessels, in situ burns, SCAT teams, shoreline assessments, 

beach clean-up). Personnel must be informed about what to do in the event a sea turtle is encountered, 

especially any that are oiled, dead, injured, or otherwise debilitated. In particular, sea turtle response 

personnel should coordinate with other wildlife operations personnel to ensure efficient response 

efforts and information sharing across taxa. In addition, documentation of sightings and observations of 

sea turtles, including location, whether oiled or non-oiled, and state of the turtle is important. Workers 

See Appendix 

5, pg. 119
42

should have access to an efficient information reporting system and basic data collection forms. 

Moreover, this information must pass efficiently to the appropriate channels of wildlife operations in 

order to ensure the information is recorded and any necessary response is undertaken. Data forms and 

protocols designed for personnel performing various functions during spill response are provided in the 

appendices.

3.4.5. Collecting external samples of oil or suspicious material

An external sample should be collected from any sea turtle that is visibly oiled, that smells of oil, or 

has any substance on it that is suspected to be oil or other material of interest for a spill. In general, 

samples are not collected from non-visibly contaminated sea turtles during a spill involving heavier, 

readily visible chemicals, such as crude oil. For a spill involving transparent petroleum products, such as 

lighter or refined fuels, all observed sea turtles may be sampled. Two general types of material can be 

used: wooden tongue depressors or gauze (TeflonTM or cotton). Tongue depressors generally are only 

used if there is a large quantity of oil present. Gauze is used for any amount, including collection of 

limited quantities of material. Ideally, sample kits with materials that have been specifically prepared 

are used to minimize interference with analyses (i.e., certified glass, TeflonTM sampling pads), especially 

when sampling trace material. These high-grade kits typically are prepared in a laboratory prior to use.

However, adequate samples can also be collected using off-the-shelf components (aluminum foil, cotton 

gauze, sealable plastic bags) if the sample includes globs or heavy pastes of suspect material. Important 

considerations for sampling include wearing proper PPE, decontaminating any non-disposable

instruments or other materials between uses, and following COC procedures (see Appendix 12).

3.4.6. Stranding response

Response to an oil spill in areas inhabited by sea turtles typically entails some degree of 

enhancement of regular stranding response operations, including more rapid response to and reporting

of stranded animals, use of more detailed documentation protocols, implementation of evidence 

handling procedures, and recovery and retention of carcasses that might typically be left in the field. In 

addition, some locations may require dedicated surveillance effort for detection of stranded turtles in 

addition to that considered part of usual (i.e., non-spill) network operations.

The implementation of enhanced stranding response protocols required during a spill response is 

communicated to responders and directed by the Wildlife Branch within the Operations Section of the 

UC, working at the direction of the Federal or State On-Scene Coordinator. This communication may 

occur through Wildlife Branch personnel working remotely or on-site in the Command Post. Specific 

activation and demobilization procedures are required by the UC in order for stranding responders to 

participate in an oil spill response. Multiple governmental and non-governmental organizations and 

individuals may comprise the network of stranding responders for a given area. 

See Appendix 

7, pg. 137

See Appendix 

8, pg. 139
43

Logistical and procedural considerations related to stranding response during an oil spill

Stranding response procedures and capacity

During an oil spill, the regional stranding network typically is engaged in response activities because 

network members are located nearby the spill and are familiar with their response area. Stranding 

response is enhanced during a spill in order to increase the likelihood of sea turtle survival and also to 

obtain information about the potential effects of the spill, which is relevant to both the spill response 

and NRDA. This enhancement may include additional documentation (including use of COC procedures), 

training and appropriate use of PPE, collection of oil from oiled turtles, increased collection of carcasses, 

and more rapid reporting. This increased effort may require additional dedicated personnel, especially if 

human safety concerns and training requirements (e.g., HAZWOPER) limit or prevent involvement of 

some participants. All response protocols related to stranding response must be communicated to 

responders; typically this is done through the state, regional, or national sea turtle stranding 

coordinator. 

For any stranded sea turtle, determination of whether impairment or death was related to an oil 

spill (or response activities) often is deferred2 until response has been concluded and all available data 

are evaluated. Considerable time and effort are required to investigate all possible links between 

strandings and potential spill-related effects. Therefore, if effects on sea turtles are a concern, the extra 

response and documentation requirements implemented during an oil spill typically are applied to all

strandings during a response, regardless of whether or not turtles are visibly oiled. Historical stranding 

data should be reviewed at the onset of a response in order to gauge the minimum number of animals 

that may be documented, as well as where and when strandings typically occur, so that the necessary 

human and physical resources can be allocated effectively.

Although field disposal of sea turtle carcasses is commonplace under regular operations in some 

areas, during an oil spill, all sea turtle carcasses are collected from the response zone, if feasible, 

regardless of whether they are visibly oiled. Collection of dead turtles facilitates any necessary 

subsequent examination, prevents duplicative reporting of animals, and removes any contaminating 

substance on or within the carcass from the environment. Unified Command must approve any disposal 

of carcasses in the field or decision not to salvage carcasses. 

In addition, it is common practice during an oil spill that all collected sea turtle carcasses from within 

the spill zone are examined (necropsied) to the extent afforded by postmortem condition. Carcasses 

within a spill zone, especially decomposed animals, may be frozen for later examination due to logistical 

constraints and to maximize preservation. Therefore, adequate freezer space must be available. The 

necessary capacity can be gauged by examining historical stranding numbers and budgeting space

accordingly. Minimally, contingencies should be in place for temporary freezer capacity for a worst-case

scenario. Legal counsel within the UC should be consulted regarding requirements (related to spill 

 

2An exception is injuries or deaths of wildlife caused by response-related activities. Immediate consideration by the 

UC may lead to alteration of current practices under the Incident Action Plan to minimize harm from the 

response activity.
44

response) for preservation of remains following examination. In addition, the NOAA General Counsel’s 

Office (Natural Resources Section) and the DOI Office of the Solicitor (Environmental Restoration 

Branch) should be consulted for preservation requirements associated with NRDA, which may apply to 

samples and other data or materials created or collected during response. See Subsection 3.4.1 for 

additional information on legal requirements to preserve samples, information, and documents.

Sparsely or irregularly surveyed locations

Remote areas (e.g., uninhabited islands or coastline) may not be surveyed regularly by networks and 

may require dedicated patrols by response personnel or other means. It is important to note that aerial 

surveys by manned aircraft that are commonly used to look for stranded marine mammals only detect 

larger sea turtles (>45 cm carapace length). Such surveys are inadequate for detection of stranded sea 

turtles in many areas because a significant number of turtles are too small to be reliably seen by air and 

are easily obscured by shoreline debris. If surveys by foot or all-terrain vehicle (or similar) are impractical

for detection of smaller stranded turtles, other aircraft and UAVs that can fly lower and with less speed, 

if permissions allow, are another consideration.

Alignment of reporting mechanisms

Stranding networks have 24-hour response hotlines for the public to report stranded turtles. These 

phone numbers generally are widely advertised and well-known in coastal areas where sea turtles 

occur. Many animals are reported by the public, especially in areas were the coast is inhabited or 

regularly visited by people. It is common for spill response operations to set up a dedicated call center 

for reporting oiled wildlife. Multiple phone numbers and call centers can result in loss of information 

and delay response to stranded animals. If new hotlines are created, information must pass efficiently to 

members of the stranding network or other appropriate designated responders. Likewise, information 

collected from existing hotlines must be communicated expediently to the UC.

Data collection and summaries/analyses needed for response

The regular operations of the stranding network provide important information for assessing spillrelated injuries to sea turtles, including documentation of the timing and locations of strandings, life 

history information, presence or absence of visible oil, and any obvious external abnormalities.

Additional information is collected from live or dead turtles that are transported for clinical evaluation 

or necropsy. The Wildlife Branch typically requires daily reporting of turtle numbers, including the 

number of visibly oiled turtles and status (live or dead). These data also are accessible for NRDA

purposes. During the preliminary reporting phases, sea turtles are classified as visibly oiled or non-visibly 

oiled. The designation of non-visibly oiled does not imply lack of exposure, especially for a spill of lower 

viscosity oil products.

Funding considerations for stranding response organizations

During an oil spill, funding may become available to cover certain costs of a stranding response 

once an entity (organization or individual) is activated by the Wildlife Branch. The RP may contract with 

members of the stranding network for assistance in responding to a spill, or funding may become 
45

available through the UC via the NPFC administered by USCG. If funding is provided, the Logistics Section 

or entity making payments (i.e., the RP), will likely require specific procedures for cost documentation.

If a NRDA is pursued for a spill and a stranding network participant’s activities would support the 

NRDA, and the participant is not receiving compensation from a RP or UC (no contract was entered or it 

has ended, e.g., after the official spill response concludes), certain costs associated with stranding 

response activities may be eligible to be reimbursed by the natural resource Trustees pursuant to OPA.

The commitment to reimburse stranding network participants for activities in support of the NRDA is 

determined solely by the natural resource Trustees (e.g., NOAA and DOI). The Trustees will notify 

stranding network participants of potential assessment needs. Stranding network participant(s) should 

reach agreement with the relevant natural resource Trustee regarding details concerning 

reimbursement (including activities eligible for reimbursement and the amount of reimbursement) prior 

to performing reimbursable activities.

3.4.7. Live turtle intervention

De-oiling and rehabilitation facilities

Area rehabilitation facilities are alerted by their state or regional coordinator if a spill is identified 

within their geographic response area. A link to a current list of rehabilitation facilities by state or 

territory is provided in resources listed in Appendix 1. Most rehabilitation facilities are operated by 

private entities and non-governmental organizations, thus the Wildlife Branch within the ICS must work 

closely with each facility’s representatives and internal administration to ensure that activities are linked 

into and supported by the UC. In addition, specific federal or state agency staff coordinate rehabilitation 

facilities either regionally or by state. The Sea Turtle Group within the Wildlife Branch will either include 

these individuals or will work closely with them to identify the facilities that are most likely to receive 

animals. 

Organization of rehabilitation facilities

For the purposes of oil spill response, rehabilitation centers are designated by Wildlife Branch as 

either primary or secondary facilities. Primary facilities are defined as those that actually wash oil from 

sea turtles and thus are equipped with appropriate hazardous waste disposal facilities on site, site safety 

plans, and other requisite safety measures in place. In addition, staff are required to have the level of 

HAZWOPER or other training dictated for a spill. Primary facilities also must be staffed to meet the 

demands of response operations. For example, on-water recovery operations may not return with 

animals until the late afternoon or evening. For these reasons, primary facilities should be identified and 

prepared as early in response as possible. This consideration is especially important for a spill involving 

inshore areas or if any operations are deployed that may collect oiled turtles, such as directed captures, 

as these circumstances are most likely to imminently yield animals requiring care. Secondary facilities 

are those that receive de-oiled turtles for subsequent rehabilitation - they play a vital role in maintaining 

capacity at primary facilities for incoming oiled turtles. Secondary facilities also may be used to 

temporarily hold animals prior to release and for rehabilitation of turtles without visible oil exposure 

that strand within the response zone. Facility location relative to the spill area and willingness and ability

to serve as a primary facility are factors that influence designation of specific facility roles. It can be 

See Appendix 

11, pg. 157
46

challenging to predict sea turtle impacts from a spill and to appropriately scale preparations of care and 

treatment of oiled turtles. At least one primary facility should be identified within a spill area to care for 

oiled sea turtles.

Primary facilities are organized by a facility plan according to contaminant zone designations to 

minimize exposure of people, animals, and equipment to hazardous materials. Oiled sea turtles are 

admitted into the exclusion zone “hot or red zone” for evaluation and decontamination. Washed animals 

that may still have some oil on them or are defecating oil are maintained in the reduction zone “warm or 

yellow zone.” Once turtles are believed to be decontaminated, they transition to the support zone “cold 

or green zone” for the remainder of their care. Standard PPE requirements are defined for each zone. 

Secondary facilities only receive non-visibly oiled and fully decontaminated (i.e., “green zone”) sea 

turtles; therefore, they do not require these hazardous material measures and procedures.

Equipment necessary for de-oiling and hazardous waste containment usually is provided by 

response operations. Oiled turtles will continue to pass ingested oil in the feces, so they are most easily 

maintained initially by conducting water changes (dump and fill) to avoid contaminating filtration 

systems. It may take a week or more for animals to stop defecating visibly detectable oil observed as a 

sheen on the tank surface or film on the sides of the tank walls. Therefore, a large capacity waste water 

collection system, with regular removal and replacement, is needed even for small numbers of turtles. In 

the initial phases of response, water can be collected into large plastic drums, which are readily 

available, until facilities transition to a more efficient collection system.

Remote locations and portable facilities

Temporary or portable facilities may be required for areas that are remote or otherwise do not have 

brick-and-mortar rehabilitation facilities. In these situations, animals are stabilized and decontaminated 

to the degree possible and transported to the closest facility for further evaluation and care. Minimally, 

facilities should be equipped with the following (in addition to staffing): 1) means of capturing or 

disposing of contaminated wastewater or materials; 2) appropriately-sized, temperature-controlled (as 

needed) tanks for housing turtles; 3) materials and instruments for decontaminating sea turtles; 4) 

medical supplies for stabilizing animals and treating immediately life-threatening conditions; 5) field 

diagnostic equipment (capability of measuring packed cell volume, total solids, blood gas, and basic 

blood chemistry parameters); and 6) an uncontaminated salt water source (natural, artificial, or 

imported). The field unit should include an experienced sea turtle veterinarian to oversee stabilization 

and any necessary triage. It is recommended that additional specific preparations be included in ACPs

where portable facilities may be needed.

Care and treatment of live oiled turtles

Field 

In many instances, oiled turtles encountered in the field are brought into captivity to be cleaned and 

for medical care. There are some exceptions that depend on the specific circumstances of each spill. For 

example, nesting females and other large turtles are not typically captured unless they are obviously 

impaired. Also, turtles that are very lightly oiled (see Box 3-2), but otherwise apparently normal, may be 
47

cared for in the field unless there is a clear benefit to bringing them to a facility. The decision whether or 

not to capture turtles typically is based on the magnitude of the threat posed by a spill (which likely 

varies among life stages), environmental conditions (i.e., the stage of the response, how much oil 

remains in the water, etc.), and the condition and behavior of the animal.

Many oiled turtles are initially documented by stranding responders and personnel with turtle 

expertise that are deployed for wildlife rescue operations. These individuals also take external 

evidentiary samples of the substance and may transport the animal(s) to a care facility. If the animal will 

receive care within a few hours or less, the turtle is sheltered from environmental conditions and 

transported in a manner that abides by the parameters provided in Appendix 10. If transport is delayed 

(e.g., day-long operations, multi-day deployments), it is preferable to remove as much of the substance 

from the animal as possible in the field in order to minimize continued exposure. A large amount of oil

can be removed using oil-absorbent pads; therefore, operations should be equipped with the necessary 

PPE and cleaning materials. Additional medical evaluations may be warranted in the field and can be 

especially relevant to injury assessment. For example, during the DWH spill, physiological derangements 

were evident in clinical chemistry analyses of oiled turtles, but physiological changes resulting from 

handling and transportation to animal care facilities complicated interpretation (Stacy et al. 2017).

Measurement of health parameters upon capture (i.e., using point-of-care analyzers) could provide an

immediate measure of any physiological effects of oiling without the confounding effects of subsequent 

handling and transport.

Personnel involved in various types of operations, but without training in the care and handling of 

sea turtles, also may encounter sea turtles and have the opportunity to capture oiled, debilitated 

animals for treatment. In these situations, the primary objectives are safe capture (if possible) and 

handling of the animal, immediate notification of the Wildlife Branch to coordinate transfer to an 

appropriate wildlife responder, and documentation of the event. Non-wildlife response personnel that 

may encounter sea turtles should be provided with clear and relatively simple protocols, as well as 

appropriate collection equipment.

Medical facility

Admission procedures and records

Within an area defined as the response zone, procedures for documentation must be followed for 

all recovered sea turtles, including those that are not visibly oiled. Upon admission, a COC Form is 

initiated or passed to a representative of the care facility. For turtles recovered by stranding responders 

or field personnel, the appropriate field data form should also accompany the animal. The care facility 

reviews all forms and completes any missing data fields (e.g., body weight, measurements). The COC is 

reviewed to ascertain whether: 1) an evidentiary sample of any external material has been collected and 

2) dorsal and ventral photographs have been taken. If not, then a sample should be collected as per the 

protocol in Appendix 8. Unless otherwise directed by UC, all evidentiary samples collected or received 

with turtle are kept by designated facility staff under the pertinent COC. A Live Oiled Sea Turtle Intake 

Form is completed by the care facility for each animal and retained with the medical record. This form 

See Appendix 

10, pg. 156

See Appendix 

5, pg. 119

See Appendix 

11, pg. 157
48

contains important questions specific to oiling and general condition of sea turtles. Appendix 11 includes 

a simplified outline of these admission and documentation procedures.

In addition to the Intake Form, the rehabilitation facility’s standard forms for stranded sea turtles 

and medical records system can be used to record physical examination findings, laboratory values, 

treatments, and feedings, provided that all information is clearly documented and assigned to each 

specific turtle. The importance of complete medical records cannot be over-emphasized as they are 

viewed as potential evidence for legal purposes. Whenever medications are administered, the name of 

the drug, dose, and route (oral, subcutaneous, intramuscular, intravenous) should be recorded, as well 

as the initials of the person who administered the medication. Any notation of care or treatment 

administered needs to be initialed by the provider or otherwise be traceable digitally.

Identification of individual sea turtles is important and can be challenging if large numbers of 

animals are admitted. Any identifier assigned by a facility should be clearly cross-referenced with the 

identifier assigned on the COC (e.g., stranding network number, field ID). Individuals can be temporarily 

identified using a waterproof marker on the carapace or Tyvek® flipper band (Figure 3-5). Admitted 

turtles may receive metal flipper and Passive Integrated Transponder (PIT) tags pursuant to usual facility

operating protocols under non-spill conditions. Clinical stability and need for individual identification are 

considered when determining timing of tag placement relative to other procedures. Aseptic technique 

shall be practiced for all tagging procedures and tagging shall only be performed by trained, permitted 

individuals. If insertion of a PIT tag is delayed, the temporary markings or bands must be maintained and 

replaced as necessary to ensure that individuals can be specifically identified until they receive more 

permanent tags. 

Physical examination - A brief physical examination is performed upon admission. A veterinarian or 

animal care specialist familiar with sea turtles should conduct the evaluation and identify conditions that 

are considered to be life threatening. The capture, transport, and intake process can be stressful and an 

oiled animal’s condition may be unstable. The intake area should be as dark and quiet as is practicable,

and animals must be monitored during the examination and intake process. If an animal’s condition 

deteriorates and a veterinarian is not participating in the examination, the animal care specialist should 

seek appropriate veterinary advice immediately. An intake protocol adapted from the system used by

the Audubon Nature Institute is provided in Appendix 11. This protocol is based on experience with over 

100 oil-exposed sea turtles treated during the DWH spill.

Figure 3-5. Use of temporary 

identifiers to keep track of 

individual turtles. Arm bands and 

tags must be monitored to 

ensure they are not causing 

abrasions. Waterproof paint 

markers are a good option, but 

to maintain legibility must be 

replenished as they wear. 
49

A thorough examination of the entire body is conducted, making note of the degree and nature of 

oil contamination. Oil may have been removed in the field (this should be noted on the field form 

accompanying the turtle). Behavior, activity level, and alertness are assessed. Veterinary assistance is 

provided for any turtles that are lethargic, having difficulty breathing, or if there is froth or fluid 

discharge from the nostrils (indications of aspiration). Respiratory rate and body temperature are 

recorded. Hyperthermia or hypothermia is a significant concern in oiled turtles, depending on 

environmental conditions, thus body temperature may be measured using either a cloacal thermometer 

or digital, infrared laser thermometer aimed at prefemoral or prescapular areas. Temperatures above 

88-90°F (30-32.2°C) or under 50-55°F (10-15°C) indicate the need for immediate treatment. This may 

include gradual warming or cooling of the animal, fluid therapy, and other medical intervention by a 

qualified veterinarian. Evaluate overall body condition (eyes, soft tissues of the neck, condition of the 

plastron) and assess the presence of epibiota. Unlike mammals, hydration status is not easily assessed in 

sea turtles, and most likely will require a combination of physical examination and evaluation of blood 

values.

The eyes and mouth are carefully examined; noting any oil. Most sea turtles will open their mouths 

if the gular area and sides of the upper beak are retracted. Be careful to avoid being bitten and do not 

attempt this if unfamiliar with sea turtles. Using a flashlight or other light source, look for any oil within 

the oral cavity, pharynx, and upper esophagus. Mouth gags, medical speculums, tooth brush handles, 

Nylabones®, or padded PVC pipe can be used to facilitate oral examination and removal of oil or tar. 

Examine any feces for presence of oil (sheen produced following exposure to water).

Diagnostic evaluation - The priority of live sea turtle intervention is to ensure recovery and eventual 

release, thus medical care should be provided as with any other sea turtle patient. No aspect of oil spill 

response procedure (or any requested sampling) should jeopardize the health or welfare of sea turtles 

under care. Any procedure or test necessary for diagnosis and optimization of care is available to the 

attending veterinarian (including imaging, blood analyses, etc.). The minimum clinical data collected 

from all oiled sea turtles should include standard hematology and blood chemistry. Blood gas analyses 

(i.e., measured using a point-of care analyzer) and dorsoventral and craniocaudal radiographs (with 

additional projections as indicated) also may be of value for initial stabilization and detection of any 

abnormalities. 

Hematology and blood chemistry should be analyzed upon admission (if sufficiently stable) and as 

frequently as indicated by clinical assessment. The preferred anticoagulant for reptile plasma chemistry 

is lithium heparin (green-top tube). Blood films can be made from either freshly collected blood (without 

anticoagulant) or from whole blood in lithium heparin. A minimum of four blood films are made per 

animal; two are left unstained. Standard blood parameters measured in sea turtles for clinical evaluation 

include the following: complete blood cell count (CBC), packed cell volume, hemoglobin concentration, 

an estimation of white cell blood count, red cell blood count, and morphological evaluation of cells 

(using a blood smear). Analytes included in a standard plasma chemistry profile include: glucose, urea 

nitrogen, total protein, aspartate aminotransferase (AST), albumin, calcium, phosphorus, sodium, 

potassium, chloride, globulin, creatine phosphokinase (CPK), and uric acid.
50

Special biomedical sampling for spills - At times, protocols may be provided for additional blood samples 

for other tests (e.g., immune function assays, serum protein electrophoresis, polycyclic aromatic 

hydrocarbon (PAH) analysis). Other biomedical samples (e.g., urine sample, fecal sample, microbiological 

culture, skin biopsy) may also be collected at the discretion of the attending veterinarian or 

opportunistically, provided that samples are documented and handled as described in Appendix 6. 

Decontamination - It is anticipated that most stable turtles will be washed soon after an immediate 

examination is performed; however, the attending veterinarian or animal care specialist will evaluate 

the condition of each animal and may provide any necessary initial therapy, such as supportive fluids 

and ophthalmic medications prior to washing.

Washing procedures are similar to those described for other taxa. A key exception is that cooler 

water temperatures (not to exceed 80-85 ̊F) should be used and water temperatures should be within 

5 ̊F of the turtle’s body temperature to avoid sudden changes. Depending on the situation and animal 

numbers, risk of hyperthermia should be considered and body temperature monitored as necessary. 

Liquid dishwashing detergent (Dawn® is a commonly used product) is effective for removing oil from the 

body. Vegetable oil can be used to remove oil from the eyes and mouth. Mayonnaise also can be used to 

clean the mouth. Soft scrub brushes, toothbrushes, cotton swabs, and gauze are all helpful tools for 

removing oil. Oil is removed from the mouth and upper esophagus using gauze and forceps. Thorough 

cleaning of the mouth may be difficult or impossible for energetic, refractory sea turtles. Consult the 

attending veterinarian before stressing animals with repeated cleaning efforts.

Medical treatment - Following physical oil removal, medical treatment of oiled turtles is at the discretion 

of the attending veterinarian and may include fluid support, oral administration of emulsifying agents 

(e.g., mayonnaise and fish oil) to remove oil from the digestive tract (see Appendix 11), and antibiotic 

therapy. Activated charcoal is not recommended because it poorly absorbs most hydrocarbons and 

administration creates additional stress and risk of aspiration. 

Monitoring and rehabilitation - Animals should be regularly monitored during the rehabilitation process. 

All clinical, feeding (food consumption and/or preferences), and behavioral observations should be 

described in the medical records. Body weight should also be monitored repeatedly during rehabilitation 

and recorded, at a minimum, upon admission, at some point during rehabilitation, and prior to release. 

It is recommended that plasma electrolytes and hydration be closely followed during the initial week of 

rehabilitation. Furthermore, electrolytes should be closely monitored (every two days at minimum) if 

animals are temporarily placed into lower salinity (e.g., 16 ppm) or freshwater conditions for any reason.

Oil may damage the skin of sea turtles and may cause injury to other areas of direct contact, such as 

the eyes. Organ injury, including damage to the lungs and liver, has been inconsistently observed, but 

also is a concern and may depend on the characteristics of the spilled material and route of exposure. 

Repeated radiographs and blood work, at least within the initial two weeks of care, is recommended to 

detect any delayed effects. Other health problems of concern that may require treatment include 

opportunistic infections and other commonly encountered secondary problems in sea turtles, especially 

pneumonia.
51

Release - The decision regarding when and where to release a rehabilitated, previously oiled sea turtle

or group of turtles is based on a number of factors, including species, life stage, time of year, and 

circumstances of the spill. In most instances, it is desirable to return an animal as close to its 

location of origin as possible; however, other biologically appropriate alternatives may be selected if a 

location remains under threat from a spill or if the turtle(s) is of a transitional life stage that has been 

interrupted by captivity. Once a sea turtle is medically cleared, it is released as soon as logistics allow.

Release locations and release timing for a rehabilitated sea turtle(s) are coordinated with NOAA-NMFS

and the USFWS, and/or other appropriate government entity. A Release Plan should be drafted, 

reviewed, and signed by agencies and the UC if needed.

3.4.8. Postmortem examination (necropsy)

Postmortem examinations (necropsies) are performed on sea turtles that are found dead, or that 

are recovered alive from within the spill response area and subsequently die. These examinations 

facilitate understanding of the effects of the spill on sea turtles, which benefits the clinical care of live

affected turtles and yields important information for NRDA. Moreover, much of the information and 

samples obtained by necropsy cannot be collected from live animals. Necropsy procedures and findings 

from an oil spill are subject to considerable legal scrutiny, thus examination of oiled sea turtles (or those 

suspected to be oiled) is to be performed by a veterinary pathologist identified by NOAA-NMFS.

Depending on the circumstances of the spill, similar considerations may also apply to necropsy of any 

non-visibly oiled sea turtles found within the response zone. A gross necropsy data form and sample 

checklist are provided in Appendix 12. Postmortem condition influences the extent of examination and 

sampling. In general, if specific organs or tissues are recognizable, then they should be sampled 

according to the protocol. For all examined animals, a final report is generated that includes gross 

findings, histological findings (if postmortem condition permits), results of any diagnostic testing, final 

diagnoses, cause of death determination, and any comments related to interpretation of findings and 

conclusions.

Each examination is carefully photodocumented using the protocol provided in Appendix 12. A

photo placard is made for each case (e.g., using 

a dry erase board or similar) that includes the 

turtle’s alphanumeric identification, species, 

date, name of the examiner, and time that the 

examination begins. This placard is 

photographed at the beginning and end of each

examination in order to clearly demarcate the 

photographic series for each case. All parts of 

the body are photographed, including complete 

images of the dorsum, ventrum, an oblique 

photo showing the neck and shoulder region, 

and a ventral photo with the plastron removed 

to demonstrate nutritional condition. Any oil or 

suspicious substance found externally or 

See Appendix 

13, pg. 177

See Appendix 

12, pg. 169

Figure 3-6. Ingested oil covering the esophagus with its conical 

papillae (Kemp’s ridley turtle).
52

internally is photographed prior to sampling. Oil tends to adhere to any keratinized epithelium, thus it 

frequently will coat the mouth or esophagus if ingested (Figure 3-6). Photographs are taken of any

injuries or other abnormalities, beginning with a wide angle perspective to show anatomical orientation 

and progressing to close-up images.

Postmortem samples collected for petrochemical analyses require care to prevent crosscontamination or interference with chemical analyses. It is best to have a clean pair of forceps and a 

clean scalpel handle (or syringe, as appropriate) for each tissue or fluid that is collected for 

petrochemical analysis. Instruments should be cleaned with detergent followed by an alcohol rinse 

between animals (and between samples if reused for the same case) as described in Appendix 12.

Contact between nitrile gloves and samples, instruments, or the insides of lids and containers must be 

avoided because it may interfere with chemical analysis. Fluids (e.g., bile, blood, urine) are collected 

using glass syringes (also cleaned as described between cases) and disposable needles.

Two general types of sampling containers are used, certified glass jars (preferred) meeting the U.S. 

Environmental Protection Agency’s Specifications and Guidance for Contaminant-Free Containers (EPA 

Publication 9240.0-05A; EPA540/R-93/051) or aluminum foil pouches (solid samples only) placed into 

plastic bags. Conventional aluminum foil available from home supply stores can be used. The dull side of 

the foil should be in contact with the sample and the foil is folded to completely cover the tissue and 

prevent any contact with the plastic sample bag. Samples are stored at the lowest temperature 

available. Ultralow (<-40 ̊C) storage is preferred, but samples can also be preserved in conventional 

freezers (-20 ̊C). The samples listed in Appendix 12, the container types, and the method of preservation 

allow a variety of analyses to be conducted related to exposure to oil, dispersants, and other potential 

mortality sources of interest (e.g., biotoxin analyses). Any additional sampling that is required for 

diagnostic purposes is permitted as long as samples are documented and preserved as previously 

described (and coordinated with UC). Additional types of samples or means of preservation may be 

requested as part of the injury assessment based on specific conditions of a spill.

3.4.9. Nesting beach activities

Much of the following information is most pertinent to areas were sea turtles primarily nest at 

night and eggs are left in place to develop and hatch, which is the case in most areas of the U.S. and its 

territories. A notable exception is Kemp’s ridley nesting in Texas, which occurs in the daytime and 

requires additional considerations with regard to oiling of beaches and shoreline clean-up operations.

Nesting monitoring and data collection

Monitoring programs exist in many areas where sea turtles nest within the U.S. and its territories 

(See Appendix 2). These areas include most beaches where regular nesting occurs; however, daily 

surveys are generally not conducted in remote locations or beaches where sea turtles rarely nest.

3 These 

areas are generally on the periphery of the nesting range of the species. For locations where established 

 

3

Including parts of the northern Gulf of Mexico, Hawaii, Guam, Mariana Islands, U.S. Virgin Islands, Virginia.

See Appendix 

14, pg. 179
53

programs do not exist, the Sea Turtle Group may be required to devise nesting monitoring capability if 

such monitoring is required in the event of an oil spill. 

There is no universal standardized data form in regular use, but most programs collect similar 

information, including where and when turtle nesting activities occur (e.g., daily number of nests and 

number of non-nesting emergences [by zone or by specific location]) and fate of nests, including an 

estimate of the number of hatchlings that successfully emerge from the nest and reach the sea. A draft 

nest monitoring form for use during oil spill response and for NRDA purposes in provided in Appendix 

13. After hatchlings emerge from the nests, the overall success of the nest, or more commonly, a 

subsample of nests, is determined by examining the nest contents and estimating hatching and

emergence success. This evaluation may also include determination of the timing of embryonic death

and documentation of any deformities or dead embryos by qualified individuals. These types of 

information, as well as any observations of nesting turtles, their eggs, or hatchlings being negatively 

affected by oil exposure or response activities, should be documented. (See Section 3.4.1 for general 

considerations).

Protection of eggs and hatchlings in situ

If a spill occurs during the nesting season and near a nesting beach, responders should, if possible,

identify locations of nests already laid and begin a dedicated daily marking program to mark all 

subsequent nests. These practices are employed to prevent beach clean-up activities from harming 

nests (e.g., sand compaction by vehicles or increased human presence, sand sifting, removal of beach 

sand/oil) and to detect any nests that are later oiled. Sub-meter GPS readings should be taken at the 

approximate clutch location. Nest locations should be marked prominently and fenced or roped off to 

alert personnel and to avoid physical damage. Additional marking procedures such as triangulation 

should be implemented so nest markers can be re-established if necessary. If there are stretches of 

beach where unmarked incubating nests are present, the use of heavy equipment for clean-up 

operations should be avoided and manual clean-up operations should be employed to the maximum 

extent possible.

Protection efforts also should minimize risks to nesting females and hatchlings posed by beach 

obstructions and artificial lighting. Very large ruts or holes (~ 8 cm or deeper) should be filled prior to 

sunset to avoid entrapment of sea turtles. In addition, daily rut removal (following completion of 

response activities and immediately prior to sunset) should be implemented on the beach seaward of 

nests that are due to hatch to ensure that hatchlings do not become trapped. The use of artificial lights 

on sea turtle nesting beaches during sea turtle nesting and hatching season should be minimized to the 

maximum extent practicable, and clean-up activities should be limited to daytime hours whenever 

possible. If lights are necessary, they should be used in accordance with well-established guidance for 

lighting practices that avoid disorienting hatchlings and deterring nesting females (Witherington et al. 

2014). Lights should be full cut-off and shielded to direct light onto the work area and minimize visibility 

along the beach.

When the duration of the egg incubation period for nests has reached its expected end – i.e., 

typically 40-60 days, depending on species and incubation temperatures (Ackerman 1997) – experienced 
54

ESA-permitted personnel may be required to monitor the nest throughout the duration of the clean-up 

operations on that beach, especially at night, to protect emerging hatchlings. If hatchlings must be 

intercepted (e.g., to avoid immediate threats), cages can be placed around the expected site of hatchling 

emergence by experienced, permitted personnel. Cages must be monitored regularly throughout the 

night and day in accordance with permit requirements.

These measures are captured within BMPs related to nesting beaches (see Appendix 15) that should 

be incorporated into the Incident Action Plan (IAP) for response activities when feasible. Resource 

advisors from the Environmental Unit should be made available to ensure clean-up crews follow the 

BMPs.

Protection of eggs and hatchlings ex situ

Translocation of eggs from in situ nest sites to unoiled locations may be necessary under some

extreme circumstances, namely when oiling of nesting beaches is inevitable or if hatchlings will likely 

enter an oiled environment after leaving their natal beaches. In these cases, several important logistical 

factors must be addressed to ensure that eggs will complete incubation as successfully as possible, 

including safe and careful handling of eggs, means of transport of eggs, and environmental conditions at 

the translocation site. The logistical support required for such efforts can be substantial. If translocation 

is deemed necessary, eggs should either be exhumed within 12 hours of deposition (or by 9:00 am the 

morning following deposition) or left to incubate in the natal beach until very near hatching to allow 

embryos to develop naturally. These timing considerations are important because developing embryos

are most sensitive to movement, which can result in mortality after around 4-8 hours following laying 

through late development (Miller 1997). To mimic the natural genetic differentiation related to nesting 

locations, hatchlings should be released as close to their natal beaches as conditions allow, provided 

these areas are suitably free of oil.

Nesting female considerations

Nesting females may become oiled either as a consequence of encountering oil at sea or while 

crawling through contaminated areas on the nesting beach. Most sea turtles nest at night when very 

few monitoring programs operate, thus few encounters with nesting females are expected in most 

situations. Depending on the size, location, and season of the spill, response may consider increasing 

nighttime nest monitoring, and, when possible, coordinate with active nighttime female tagging 

operations. Kemp’s ridley turtles are an exception to night nesting. They primarily nest during the day on 

beaches in the western Gulf of Mexico and must be considered as part of the oversight of beach cleanup operations in Texas.

Oil may be sampled from oiled nesting females to inform the UC’s assessment of wildlife effects and 

NRDA. Such sampling is done following nesting (so as not to disrupt the process) using oil-absorbent 

materials and appropriate PPE. Additional oil may be opportunistically removed from more heavily oiled

females to reduce their exposure. Due to the large size of nesting females and the potential for 

unintended consequences resulting from disruption of their reproductive cycle, further intervention 

(e.g., capture and transport to a rehabilitation facility) is generally reserved only for oiled females that 

are unable return to the water on their own and are thus considered stranded.
55

3.4.10. Directed capture

Operational procedures, process for establishing search areas 

Initial surveys of oil within offshore areas require a vessel with a raised helm in order to provide 

adequate opportunity for sighting sea turtles. If operations escalate to deployment of directed capture 

crews, additional vessel specifications must be considered. For directed capture of oceanic juveniles, 30-

58’ vessels with a raised helm (tower), an enclosed cabin or ample shade, and a cruising speed of greater 

than 20 knots provide a good working platform. A pulpit is useful for netting. Sportfishing vessels 

typically have the ideal attributes and maneuverability required to sight and capture turtles, are safe, 

and transport rescued animals with the necessary expediency. For operating in inshore areas, smaller

vessels of appropriate draft may be used, but should also have a raised helm or sighting tower, ample 

shade or cabin space, and the ability to cruise at speeds necessary to efficiently reach and work in target 

areas (typically greater than 20 knots).

Direct capture crews should include at least two individuals with experience capturing and handling 

turtles in addition to the captain and a mate (if required). A veterinarian also may be included if spill 

conditions dictate the need for medical evaluation and treatment in the field. A list of specific 

equipment necessary for deployment is provided in Appendix 9. All vessels should be equipped with a 

GPS, as vessel tracks must be recorded and search effort documented (Box 3-2). As discussed under 

Subsection 4.2.2, directed capture efforts should follow standard transect sampling methodology, which 

allows later analysis to estimate the total number of turtles exposed or injured by the oil spill. All crew 

should clearly understand operation rules and objectives, including animals/habitat to be targeted and 

any constraints related to capture (e.g., limitations on pursuit of turtles that actively evade capture).

Data sheets for sea turtle sightings and captures are provided in Appendix 9. In addition, the crew leader 

for each vessel should keep a daily written log that includes the time of deployment and return, general 

conditions at-sea (especially as related to observations of the spill), and any additional wildlife 

observations of note (including time and location).

The size of the spill will dictate the number of vessels required. Search efforts should focus on the 

most heavily oiled areas, but survey of the spill area should be conducted as completely and as 

frequently as possible. The longer transit times required to reach offshore areas should also be 

considered when planning and scaling effort. The strategy for deployment of vessels often relies on 

information from websites that report oceanographic conditions (e.g., probable location of convergence 

fronts), field reports of oil location, and aerial reconnaissance. Locating suitable search areas can be 

difficult, especially if far from shore.

Flights for aerial surveys typically are provided by or must be coordinated with the Air Ops Branch in 

Operations. Communication between aerial surveillance and vessels searching for oiled turtles is 

essential. There are a number of potential challenges associated with this coordination. Information 

from aerial operations is needed early in the day to identify appropriate search areas or it is not 

actionable. Search crews must also communicate closely with shore-based operations to ensure that 

ground transportation of animals is coordinated and rehabilitation facilities are prepared to receive 

See Appendix 

9, pg. 150
56

oiled turtles. Lastly, crews must be kept informed of other response activities (e.g., skimming, in situ

burns, and dispersant application) in order to avoid conflict.

Box 3-2. Important data and observations obtained by directed captures. Directed capture operations serve 

a dual role of saving individual sea turtles and documenting the effects of a spill in a manner that allows

estimating injury to turtles within the entire area of a spill. Photos: (top) Search transects and sighting data used to 

estimate numbers of turtles within a large spill area during the DWH spill (McDonald et al. 2017). Various degrees 

(minimal, light, moderate, and heavy) of oil exposure (lower left) documented in rescued turtles. 

Photodocumenting ingestion of oil (lower right), an important route of exposure for sea turtles.
57

3.4.11. Aerial surveys

Large, neritic juvenile and adult sea turtles dispersed over large geographic areas are most 

effectively observed by aerial surveys. Although aerial surveys do not allow for the rescue and 

rehabilitation of turtles, they are vital for directing capture or response assets on the water, to 

characterize the presence, distribution, and abundance of turtles relative to oil and response activities

(Box 3-3) (Garrison 2015). Aerial surveys can also be deployed to map the presence and distribution of 

habitat features relevant to sea turtles, such as Sargassum.

NOAA’s standard aerial surveys for sea turtles and marine mammals are typically conducted using 

DeHavilland Twin Otter (DH-6) planes that fly at approximately 600 ft altitude at an airspeed of 100 

knots (185 km hr-1). Surveys are usually flown only in favorable viewing conditions and are not 

conducted when sea states exceed 4 on the Beaufort scale (typically surface winds > 15 knots) or during 

fog, rain, or other conditions that limit visibility. In manned aircraft, in addition to a pilot, the crew 

should include at least two experienced aerial observers (depending on the number of viewing bubbles 

in the plane), and an additional scientist to record sightings, weather, and visibility data on a laptop 

computer connected to a GPS and running data-acquisition software. Sighted animals are photographed 

to assist in species identification, group size (if applicable, primarily for mammals), and association with 

oil or other habitat features. Visibility data (e.g., sea state, weather, cloud cover, water color, water 

turbidity, glare for each side of the trackline, and sun penetration into the water) are recorded every 15 

min or when conditions change. Observers rotate viewing positions at regular intervals (typically every 

20 min) to reduce fatigue.

Box 3-3. Aerial surveys provide observations of sea turtles while at or near the surface and are the basis of density and 

abundance data across wide areas of the U.S. continental shelf.
58

Surveys should be designed in accordance with recommendations for line-transect “Distance” 

sampling as described in Buckland et al. (2001). Regular survey tracks for NOAA aerial surveys are 

included in the Environmental Response Management Application (ERMA). The number of animals is 

estimated and identified to the lowest taxonomic group possible. Observers should also record 

observations of surface oil including details about its appearance (e.g., sheen, mousse, dark oil, 

patchiness) and spatial extent. If weather conditions permit, surveys should be designed to cover the 

entire spill area within three to four flight days, and surveys of the entire area should be spaced 

approximately seven to ten days apart, depending on the circumstances of the spill. 

Other types of aircraft, such as helicopters and smaller planes, might be used for nearshore areas 

and barrier islands. These smaller-scale aerial surveys use alternative protocols to those used by 

standard NOAA aerial surveys. All survey flights must be coordinated with other response aerial assets, 

and usually under the operational direction of the Air Ops Branch in the Operations Section.

In addition to surveys using aircraft with trained observers, which are the typical aerial survey 

method, other tools are available for obtaining visual imagery data at different scales (Box 3-4). 

Unmanned aerial vehicles (UAVs), including powered craft, kites, and balloons equipped with cameras 

are an emerging technology with regard to study of sea turtles, and potentially can be used to detect 

and observe turtles within a spill area or to assess potential effects on habitat (Seymour et al. 2017;

Hodgson et al. 2018). The various options available can be flown as different altitudes, depending on 

specific needs. Digital aerial imagery can produce high-resolution, archival data, which may be used for

species identification, size estimation, and location relative to features of interest, such as surface oil.

Additional advantages include the ability to observe smaller sea turtles that cannot be reliably seen from 

manned aircraft and the opportunity to detect greater numbers of animals that may be visible to vesselbased observers. 

Box 3-4. Alternative methods for obtaining aerial imagery of animals and oil. Digital aerial imagery can provide 

valuable high-resolution visual data during an oil spill, such as characterization of presence and size of sighted animals 

relative to features of interest, particularly surface oil, as 

well as description and measurement of habitat (e.g., 

Sargassum). Unmanned aerial vehicles (UAVs, or drones) 

are an alternative to manned aircraft; various options

exist that can be flown at different altitudes, depending on 

the subject of interest. For example, non-NRDA 

researchers used balloons and kites with 

commercially available camera systems to document 

DWH oil in nearshore coastal habitats in Louisiana. The

image on the right, obtained by a camera attached to a 

helium balloon, shows strands of surface oil off the coast 

of the Chandeleur Islands, Louisiana, during DWH spill. 

https://publiclab.org/wiki/gulf-coast
59

3.4.12. Vessel-based surveys

Vessel-based surveys may be conducted as a means of assessing sea turtle presence and density 

within spill areas, to opportunistically capture oiled turtles, recover dead turtles, and as a complement

to aerial surveys (i.e., provide finer scale spatiotemporal exposure data and observations of life stages 

not seen by aircraft). These operations are distinct from directed capture operations reviewed in 

subsection 3.4.10, which have been used thus far primarily to recover small oceanic juveniles. Vessel 

surveys are intended to detect neritic juveniles and adults, especially within continental and insular shelf 

and inshore waters. These larger life stages spend less time at the surface and tend to be dispersed, thus 

efforts are likely to be more observational than interventional. Similar to aerial surveys, environmental 

conditions, such as sea state and water clarity, strongly influence sightability. For example, more 

sightings are expected in calm conditions and shallower areas with good water clarity, and less with a 

higher sea state and deeper and/or turbid water. In addition, many of the capture methods typically 

used on larger sea turtles may not be feasible if associated with danger to field personnel – this 

effectively prevents any human entry into oiled water (hand-capture) or contamination of large 

equipment (trawl or tangle nets) with oil. Dip nets may be used, but are only effective in some

situations. Recovery may be limited to debilitated or deceased turtles. Nonetheless, vessel-based 

surveys provide valuable information related to effects of a spill and response actions on sea turtles and 

their habitats.

Basic methods, materials, and protocols provided in Appendix 9 are also used for vessel surveys. It is 

important that survey plans ensure that affected areas are comprehensively examined with due 

attention to heavily impacted or ecologically sensitive locations. Sightings and effort (including recording 

and preservation of GPS tracks) should be clearly documented. Vessels suitable for a given area (e.g., 

size and draft) must be selected. A raised helm or sighting tower is essential to allow effective sighting of 

sea turtles, thus existing sea turtle research vessels are an ideal option, although these are few in 

number. Vessel crews should include at least two people with experience sighting and handling sea 

turtles so that they are able to conduct surveys in a confident and reliable manner, and safely render 

assistance to oiled turtles and other wildlife if necessary. Personnel with experience sighting and 

identifying sea turtles may be deployed on vessels intended to survey spill areas for multiple types of 

wildlife, especially during the initial period of a spill. However, such multi-species efforts are not 

necessarily a suitable surrogate for designated sea turtle surveys.

3.4.13 Basking turtles (Hawaii)

Green turtles come ashore to bask on all of the main Hawaiian Islands (e.g., Hawai’i, Maui, 

Lana’i, Moloka’i, O’ahu, Kaua’i) and in the Northwestern Hawaiian Islands Marine National Monument 

(including Nihoa, Necker, French Frigate Shoals, Gardner Pinnacles, Maro Reef, Laysan, Lisianski, Pearl 

and Hermes, Midway, Kure). In the main Hawaiian Islands, basking is more prevalent than nesting and 

poses a greater exposure to shoreline oil or other contaminant events as turtles may bask for hours to 

days. Maps of known basking locations are provided in Appendix 2. Larger turtles typically emerge in the 

midmorning through the afternoon hours and may remain on shore for up to 48 hours, whereas 

juveniles may emerge from the water during sunset and remain on the beach throughout the night.

These sites are not regularly attended by resource agency staff, with few exceptions such as Laniakea 
60

Beach (north shore O’ahu) and Hookipa (north shore Maui). Some locations are within populated areas; 

many are remote. Some basking areas also are used by the endangered Hawaiian monk seal 

(Neomonachus schauinslandi), which is another protected species that may be affected by an oil spill in 

this region. An oil spill impacting locations where turtle basking is known to occur can result in oiling of 

turtles in the water or as they come ashore, as well as injury from shoreline boom and cleaning 

equipment. It should not be assumed that sea turtles attempting to bask will avoid oil, thus intensive 

monitoring is recommended as these turtles typically show high site fidelity for basking areas.

In the event of a spill involving a basking area, knowledgeable observers should continuously 

monitor these areas (24 hours) to prevent interactions with equipment and clean-up personnel. If 

necessary, multiple observers should be deployed to provide adequate attendance of clean-up 

operations and regular survey of the spill area. If determined necessary, basking turtles could be 

discouraged from emerging onto oiled shorelines or transported by permitted personnel to un-oiled 

locations for release. However, it is important to note that such displacement likely will only be

temporary because individual turtles return to specific basking sites. Any oiled basking turtles may be 

cleaned, temporarily housed, rehabilitated, and released at designated locations as described in Section 

3.4.7. 
61

As discussed in Section 2.1.1, NRDA under the Oil Pollution Act (OPA) of 1990 is a restorationfocused, statutorily-based process for the identification, evaluation, and quantification of injuries to 

natural resources and services as a result of exposure to oil and/or response actions, and development 

and selection of restoration actions for injured resources and their services. In the event of an oil spill, 

the natural resource Trustee(s) will follow the process set forth in the OPA NRDA regulations to 

determine whether a NRDA should be pursued. Should a NRDA be undertaken, technical working groups 

(TWGs) comprised of trustee agency representatives and associated experts may be formed to focus on 

specific animal or plant groups or ecological areas. Experts representing the RP’s may also participate, 

depending on the nature and extent of the RP’s agreement to work cooperatively. A comprehensive 

review of all NRDA elements is beyond the scope of this document, rather the focus herein is technical 

considerations that may help inform a damage assessment for sea turtles. Additional general 

information regarding NRDA can be found in documents available from the Departments of the Interior 

(DOI) (e.g., BLM-NRDA 2008; NPS 2003) and Commerce (e.g., NOAA-DARP 1996).

Information and samples collected under the NRDA may be used as evidence in any potential 

related litigation, as with that collected during response activities, thus the chain of custody procedures 

are equally applicable (see Subsections 3.4.1 and 3.4.3). Those involved with NRDA will also need to 

retain all documents, samples, photographs, data, and other materials as directed by the NOAA General 

Counsel Office, the DOI Office of the Solicitor, and/or the US Department of Justice. Additional guidance 

related to handling of data, samples, and other evidentiary materials, such as for researchers conducting 

NRDA studies, may be provided by legal counsel or NRDA case managers.

4.1. Assessing exposure and injury to sea turtles: conceptual model

An example of a conceptual model for exposure of sea turtles to oil and injury resulting from this 

exposure, as well as response activities, is shown in Figure 4-1. A conceptual model should be tailored to 

depict the facts and considerations specific to each spill. Notably, many of the key elements of this 

example conceptual model rely on data collected during the response phase of an oil spill (e.g., 

establishing exposure and pathway), thus close alignment of response operations and NRDA activities, 

to the degree possible, can support a strategically sound and efficient assessment. However, NRDA is 

distinct from response and NRDA practitioners must coordinate within the response structure. Examples 

of information that are important to NRDA and may be collected under response operations include: 

direct observations of exposure of animals to oil, determination of resulting health effects and mortality 

due to exposure to oil or as a result of response actions, documentation of disruption of reproduction 

and other biological functions, and demonstration of loss of important habitat or prey. Such information 

can be ephemeral and requires targeted, proactive collection.

4. Natural Resource Damage Assessment (NRDA) and sea 

turtles: conceptual model, integrating response data, and 

tools for assessment 
62

The overview of NRDA as related to sea turtles provided in this section follows the convention of 

other aspects of these guidelines in terms of threats posed by an oil spill to different life stages and 

habitats. Specific considerations are organized under three broad ecological zones: terrestrial, oceanic, 

and neritic environments. Subsection 4.2 reviews opportunities for data collection during the response 

phase of an oil spill and important considerations with regard to NRDA applications. Subsection 4.3

considers different types of data, analyses, and studies that may be used for NRDA and includes

rationale for prioritization and a heuristic rubric of important factors to evaluate when developing and 

executing a NRDA for sea turtles. Subsection 4.4 discusses how restoration planning factors into 

selection of injury assessment approaches. Subsection 4.5 reviews important aspects of data 

management under NRDA and tools available to NRDA practitioners. 

Figure 4-1. Conceptual model of the approach to sea turtle injury assessment. For the purposes of NRDA, injury is often 

quantified as the number of animals that died or were lost due to diminished reproduction. Quantification may be further 

provided by species or life stage.
63

4.2. Oil spill response and NRDA

This subsection highlights information applicable to NRDA for sea turtles that tends to be 

collected by response operations or that generally is most available during the period of an oil spill 

response. In addition to these considerations, assessment of exposure to an oil spill and resulting injury 

greatly benefits from the availability of baseline data for comparison with data and observations 

collected during and following a spill, which can be pertinent to both acute and long-term effects. 

Ideally, baseline data are collected either routinely, or in the recent past, prior to the spill. However, 

NRDA can collect this type of ephemeral data after an oil spill 

occurs if the Trustees determine that the oil and/or response 

actions have not yet impacted the baseline. Examples of 

baseline data that may be useful for sea turtles include in-water 

studies aimed at collecting vital population and health-related 

data (e.g., metrics of abundance, growth rates, habitat use, 

movements, nutritional indices) and nesting studies (e.g., nest 

numbers, hatching success, deformity rates). As long-lived 

species, such studies are often lengthy endeavors that exceed the timeline of most NRDAs. Nonetheless, 

if important baseline data are unavailable, initiation of these efforts, provided the animals have not yet 

been impacted by the oil spill, eventually may yield information on spill effects that benefit sea turtles

and future NRDAs.

Effects of oil spills on habitat, prey, and forage is another concern as both a route of exposure and 

effect through loss of nutritional resources and other disruption of the ecosystem as a result of an oil 

spill. Within the NRDA framework, representatives of the sea turtle TWG should coordinate with other 

TWGs and response personnel that hold or may collect pertinent information related to prey, habitat, or 

other linkages to sea turtles.

4.2.1. NRDA considerations for the terrestrial zone 

There are a number of metrics that can be incorporated into an injury assessment involving sea 

turtles in the terrestrial zone, which is mainly the nesting beaches. Some key measures of injury that 

might be documented by appropriately trained response personnel include direct observations of oiled 

nesting turtles and their nests, mortality of oiled adults and embryos/hatchlings, destruction of nests, 

deterrence of nesting females, and disorientation of nesting turtles and hatchlings. These data may be 

used by the Trustees to determine if there were any negative impacts to reproduction as a result of a

spill. Depending on the spill, the NRDA may want to undertake additional sea turtle nesting monitoring 

effort to supplement areas where response may not be able to visit and/or to provide more frequent 

and/or systematic search information. Many well-monitored nesting beaches within the U.S. have 

historical datasets that can be used to detect potential spill-related effects, such as changes in the 

number of nests, increased disorientation events, or other biological parameters (e.g., hatching success).

For example, following the DWH oil spill, sea turtle nest densities within the spill area were compared 

with similar sites to demonstrate a reduction in nesting that was attributed to deterrence of females 

caused by shoreline response operations (DWH NRDA Trustees 2016; Lauritsen et al. 2017).

Baseline - the condition of the natural 

resources and services that would have 

existed had the incident not occurred. Baseline 

data may be estimated using historical data, 

reference data, control data, or data on 

incremental changes (e.g., number of dead 

animals), alone or in combination, as 

appropriate (15 CFR § 990.10).
64

Beyond relatively straightforward injuries that may result from an oil spill, there are other types of 

injury that merit consideration for NRDA. One area of concern is effects of oil on the nesting 

environment and developing embryos. As with other taxa, turtles are thought to be especially sensitive 

to harmful effects of oil contamination during development. Field and laboratory studies of the effects 

of oil on turtle eggs have yielded mixed results, ranging from no biological effect to increased deformity 

rates and mortality (Fritts and McGehee 1982; Van Meter et al. 2006; Rowe and Mitchelmore 2009).

These studies suggest that the outcome is influenced by the timing of exposure and composition of the 

oil (i.e., type of oil, degree of weathering). The magnitude of contamination likely is a factor as well. 

Physical effects of oil on fluid and gas exchange by egg shells and characteristics of the nesting substrate 

and incubation chamber are also considerations. These potential effects on sea turtle embryos should 

be considered for any spill that results in oiling of active sea turtle nesting beaches. Data on hatching 

success, embryo mortality, and deformities are commonly collected by nest monitoring programs (as 

well as those conducted under response actions), but additional measures may be necessary for NRDA 

applications, such as increased sampling effort, enhanced characterization of embryo mortality, studies 

of hatchling health and fitness, and collection of biological samples necessary for demonstrating 

exposure in ovo.

Another pathway of embryonic exposure that could be relevant to NRDA, but is poorly understood,

is the transfer of chemical constituents of oil, especially polycyclic aromatic hydrocarbons (PAHs), from 

adult females to their offspring. Lipophilic (fat-associated) compounds, such as PAHs, may pass from a 

female turtle to her eggs during the yolk formation phase (vitellogenesis) of egg production and is 

mentioned in the literature as a possible route of PAH exposure for turtles (Bell et al. 2006). Although 

PAHs have been measured in nesting female sea turtles (Camacho et al. 2012) and eggs (Alam et al. 

2000), there have been very few studies of maternal transfer in any animals (e.g., Tilghman and Oris et 

al. 1991; Fournier et al. 2010). Understanding potential maternal transfer of PAHs in sea turtles is 

complicated by their reproductive biology. Vitellogenesis begins approximately 8-12 months prior to 

breeding and is completed by the time female turtles arrive at nesting areas (Miller and Limpus 2003). 

Thus, exposure of females on foraging grounds or during reproductive migration could potentially lead 

to transfer of PAHs to developing eggs, but this route of exposure may be less significant if exposure 

occurs after completion of vitellogenesis. Furthermore, assemblages of females at a given nesting beach

may include turtles originating from multiple foraging areas, which could have different levels of PAH 

exposure. Additionally, transfer of PAHs during actual egg formation (i.e., deposition of the albumen and 

the shell) has not been studied. Relevant to NRDA, demonstration of maternal exposure would need to 

carefully consider the timing of the spill relative to reproduction, potential for variation in background 

exposure, and the importance of baseline PAH data, which are lacking for most major nesting areas.

Translation of such exposure to injury should consider demonstration of adverse effects on embryos or 

hatchlings, as previously discussed.

The effects of oil on maternal health and reproduction through direct sublethal effects on female 

turtles or indirect effects associated with loss or alteration of prey and habitat is another consideration, 

but has not been closely examined in any turtle species. The ocean-going nature of sea turtles, their 

reproductive migrations, and natural variation and complexity in their reproductive biology are 
65

significant challenges to investigation of such linkages. Nonetheless, these potential effects warrant 

consideration during NRDA.

4.2.2. NRDA considerations for turtles in the oceanic zone

As described in Section 3, observations and data collected on sea turtles within the oceanic zone

during response operations can yield valuable information relevant to exposure and injury, including 

documentation of exposed sea turtles, harmful effects, and environmental conditions (Box 4-1). As a 

notable case example, data collected by directed capture operations during the DWH spill as part of 

response efforts supported the Trustees’ determination of injury to sea turtles (DWH NRDA Trustees 

2016). Oceanic (surface-pelagic) juvenile turtles are especially at risk during an oil spill within the 

oceanic zone; therefore, much of this subsection pertains specifically to this life stage. Considerations 

for large juvenile and adult turtles that also are found in the oceanic zone are included in the next 

subsection (Subsection 4.2.3).

Field observations of oiled turtles and oil ingestion can be used to document and characterize 

exposure. Observational data on the condition and behavior of animals, necropsy findings, and results of 

clinical evaluation at care facilities – including physical examination findings, blood analyses, and 

diagnostic imaging results – can aid injury assessment. Thus, directed capture efforts should be welldesigned and executed to maximize information collected in addition to fulfilling the primary objectives 

of rescuing and rehabilitating oiled animals. Example field data forms provided in Appendix 9 are 

intended to record data that are essential for these purposes. In addition, comprehensive review and 

compilation of all medical-related data collected from sea turtles in the field and at rehabilitation 

facilities may be used to evaluate the effects of exposure. These health assessments generally are done 

by veterinarians and other experts with specific knowledge of sea turtles and expertise in fields such as 

clinical medicine, pathology, and toxicology.

Many types of information require additional effort and planning to collect, highlighting the 

importance of coordinating response efforts with NRDA studies and intra-NRDA studies, to the extent 

feasible, to be efficient and cost-effective. For example, classifications of various degrees of internal and 

external oil exposure, coupled with veterinary evaluations of physical and physiological conditions of 

rescued sea turtles, provided the technical framework for the overall DWH sea turtle injury assessment 

across multiple life stages. The severity of oiling (i.e., minimal, light, moderate, heavy; see Box 3-2) was 

categorized using field observations and photographs, and oil ingestion was subjectively assessed based 

on the quantity of oil observed within the mouths and throats of rescued turtles. Other types of data are 

time sensitive, highly situation-dependent, and may require additional resources or specific effort to 

collect beyond response operations. For example, hyperthermia or hypothermia can affect turtles after 

they become oiled, or after stranding due to having been oiled; these conditions are most accurately

documented at the time of discovery (in the field) rather than at rehabilitation centers. Similarly, some 

blood parameters that are affected by oiling, such as stress hormones, blood gases, and pH, also are 

affected by capture, handling, and transport, and therefore must be sampled or measured in the field in 

order to more confidently attribute cause.
66

As subsequently discussed in Subsection 4.3.1, data collected during response related to exposure 

and injury may include only a partial sampling of the spill area, especially for large and protracted 

events, or those that occur in remote locations. Under NRDA, these response data may need to be 

expanded to account for injuries that are representative of the entire footprint and duration of the spill

(Box 4-2). Protocols for vessel surveys should be carefully reviewed and use established methodology 

that is adequate for later quantification analyses. As demonstrated during the DWH spill, vessel-based 

search and rescue transects provided a survey framework from which empirical observations of oiled 

turtles could be expanded to overall densities and abundances of each species encountered (McDonald 

et al. 2017). Especially for larger spills, a statistician should work with data managers to monitor the 

incoming data to ensure that the information is adequate for calculation of these extrapolations in case 

they are needed.

In the Atlantic and Gulf of Mexico, another important consideration for juvenile oceanic turtles is

loss of habitat comprised of a floating macroalgae (Sargassum sp.), which can be destroyed by oiling or 

clean-up operations. Sargassum is very dynamic in terms of density and distribution because it 

constantly breaks apart, coalesces, undergoes senescence, and regenerates as it is transported in 

surface currents. Sargassum and the floating ecosystem that it creates, including juvenile sea turtles, is

vulnerable to surface oil, which also tends to accumulate within convergence fronts in offshore areas.

Box 4-1. Boat-based rescue efforts documented more than 900 sea turtles 

in the DWH spill zone. Photos: (upper left) locations of turtles captured and 

assessed during rescue operations, shown by species and degree of oiling, 

overlaid upon cumulative oil-days within the overall oiling footprint (note: nearly 

all heavily oiled turtles were found within 90 kilometers of the wellhead, and 

prior to August 1, 2010); (upper right) boat-based rescue efforts on search 

transects within offshore convergence areas that are known habitats for small 

juvenile sea turtles; and (lower right) a NOAA veterinarian assessing the 

condition of a heavily oiled sea turtle rescued from oiled surface habitat.
67

Quantification of Sargassum habitat loss, along with information about how sea turtle densities vary

with Sargassum patches of different sizes, are an important consideration for NRDA injury assessment 

studies focused on oceanic sea turtles. Accurate assessment of oiling and losses of Sargassum over large 

areas likely requires aerial surveys (e.g., fixed wings, unmanned aerial vehicles (UAVs)) during the time 

period where oil is still being discharged, calibrated with fine-scale assessments. Satellite imagery can 

provide a platform for broad-scale Sargassum studies, but may underestimate Sargassum coverage by 

missing smaller dispersed patches, which can still serve as habitat for turtles. Therefore, validation using

high-resolution imagery or direct measurements in the field are needed, which may include data or 

observations collected during response operations (Hu et al. 2016).

Box 4-2. Use of direct observations of turtles in oil to estimate total injuries across the entire footprint and spill 

period. Careful documentation of search area and effort can be used to estimate the numbers of sea turtles within the spill 

area (McDonald et al. 2017), and these estimates and field observations can be combined to investigate the degree of 

exposure and injury over large spatial and temporal scales (Wallace et al. 2017).
68

4.2.3. NRDA considerations for turtles in the neritic zone

Information on exposure of sea turtles within neritic areas to an oil spill and assessing the effects of 

oil and response activities may rely on a combination of direct and remote methods. Aerial surveys 

(manned by observers or camera-equipped UAVs) are the most practical means of documenting and 

estimating the number of large juvenile and adult sea turtles within a spill area. Due to seasonal and 

inter-annual differences in the presence of turtles, it is recommended to collect these data for each spill.

Whenever possible, established tracklines and methodology (Buckland et al. 2001) should be the basis of 

any NRDA study attempting to document turtles within a spill area for eventual statistical estimation of 

density, total abundance, potential degree of interaction with surface oil, or other factors relevant to 

exposure and injury assessments. NOAA has conducted aperiodic fixed-wing and shipboard surveys to 

document presence and estimate abundance of sea turtles throughout U.S. Exclusive Economic Zones in 

the Atlantic Ocean, Gulf of Mexico, and Pacific Ocean (Appendix 1). Aerial and shipboard surveys 

undertaken for response or NRDA purposes should consider collecting survey data in a similar manner, if 

appropriate, to maximize comparability with historical/baseline data. In addition to these uses, 

photographs from the air of sea turtles in and around oil are valuable for demonstrating exposure and, 

potentially, injury.

Although aerial surveys provide information about the presence and distribution of sea turtles in 

relation to a spill, complementary vessel-based surveys within the spill area may also be needed in order 

to: 1) characterize environmental conditions from the perspective of sea turtle exposures; 2) provide 

additional direct documentation of exposure; and 3) detect smaller turtles (<45 cm SCL) that are not 

reliably visible from aircraft if alternative methods (e.g., survey by UAV) are not feasible. As with 

directed capture of oceanic juveniles, vessels participating in these surveys should carefully document

search tracklines and effort so that results can be quantified, expanded, and used to corroborate other 

data.

Large juvenile and adult turtles can be evaluated for response and NRDA purposes if they strand 

ashore or if they are captured during the course of spill response operations (e.g., directed or incidental 

captures). Veterinary assessment of live oiled turtles and necropsy of recovered dead turtles may yield 

information about exposure and adverse effects. However, due to their large size, active and prolonged 

diving, and dispersed distribution - directed capture, as conducted for oceanic juveniles, is likely to be 

more difficult and resource-intensive for these larger turtles in many circumstances. Moreover, human 

safety concerns within active spill areas prevent the use of common capture techniques, such as 

deployment of nets and in-water hand capture. These challenges also are relevant for large juvenile and 

adult turtles within oceanic areas, thus similar approaches apply to large turtles in both zones. 

Other methods may be used to assess exposure and injuries to neritic stage turtles when direct 

evaluation is difficult or impossible. For example, during the DWH NRDA, comprehensive satellitederived data corroborated by field observations of sea turtles in oil was used to characterize the entire 

surface oil footprint (e.g., extent, thickness) and estimate the distribution and degree of oil exposure 

experienced by neritic stage turtles documented by aerial surveys (Box 4-2) (Wallace et al. 2017). These 

analyses were used to estimate both exposure and injury (DWH NRDA Trustees 2016). Because remotely 

sensed surface oil data are likely to be collected in future spills, this type of analytical approach could be 
69

adapted to other situations where empirical data reflect a partial sampling, as is probable during a larger 

oil spill. Other sources of data on sea turtle presence, movements, and habitat use from in-water and 

satellite telemetry studies (e.g., Foley et al. 2014; Hart et al. 2012; Hart et al. 2017; Mansfield et al. 

2014; Shaver et al. 2013) can be similarly used to demonstrate exposure to an oil spill (Hart et al. 2014;

Vander Zanden et al. 2016)(Box 4-3). Applications of remotely collected data for NRDA purposes are 

enhanced when corroborated by direct observations in the field. Thus, potential future needs of data 

and observations that can only be acquired during the response phase of a spill, such as empirical 

information on oil thickness and documentation of sea turtles in oil, must be carefully considered from 

the outset.

Box 4-3. Use of satellite telemetry to demonstrate foraging home ranges of loggerhead turtles within the area of 

the Deepwater Horizon oil spill. Such approaches can be valuable for investigating oil exposure at-sea and 

demonstrating threats to important habitat (Hart et al. 2014).
70

4.3. Prioritizing exposure and injury assessment tools for NRDA for sea turtles

This section reviews factors for NRDA practitioners to evaluate when considering how to prioritize 

among potential exposure and injury assessment approaches and studies for NRDA. First, special 

considerations are described that apply generally to assessing oil exposure and injuries involving sea 

turtles. Next, various metrics and study approaches are presented and discussed in the context of

assessment of specific life stages and habitat types. This information should be considered on a case-bycase basis according to the specific circumstances and characteristics of each oil spill and the associated

conceptual model.

4.3.1. Special considerations for approaches to determining exposure and injury under 

NRDA

There are several general issues that may be encountered when constructing a NRDA that warrant 

careful consideration when selecting and planning studies of any sea turtle life stage. These issues 

include methods for detecting exposure as related to the specific petroleum product of interest; 

toxicological testing to identify effects, particularly sublethal effects of oil exposure; expanding 

quantification from partial sampling effort to the full extent of the spill; and incorporating uncertainty in 

quantification of both exposure and injury.

Characteristics of oil and relevance to assessing exposure and injury in sea turtles 

Many different types of petroleum and its derivatives are included under the term “oil spill,” from 

crude oil to highly refined products. All are complex mixtures of chemicals in different proportions, 

including classes of organic and inorganic compounds with different properties and toxicological effects.

Composition and other characteristics of these products are determined by factors such as location and 

depth of origin, extraction methods, refining, and weathering. The most injurious compounds in oil are 

believed to be the aromatics, i.e., those comprised of one or more six carbon rings joined by alternating 

double bonds (Neff 1979; Krahn and Stein 1998). The small single ring compounds, such as benzene, are 

especially hazardous and are known to be both carcinogenic and damaging to organs of vertebrates.

These smaller aromatics also are more water soluble and volatile, thus they are readily bioavailable but 

also are rapidly dispersed. The large multi-ring aromatics (PAHs) are more persistent and also are

associated with a variety of toxicological effects in animals. Notably, PAHs in petroleum products are 

highly alkylated whereas most toxicological studies have been done with non-alkylated forms due to the 

limited availability of alkylated PAH standards. All of these considerations are important when planning 

studies of specific toxicity endpoints or evaluating anticipated effects based on prior studies.

With regard to detection of exposure, dermal contact and ingestion of crude oil and similar products 

generally manifests as grossly visible oiling – material that can be photodocumented, readily sampled, 

and chemically analyzed. In some situations, other materials, such as brown algae, can have a similar 

appearance and may need to be distinguished from oil by microscopy or chemical analysis. Exposure to 

lighter, refined products may not be as evident by simple visual examination. Similarly, detection of 

exposure by inhalation, ingestion that does not cause frank oiling (e.g., ingestion of contaminated prey 

or sediment), or exposure in ovo also require chemical analysis.
71

Chemical detection of exposure to petroleum products beyond that apparent by visual inspection 

generally relies on detection of PAHs, either parent compounds or their metabolites. An important 

characteristic of PAHs is that these compounds are rapidly metabolized by vertebrates and are excreted 

primarily in bile, urine, and feces. Therefore, timing of exposure must be considered when selecting 

appropriate biological samples for PAH analysis and interpreting results. Analysis of tissues (parent 

compounds), bile (metabolites), urine (metabolites), and gastrointestinal contents (parent compounds 

and metabolites) can be useful for detecting recent or ongoing exposure, but also can be very insensitive 

due to high rates of metabolism. Bile was observed to be much more sensitive for detection of PAH

exposure in sea turtles exposed to crude oil in comparison to other sample matrices (Ylitalo et al. 2017).

However, bile rapidly degrades postmortem and cannot be collected from live turtles. Selection of 

chemical analyses to be used to assess exposure in sea turtles for NRDA requires attention to timing and 

degree of exposure, anticipated sensitivity of analytical assays and available sample types, and risk of 

false negative results.

Assessing potential toxicological effects of oil exposure on sea turtles

Various measures of oil toxicity, specifically those related to chemical effects, may be used for injury 

assessment under NRDA, either as means of confirming or corroborating observations in animals oiled 

during a spill or to assert effects that cannot be easily measured or observed in wild sea turtles. These 

approaches may be in the form of analysis of sublethal toxicity endpoints (such as biomarker assays, 

metagenomic analyses, immune function testing, and measures of genotoxicity) in animals exposed to 

oil; laboratory studies; or risk assessments based on modeled exposure regimes, chemical analyses, 

literature reviews, and other data. It is important to note that some samples, analytical results, and 

other information needed for some of these applications must be collected during the spill response 

phase and may be beyond the scope of standard clinically-based evaluations. Coordination and 

cooperation between response and NRDA is needed to determine the best path forward to collect data 

needed by NRDA while not impeding response activities with sample collection and processing that is 

not needed to treat the animals.

As with all assessment studies, for any toxicology-related analyses considered for NRDA purposes, 

the potential efficacy, logistical requirements of a robust experimental design, and clarity of expected 

results should be carefully deliberated prior to implementation. Life stage, exposure route, dose, and 

duration of exposure are some key parameters that must be considered. For example, although sea 

turtles exposed to oil in the field can provide essential information on effects of oil, dose and duration of 

exposure typically are unknown, which complicates interpretation of some toxicity endpoints.

Laboratory exposure studies under controlled conditions may provide a more straightforward means of 

assessment, but should be relatable to exposures under spill conditions. Also, studies or analyses aimed 

at measuring sublethal endpoints should provide a clear contribution to the exposure or injury aspects 

of a conceptual model.

Expanding observations to spill-wide effects

Once exposure to oil and effects of that exposure or response activities have been documented, 

some expansion from direct observations to the complete spill area (and beyond for migratory species 
72

such as sea turtles) and time period is often necessary for NRDA. This is because any response and 

assessment activities related to a marine oil spill are unlikely to cover the complete extent and duration 

of a spill, except in geographically confined situations and relatively small incidents. One tool for this 

purpose is satellite telemetry, which can provide information about sea turtle movements and potential 

exposure to oil over large geographical areas (e.g., Hart et al. 2012; Hart et al. 2014). For other purposes, 

such as injury quantification, the case team may need to rely on statistical techniques to extrapolate 

conclusions from partial information. An example of such an approach is the model-based estimation of 

sea turtles harmed by the DWH spill, which applied field observations of exposure and veterinary and 

toxicological-based assessments to investigate exposure and injury over the full extent and duration of 

the spill (DWH NRDA Trustees 2016; Wallace et al. 2017). These methods require data that support 

extrapolation through proper study design and collection methods. NRDA study protocols, e.g., those 

used for vessel, aerial, and shoreline surveys, should be reviewed to ensure that methods and 

assumptions are as robust as possible with forethought that data may be used for statistical expansions.

Incorporating uncertainty in exposure and injury quantification

Determination of adverse sublethal effects, application of these effects to injuries, and expansion of 

directly observed oil-turtle interactions to the full extent of the spill are approaches that inherently 

contain uncertainty in empirical and statistical terms. In the context of NRDA, accurate (reflecting actual) 

and precise (little uncertainty) values for exposure and injury quantification facilitate the determination 

of the amount of restoration needed to make the environment and public whole. Exposure and injury 

quantification should be conveyed with appropriate descriptions of uncertainty (e.g., standard 

deviation, range, appropriate confidence intervals), as in any scientific presentation of such values. 

Technical personnel performing quantifications of exposure and injury should seek guidance from case 

management (legal and technical) about presentation of uncertainty associated with quantification. 

4.3.2. Evaluation of tools and metrics for determining sea turtle exposures and injuries 

under NRDA

This section discusses prioritization of various tools and studies currently available for sea turtle 

NRDA and consists of three tables - one for each of the main ecological zones and associated life stages.

Various metrics and approaches are considered with regard to exposure and injury and are described in 

terms of feasibility (including existence of established methods and availability of necessary data), 

considerations under NRDA (study design, expected challenges, useful resources), and rationale for the 

given level of prioritization. The content of these tables is based on deliberations and experiences of 

trustee agency personnel and other experts participating in prior NRDAs involving sea turtles. Priority 

levels are intended as a general ranking of value and importance and will vary according to the 

characteristics of a specific spill. 
73

Table 4-1. Terrestrial areas (i.e., nesting beaches): tools and metrics for sea turtle NRDA assessments. Priority level synthesizes details of all factors to help weigh the

relative utility of each tool / metric and associated assessment approaches for constructing sea turtle injury assessments under NRDA. Priority levels are indicated as 

“high”=, “medium”=, and “low”=. This table is not intended to be an exhaustive list. Depending on the circumstances of the spill and the evolution of 

scientific understanding, other assessment activities could provide useful data for NRDA.

Pathway and exposure to oil and/or to shoreline response activities

Tool / metric Feasibility / methods Considerations / applications Prioritization rationale

Quantification of nest locations 

and densities



Methods for locating and 

documenting nests are 

well-established.

Requires engagement with regional nest monitoring 

programs, implementation of necessary documentation 

procedures, and potentially increased beach 

surveillance effort. Spatial analysis can be used to 

study overlap between oil, response activities, and sea 

turtle nesting. Data sets exist for comparing nesting 

activity within spill areas with historical records and/or 

comparable unoiled beaches. Metrics can be 

translated to injury quantification and restoration.

This information informs a number of potential sources of 

injury, including direct destruction of nests, oiling of nests, 

and deterrence of nesting resulting from spill-related 

human activity and other disturbances (e.g., deployment 

of shoreline boom). Moreover, knowledge of the locations 

of nests is necessary for protective measures.

Spatial and temporal data on 

shoreline oil and response 

activities



Data on shoreline activities 

and distribution of oil are 

routinely tracked by 

response.

Ensure that data are sufficiently detailed to allow for 

analysis of effects on turtles. Comprehensive 

compilation will require data from many different 

sources. Metrics can be translated to injury 

quantification and restoration.

Helpful for basic analyses of spill effects on turtles, 

nesting, and nests.

Oiling of turtles, hatchlings, or 

eggs



As above, the necessary 

methods are wellestablished.

As above Direct evidence of exposure helps link a spill with any 

observed effects on turtles, hatching or development.

Satellite telemetry tracking of 

nesting females



Technology is readily 

available for tracking animal 

movements, including 

within an oil spill area.

Study design should consider likelihood of detecting 

exposure, such as proximity of a spill to nesting 

beaches, migration corridors, and foraging grounds. 

Study design should consider that nesting 

assemblages include females originating from multiple, 

potentially distant foraging areas.

Bolsters documentation of exposure and potentially 

allows for correlation with any effects. 
74

Pathway and exposure to oil and/or to shoreline response activities (continued)

Tool / metric Feasibility / methods Considerations / applications Prioritization rationale

PAH analysis of 

nesting substrate and 

eggs in oiled areasa



Methods exist for detection of oil

and dispersant-related 

compounds. Baseline data 

generally are lacking for pre-spill 

comparisons.

Study design should consider availability of or 

collection of baseline data, or identify suitable control 

site(s).

Bolsters documentation of exposure and potentially allows for 

correlation with any effects. 

PAH analysis of 

samples from oiled

nesting females (or 

turtles suspected be 

exposed to oil)a



Methods exist for detection of 

PAHs and dispersant-related 

compounds in tissues collected 

from dead turtles. Detection of 

PAHs in blood (from live turtles) 

and other matrices is challenging 

using current methods. Locationspecific baseline data are often not 

available for pre-spill comparisons.

Females of most species nest at night and thus are 

often not encountered. Study design should consider 

availability of or collection of baseline data or identify 

a suitable control group(s). Unknown timing, duration, 

and dosage may complicate interpretation.

It is anticipated that most samples would be blood collected 

from live turtles, which to date has not been very informative 

for demonstrating exposure, but could be improved by more 

sensitive analytical methods. Detection of PAHs is insensitive 

for detecting exposure in some contexts due to rapid 

metabolism. Analysis of samples from any recovered dead 

oiled nesting females may be more useful and merit higher 

priority. 

Effects of oil or response-related activities on nesting, embryos, hatchlings, and adult females

Tool / metric Feasibility / methods Considerations / applications Prioritization rationale

Destruction of nests or 

injury to females



Documented during the course of 

response.

Any injury involving sea turtle nests or turtles should 

be captured under the response reporting structure 

and accounted for under NRDA.

Basic injury metric.

Analysis of the effects 

of shoreline 

disturbance and other 

response activities 



Methods and historical data exist 

for a number of relevant metrics, 

including nesting activity, false 

attempts at nesting, and 

disorientation rates.

The data necessary to undertake these analyses is 

available through USFWS and the relevant 

state/regional nesting authority. The necessary 

response-related data are documented and also 

available. Nesting activity is variable; requires 

consideration of long-term trends and data from index 

locations.

Provides evidence of injury with demonstrated value in prior 

NRDAs.

a

Prioritization is low for non-visibly oiled animals/areas unless serving as controls due to lower likelihood of yielding data useful to NRDA. In addition, PAH analysis may be a greater priority for 

petroleum types that do not necessarily result in readily visible external exposure.
75

Effects of oil or response-related activities on nesting, embryos, hatchlings, and adult females (continued)

Tool / metric Feasibility / methods Considerations / applications Prioritization rationale

Assessment of beachcast strandings, 

including clinical and 

necropsy evaluations



Established methods and 

trained personnel are available.

Significant effort necessary to 

encounter turtles, document 

required information, and 

transport turtles to appropriate 

facilities.

Stranding networks operate at all times, including in 

response to oil spills, so baseline data are available. 

Strandings are influenced by multiple factors and typically 

represent a biased fraction of overall mortality. Probability 

of discovery is dependent on origin (e.g., distance from 

shore) and environmental conditions, and should be 

considered. 

Basic approach to documenting oil exposure and effects. 

Common aspect of spill response activities. Relatively high 

probability of detecting mortality of nesting females and newly 

emerged hatchlings via stranding response if occurs on or 

near shore.

Evaluation of embryos 

and hatchlings in oiled 

areasa



Established methods are 

available for evaluating the 

development and health of 

embryos and hatchlings, 

including embryo mortality, 

hatching success, and 

deformity rates. Clinical and 

behavioral observations also 

may be performed.

Studies examining embryonic effects of oil on chelonians 

have yielded mixed results. Demonstration of exposure 

using analyses of nest substrate, egg tissues, or other 

means should be concurrent with these evaluations.

Some metrics are highly variable – controls must be 

carefully considered. 

These metrics are of greatest interest when there is clear 

evidence of exposure or if nests have been manipulated as 

part of any necessary mitigation or protection.

Health parameters –

nesting females in 

oiled areasa

-

Reference data exist for many 

basic means of clinical 

evaluation, including 

hematology and blood 

chemistry.

Blood parameters are the most accessible means of 

evaluating the health of live turtles, but may be relatively 

insensitive for detecting potential effects of oiling. 

Logistically difficult because most species nest at night and 

interference with nesting females should be as minimal as 

possible. Translation to injury may be challenging depending 

on the availability of corroborative data. May be done if 

opportunity for safe field evaluation and sampling are 

available.

Laboratory toxicity 

studies (eggs)



Published methods exist. 

Protected status requires 

permits or use of surrogate 

species.

Results of previous studies have been mixed. Methods 

require consideration of both oil and exposure 

characteristics (e.g., effects of portioning within 

sediments), as well as chemical and physical effects.

May be most useful (and higher priority) if necessary to 

corroborate observed effects in spill-exposed nests.

a

Prioritization is lower for non-visibly oiled animals and unoiled areas unless serving as controls due to lower likelihood of yielding data useful to NRDA.
76

Effects of oil or response-related activities on nesting, embryos, hatchlings, and adult females (continued)

Tool / metric Feasibility / methods Considerations / applications Prioritization rationale

Analyses of oiling 

effects on nesting 

habitat



Methods and trained personnel 

are available.

Oil can have persistent effects on substrate 

characteristics, including microbial communities 

May be most useful (and higher priority) if necessary to 

corroborate observed effects in spill-exposed nests, if easily 

added to other beach studies, or if pursued in conjunction with 

long-term monitoring.

Biomarkers and other 

sublethal measures in 

turtles / eggs



Assays exist for detecting 

biomarkers (e.g., CYP1A) and 

various other sublethal 

alterations associated with 

exposure to oil-related 

compounds.

There has been limited study in sea turtles relative to 

other species. Study design should strongly consider 

likelihood of Type I and II error, availability of data to 

facilitate interpretation of results, and a specific plan for 

how results will be used for assessment of exposure or 

injury.

Demonstration of exposure and injury attributable to an oil spill 

may be challenging based on current knowledge. May be most 

useful for corroborative purposes.
77

Table 4-2. Oceanic / offshore areas: tools and metrics for sea turtle NRDA assessments. Priority level synthesizes details of all factors to help weigh the relative utility of 

each tool / metric and associated assessment approaches for constructing sea turtle injury assessments under NRDA. Priority levels are indicated as “high”=, 

“medium”=, and “low”=. This table is not intended to be an exhaustive list. Depending on the circumstances of the spill and the evolution of scientific 

understanding, other assessment activities could provide useful data for NRDA.

Pathway and exposure to oil and/or response activities – oceanic/offshore

Tool / metric Feasibility / methods Considerations / applications Prioritization rationale

Vessel surveys for 

oceanic juveniles 



Potential for dense concentrations of 

turtles in oiled areas, depending on 

time of year. Readily observed from 

vessels; may be targeted for rescue.

Requires early deployment; can be limited by sea 

state, weather, and human safety concerns. Aerial 

support can be extremely helpful, but challenging to 

coordinate. Identifying and contracting aircraft and 

vessels takes time to coordinate. Metrics can be 

translated to injury quantification. Use of line-transect 

methods also may be used for statistical analysis to 

estimate abundance within the affected area.

Provides documentation of both exposure and injury, 

including that resulting from response operations (e.g., 

controlled burns).

Aerial surveys for turtles 

>45 cm



Established methods and trained 

personnel are available.

Only turtles >45 cm are reliably visible from aircraft

used in most manned aerial surveys; use of alternative 

methods (e.g., unmanned aerial vehicles (UAVs)) or 

extrapolation required for smaller animals; improved by 

species/region-specific sightability parameters (e.g., 

time at surface). Used for statistical analysis to 

estimate abundance within the affected area.

Provides basic documentation of exposure for turtles that 

cannot be efficiently sighted (or captured) by vessels 

within spill areas. Important for larger spills where aerial 

surveys are the most practical means of surveying large 

areas.

Remote sensing 

products for oil 

detection (e.g., 

synthetic aperture 

radar)



Established methods exist for using 

satellite imagery to granularly 

represent the temporospatial 

distribution of oil.

Can be combined with field data to understand the 

scale of oil exposure and potential effects. The 

resolution of data products and comparability with field 

observations (e.g., oil thickness) must be carefully 

considered.

Important for large spills where direct sampling and 

observations are likely incomplete.

Spatial analysis of 

overlap between oiling 

and response activities 

and turtle abundance



Published methods available. Field observations can be used to inform and groundtruth analysis.Relevant to both exposure and injury (see below).
78

Pathway and exposure to oil and/or response activities – oceanic/offshore (continued)

Tool / metric Feasibility / methods Considerations / applications Prioritization rationale

PAH analysis of 

samples from oiled

turtles (or turtles 

suspected be 

exposed to oil)a



Methods exist for detection of PAHs 

and dispersant-related compounds in 

tissues collected from dead turtles. 

Detection of PAHs in blood (from live 

turtles) and other matrices is 

challenging using current methods. 

Location-specific baseline data are 

often not available for pre-spill 

comparisons.

Study design should consider availability or collection

of baseline data, or identify suitable control site(s).

Unknown timing, duration, and dosage may complicate 

interpretation.

Could yield exposure data to be correlated with effects or 

useful for comparative toxicology and other purposes. 

Detection of PAHs is insensitive for detecting exposure in 

some contexts due to rapid metabolism and current 

methods. Analysis of samples from any recovered dead 

turtles may be most useful and merit higher priority due to 

difficulty associated with detecting PAHs in blood from live 

turtles.

Effects of oil or response-related activities – oceanic/offshore

Tool / metric Feasibility / methods Considerations / applications Prioritization rationale

Spatial analysis of 

overlap between 

oiling and response 

activities and turtle 

abundance



Published methods available. Field observations can be used to inform and groundtruth analysis. Evidence of injury is often most robust 

for heavily oiled turtles; lesser exposure scenarios may

rely on risk assessment approach and comparative

toxicity data. Can bridge documentation to injury 

quantification.

Applies field-based observations and established methods 

to yield estimates of injury.

Health parameters –

oceanic juveniles 

(including clinical 

evaluations and 

necropsies)a



Applies standard means of veterinary 

evaluation; reference data exist for 

many basic means of clinical 

evaluation, including hematology and 

blood chemistry.

Many anticipated immediate effects are physiological 

and may be affected by capture and transport - field 

evaluations immediately upon capture should be 

considered, if feasible. Dose and duration of exposure 

are unknown, which may complicate interpretation of 

some parameters. There are a number of parameters 

that can be measured using current technology, but 

interpretability in the context of injury assessment 

should be carefully considered.

Useful for characterizing effects of oil exposure; includes 

information that is routinely collected during the care and 

treatment of oiled turtles.

a

Prioritization is lower for non-visibly oiled animals and unoiled areas unless serving as controls due to lower likelihood of yielding data useful to NRDA. In addition, PAH analysis may be a greater 

priority for petroleum types that do not necessarily result in readily visible external oiling.
79

Effects of oil or response-related activities – oceanic/offshore (continued)

Tool / metric Feasibility / methods Considerations / applications Prioritization rationale

Assessment of beach-cast 

strandings, including clinical and 

necropsy evaluations

-

Established methods and 

trained personnel are 

available. Significant effort 

necessary to encounter 

turtles, document required 

information, and transport 

turtles to appropriate 

facilities.

Stranding networks operate at all times, including in 

response to oil spills, so baseline data are available. 

Strandings are influenced by multiple factors and 

typically represent a biased fraction of overall mortality. 

Probability of discovery is dependent on location of 

origin and environmental conditions, and should be 

considered. 

Basic approach to documenting oil exposure and effects. 

Common aspect of spill response activities. The priority 

level reflects a relatively low probability of detecting 

animals that become debilitated or die in offshore areas, 

but some detection may be possible.

Analyses of oiling effects on 

turtle prey and habitats (e.g., 

Sargassum)



Methods and trained 

personnel are available, but 

analytical approaches need 

additional development.

May combine remotely obtained (by satellite, digital 

imagery) measurements and direct observations for 

ground-truthing, as well as information about turtle 

densities and movements. Other case teams may have 

access to samples or information pertinent to prey 

species.

Provides information about continued exposure of sea 

turtles to oil, and potential injury through loss of food 

sources and habitat. The designated priority reflects 

limited precedence for use in prior NRDAs.

Laboratory toxicity studies

 - 

Protected status (often 

requiring use of surrogate 

species); feasible duration of 

exposure often limited by 

logistics / expense.

Study design should include clear consideration of life 

phase / species comparability. Inclusion of sublethal 

effects should include a specific plan for how these 

data will be used in a NRDA context. Potential longterm effects (months, years) of exposure on sea turtles 

are poorly understood at present and logistically 

difficult to study.

Lower prioritization largely reflects logistical constraints 

and uncertain outcome based on previous studies. May 

be more necessary for spills involving compounds that 

have not been studied or to investigate specific effects of 

significant interest to a given NRDA (e.g., an effect 

observed in another taxon).

Health parameters – large 

juveniles and adults in oceanic 

zonea



As for oceanic juveniles, 

established methods exist. 

Evaluation of live turtles, unless debilitated, is likely to 

be extremely difficult due to the dispersed distribution 

of these life stages and human safety concerns 

associated with capture of large turtles in a spill area. 

Examinations of debilitated turtles and necropsies can 

be valuable, and should be pursued whenever possible 

Priority reflects the difficulties of working with live, larger 

turtles in the oceanic environment and the small numbers 

of animals that are likely to be encountered.

a

Prioritization is lower for non-visibly oiled animals and unoiled areas unless serving as controls due to lower likelihood of yielding data useful to NRDA.
80

Effects of oil or response-related activities – oceanic/offshore (continued)

Tool / metric Feasibility / methods Considerations / applications Prioritization rationale

Biomarkers and other sublethal 

measures in turtle tissues



Assays exist for detecting 

biomarkers (e.g., CYP1A) 

and various other sublethal 

alterations associated with 

exposure to oil-related 

compounds.

There has been limited study in sea turtles relative to 

other species. Study design should strongly consider 

likelihood of Type I and II error, availability of data to 

facilitate interpretation of results, and a specific plan for 

how results will be used for assessment of exposure or 

injury.

Demonstration of exposure and injury attributable to an 

oil spill may be challenging based on current knowledge.
81

Table 4-3. Continental shelf / inshore (neritic) areas: tools and metrics for sea turtle NRDA assessments. Priority level synthesizes details of all factors to help weigh the

relative utility of each tool / metric and associated assessment approaches for constructing sea turtle injury assessments under NRDA. Priority levels are indicated as 

“high”=, “medium”=, and “low”=. This table is not intended to be an exhaustive list. Depending on the circumstances of the spill and the evolution of 

scientific understanding, other assessment activities could provide useful data for NRDA.

Pathway and exposure to oil and/or response activities - neritic

Tool / metric Feasibility / methods Considerations / applications Prioritization rationale

Aerial surveys large (>45 

cm) neritic life stages



Established methods and trained 

personnel are available.

Only turtles >45 cm are reliably visible from aircraft

used in most manned aerial surveys; use of alternative 

methods (e.g., unmanned aerial vehicles (UAVs)) or 

extrapolation required for smaller animals; improved by 

species/region-specific sightability parameters (e.g., 

time at surface). Used for statistical analysis to 

estimate abundance within the affected area.

Provides basic documentation of exposure for turtles that 

cannot be efficiently sighted (or captured) by vessels 

within spill areas. Especially important for larger spills 

where aerial surveys are the most practical means of 

surveying large areas.

Spatial analysis of overlap 

between oiling and 

response activities and 

turtle abundance



Published methods available.

Baseline information (e.g., 

telemetry data) available for some 

areas.

Field observations can be used to inform and groundtruth analysis.Relevant to both exposure and injury.

Vessel surveys for neritic 

life stages

 - 

Dependent upon location and 

conditions; rescue / capture may 

not be feasible due to human 

safety concerns.

Requires early deployment and potentially aerial 

support to locate turtles and oil; can be limited by sea 

state, weather, clean-up operations restrictions, and 

human safety concerns. Identifying and contracting 

vessels (and aircraft if needed) takes time to 

coordinate. Metrics can be translated to injury 

quantification and restoration. 

Sea turtles sightings can be useful for ground-truthing 

remote sensing and aerial survey data, specifically 

documentation of exposure and environmental conditions 

in fine spatial scales and in greater detail. Regarding 

potential capture of turtles, logistical challenges are 

significant, successful rescues and evaluations unlikely to 

be numerous, but information that could be collected is 

very valuable (e.g., recovery of dead or debilitated oiled 

turtles for examination).

Satellite telemetry tracking 



Technology is readily available for 

tracking animal movements, 

including within an oil spill area.

Study design should consider likelihood of detecting 

exposure, such as proximity of a spill to nesting 

beaches, migration corridors, and foraging grounds.

Bolsters documentation of exposure and potentially 

allows for correlation with any effects. Has been 

combined with stable isotope analysis to study foraging 

locations before and after a spill.
82

Pathway and exposure to oil and/or response activities - neritic (continued)

Tool / metric Feasibility / methods Considerations / applications Prioritization rationale

PAH analysis of samples 

from oiled turtles (or turtles 

suspected to be exposed to 

oil)a



Methods exist for detection of PAHs 

and dispersant-related compounds 

in tissues collected from dead 

turtles. Detection of PAHs in blood 

(from live turtles) and other matrices 

is challenging using current 

methods. Location-specific baseline 

data are often not available for prespill comparisons.

Study design should consider availability or collection 

of baseline data, or identify suitable control site(s). 

Unknown timing, duration, and dosage may complicate 

interpretation. 

Could yield exposure data to be correlated with effects 

or useful for comparative toxicology and other 

purposes. Detection of PAHs is insensitive for 

detecting exposure in some contexts due to rapid 

metabolism and current methods. Analysis of samples 

from any recovered dead turtles may be most useful 

and merit higher priority due to difficulty associated 

with detecting PAHs in blood from live turtles.

Effects of oil or response-related activities - neritic

Tool / metric Feasibility / methods Considerations / applications Prioritization rationale

Assessment of beach-cast 

strandings, including clinical 

and necropsy evaluations



Established methods and trained 

personnel are available. Significant 

effort necessary to encounter turtles, 

document required information, and 

transport carcasses to appropriate 

facilities.

Stranding networks operate at all times, including in 

response to oil spills, so baseline data are available. 

Strandings are influenced by multiple factors and 

typically represent a biased fraction of overall 

mortality. Probability of discovery is dependent on 

location of origin, shoreline features, and 

environmental conditions, and should be considered. 

Metrics can be used for injury quantification. 

Basic approach to documenting oil exposure and 

effects. Common aspect of spill response activities. 

Probability of detection greatest for sea turtles that die 

or suffer debilitating effects (or are injured by response 

activities) if closer to shore.

Health parameters – oiled 

neritic life stages (includes 

clinical evaluations of live 

turtles and necropsy)a



Applies standard means of veterinary 

evaluation; reference data exist for 

many basic means of clinical 

evaluation, including hematology and 

blood chemistry.

Many anticipated immediate effects are physiological 

and may be affected by capture and transport - field 

evaluations immediately upon discovery / capture 

should be considered if feasible. Dose and duration of 

exposure are likely unknown, which may complicate 

interpretation of some parameters. There are a 

number of parameters that can be measured using 

current technology, but interpretability in the context 

of injury assessment should be carefully considered.

Important for characterizing effects of oil exposure; 

includes information that is routinely collected during 

the care and treatment of oiled turtles.

a

Prioritization is lower for non-visibly oiled animals and unoiled areas unless serving as controls due to lower likelihood of yielding data useful to NRDA. In addition, PAH analysis may be a greater 

priority for petroleum types that do not necessarily result in readily visible external oiling.
83

Effects of oil or response-related activities - neritic (continued)

Tool / metric Feasibility / methods Considerations / applications Prioritization rationale

Analyses of oiling effects on turtle 

prey and habitats



Methods and trained 

personnel are available, but 

analytical approaches need 

improvement, and requires 

significant sampling effort.

May use a combination of in situ measurements of 

oiling in habitats and prey tissues. Correlative data on 

habitat/prey use by sea turtles is helpful. Possible

applications for injury quantification.

May provide information about potential injury to neritic 

sea turtles and other organisms that rely on continental 

shelf and nearshore area. The designated priority reflects 

some uncertainty regarding translation to sea turtle injury 

during previous NRDAs.

Laboratory toxicity studies

 - 

Protected status (requiring 

use of surrogate species); 

feasible duration of 

exposure often limited by 

logistics / expense.

Study design should include clear consideration of life 

phase / species comparability. Inclusion of sublethal 

effects should include a specific plan for how these 

data will be used in a NRDA context. Potential longterm effects (months, years) of exposure on sea turtles 

are poorly understood at present and logistically 

difficult to study.

Lower prioritization largely reflects logistical constraints 

and uncertain outcome based on previous studies. May 

be more necessary for spills involving compounds that 

have not been studied or to investigate specific effects of 

significant interest to a given NRDA (e.g., an effect 

observed in another taxon).

Biomarkers and other sublethal 

measures in turtle tissues



Assays exist for detecting 

biomarkers (e.g., CYP1A) 

and various other sublethal 

alterations associated with 

exposure to oil-related 

compounds.

There has been limited study in sea turtles relative to 

other species. Study design should strongly consider 

likelihood of Type I and II error, availability of data to 

facilitate interpretation of results, and a specific plan for 

how results will be used for assessment of exposure or 

injury.

Demonstration of exposure and injury attributable to an 

oil spill may be challenging based on current knowledge.
84

4.3.3. Summary of NRDA tools and approaches for sea turtles 

According to evaluation of factors presented in Tables 4-1 to 4-3, the highest priority data to collect 

for NRDA include documentation of the co-occurrence of turtles and oil (including density and 

abundance of animals), the degree and nature to which turtles are exposed to oil, and mortality of 

turtles (and lost reproduction) caused by oil exposure and response activities. These data types are: 1) 

the most feasible to collect because they rely heavily on visual observations, most of which can take 

place during response operations; 2) very applicable to a sea turtle NRDA because they provide the 

foundation for exposure and injury determination (i.e., numbers of turtles exposed to oil to varying 

degrees and the consequences of those exposures) and for injury quantification (i.e., numbers of lost

turtles); and 3) associated with relatively few technical challenges.

Based on the state of the science at the writing of these guidelines, types of data that have been less 

fruitful for sea turtle NRDA include studies of toxicological and other sublethal effects of oil, particularly 

for turtles without clear evidence of oil exposure. As discussed briefly above, toxicological effects of oil 

exposure have not been demonstrated in sea turtles as clearly as physical effects. Previous attempts to 

measure toxicological effects of oil exposure in turtles have generated inconclusive evidence with regard 

to acute mortality or compromised survival within study intervals. Also, understanding biomarker assays 

in sea turtles is still in its early stages, and translating results of these methods and other sublethal

endpoints to injury is challenging in a NRDA context. In addition to these considerations, sublethal

toxicological and physiological effects of oil exposure in free-ranging turtles are difficult to study and 

track over potentially long periods following initial exposure. Although long-term effects of oil exposure 

(e.g., effects on growth rates, reproduction, immune function) are difficult to measure, they nonetheless 

could be significant. Applied research on potential assessment tools related to longer-term effects and 

toxicity could be especially valuable for future NRDAs.

The importance of the effects of oil spills and response activities on sea turtle habitat and prey is 

mentioned in these guidelines, but an in-depth review is beyond the scope of this document. Habitat 

and prey are important for defining exposure and demonstrating injury. Effects from spills can be both 

extensive and persistent (e.g., alteration of beach substrates, destruction of seagrass beds and other 

habitat). Researchers and NRDA practitioners focused on impacts and restoration of these specific 

resources should be engaged in order to inform and improve assessment of sea turtle injury.

4.4. Nexus between injury and restoration 

Natural resource Trustees must develop a Restoration Plan for restoring the injured resources and 

services (NOAA-DARP 1996). Although restoration actions follow the injury assessment in conceptual

sequence, it is important that injury assessment includes consideration of restoration techniques in 

planning injury assessment approaches as there are logical and practical connections to be made early in 

the NRDA process. The OPA requires that Trustees identify and implement actions that restore, 

rehabilitate, replace, or acquire natural resources and services equivalent to those injured by oil spills to 
85

the baseline condition of those resources if the incident had not occurred (33 USC § 2706(c) and the 

OPA NRDA regulations 15 CFR Part 990). Simply put, there are two main goals of restoration activities: 1) 

return injured natural resources and services to their baseline condition (primary restoration) and 2)

compensate for interim losses from the time of the incident until the resources and services recover to 

baseline conditions (compensatory restoration) (15 CFR § 990.10). 

To meet these goals, restoration activities must produce benefits that are related to, or have a 

nexus (connection) with, sea turtle injuries and service losses resulting from the spill. To meet the NRDA 

regulations, Trustees must consider a reasonable range of restoration alternatives, evaluate and select 

the preferred alternative(s), and develop the draft and final Restoration Plan(s) with opportunity for 

public review and comment (DWH NRDA Trustees 2016). To ensure that restoration actions adequately 

address the injuries caused by an incident, the benefits of the actions should be scaled in the same 

metrics as those used in injury quantification. Ideally, restoration actions will directly restore the 

species, life stages, and geographies that were lost. For example, if adult loggerhead sea turtles were 

lost, then restoration actions should be developed to specifically restore adult loggerhead sea turtles of 

the affected management unit(s), not an earlier life stage. However, in some cases restoration actions 

might be infeasible for some life stages or geographies, thus Trustees must develop restoration options 

that restore a different life stage(s) or management unit than was injured by a spill. In such instances, it

may be necessary to identify a common metric to compare the resources lost with those that will 

benefit from a restoration action. 

Consideration of injury metrics is key for robust injury quantification, as well as for enabling the 

appropriate calculation of quantifiable benefits to resources from restoration actions. In other words, 

how the injury quantification is conducted and calculated can influence the development of restoration 

alternatives in final restoration plans. With that in mind, the remainder of this section presents 

considerations for coordination of injury assessment and restoration planning, possible sea turtle injury 

metrics, and types and geographies of potential restoration approaches to restore sea turtle injuries.

4.4.1. Coordination between injury and restoration planning

Conceptually, restoration planning follows injury quantification because Trustees must understand 

the nature and extent of injuries before developing approaches to restore them. However, in actuality, 

coordination between restoration planning and injury assessment should be initiated during the 

Restoration Planning Phase. Once preliminary information about the nature, extent, and magnitude of 

the injuries becomes available, the NRDA practitioners may begin to explore potential restoration 

options. For example, if a spill occurs in a relatively small area close to sea turtle nesting beaches, and 

injuries appear to be limited to breeding turtles, eggs, or hatchlings, restoration planning can focus on 

investigating existing restoration approaches and feasibility in or near the affected area that could 

directly address beach-based injuries to sea turtles. In contrast, if a spill occurs far from shore, and 

would likely affect oceanic juveniles that are difficult to directly restore, restoration planning can 

explore restoration options to feasibly and effectively restore a different life stage, ideally an older life 

stage that has already survived beyond the one lost, and how to convert those restored resources to the 

type actually injured. 
86

The types of injury metrics that are produced by an assessment study are an important 

consideration because they are pertinent to restoration planning. As injury quantification is refined, 

coordination among personnel engaged in assessment and restoration planning should become more 

frequent to ensure effective, calculable restoration of injuries caused by an incident. To the extent 

possible, personnel involved with injury assessment should regularly participate in restoration planning, 

and vice versa, to promote efficient communication and translation between the two aspects of a sea 

turtle NRDA. In particular, restoration planners should understand injury metrics and how to apply them 

to potential restoration actions. In the following subsections, possible injury metrics that were 

presented in previous sections are discussed in the context of restoration planning. 

4.4.2. Injury and restoration metrics

Mortality and sublethal effects

The most straightforward metric is mortality (dead animals) such that any activity or study that 

documents injury in terms of number of dead animals requires little to no conversion during injury 

quantification or restoration scaling, i.e., X number of sea turtles lost requires X number or its equivalent 

to be restored. The only conversions necessary are for some specific applications (e.g., the proportion of 

hatchlings estimated to reach maturity). In addition to loss of eggs on impacted beaches and mortality 

of other life stages, offspring that are not produced due to shoreline disturbance or are otherwise lost to 

the management unit (e.g., due to required translocation out of the region) are essentially treated as 

mortality. 

Sublethal effects may contribute to injury resulting from an oil spill, but quantification in a manner 

that is applicable for restoration is more challenging than for mortality. For example, if an animal 

exposed to oil or a response action suffers some reduction in a physiological parameter, growth rate, 

energetic cost, or other potentially injurious effect, a means of restoration will be needed for this 

information to be used under NRDA. The eventual need for such application should be considered 

during study planning and design. 

Production forgone and reproductive values

Production foregone as a result of mortalities of individual female sea turtles is an injury metric that 

could be used to quantify additional sea turtle losses. This metric is an estimate of the number of 

offspring lost over some future time period (e.g., one generation) due to the loss of individual female 

sea turtles. Recognizing that there are unique life history traits for sea turtles, the potential reproductive 

contribution of an individual female of a given age (or life stage) is calculated using population matrix 

models (see, e.g., Crouse et al. 1987; Crowder et al. 1994; Heppell 1998). The process factors in 1) the 

approximate age(s) / life stage(s) of animals determined to have died as a result of the spill (determined 

under mortalities, discussed above); 2) annual survivorship; 3) age at maturity; 4) fecundity; and 5) 

reproductive lifespan. Empirical data for this suite of parameters may be unavailable and the use of 

estimates or expert opinion may be necessary. If empirical or derived, robust values from other sea 

turtle populations that generally share similar life history characteristics are available, they may be used 

as proxy values. In general, reproduction increases with age and peaks with onset of maturity. Thus, 
87

large juvenile and adult sea turtles are expected to contribute more hatchlings to the population than

small juveniles due to their lower survivorship. Another consideration for using production forgone is 

the duration of the future period over which these losses should be calculated. For purposes of discrete 

injury quantification and restoration scaling, Trustees must select a defined temporal window to 

estimate the magnitude of production forgone.

This approach has been used in NRDA cases since 1999 for a number of species, including birds, fish, 

mussels, and other turtles. It enables the Trustees to both quantify the production foregone from 

individual female mortalities and to scale restoration projects across life stages, if needed. Scaling 

injuries across life stages can be useful in informing development of balanced restoration alternatives by 

ensuring that the types and relative scale of restoration projects reflect the allocation of quantified 

injuries across life stages. However, uncertainties in important data inputs, especially stage-specific 

survival rates, can significantly influence this analysis; therefore, Trustees should exercise caution and 

explicitly incorporate uncertainty when scaling injury to restoration. 

Ecosystem services 

In addition to restoring for direct losses of sea turtles, the Trustees may consider restoring services 

that sea turtles provide to ecosystems. As highly mobile, large-bodied animals that occupy different 

marine habitats during their decades-long lives, sea turtles play unique and important roles in marine 

ecosystems. Sea turtles transport nutrients from ocean to land through deposition of eggs, thereby 

transferring nutrients derived from marine sources into sand beaches (Bouchard and Bjorndal 2000). Sea 

turtles also serve important roles in food webs as specialized consumers of gelatinous zooplankton 

(leatherbacks), sponges on coral reefs (hawksbills), and seagrass and other aquatic vegetation (green 

turtles), and as prey resources for many predators and scavengers (Heithaus 2013). In addition, as a 

result of an oil spill, there may be lost recreational services from the inability of humans to view sea 

turtles, whether through formal ecotourism or informal enjoyment of nature. In nearly every country in 

the world where sea turtles are present, particularly where they nest, people make efforts to observe 

sea turtles in the wild. Although the services provided by sea turtles are not necessarily easy to quantify, 

they are important to take into account when developing and scaling restoration alternatives. 

4.4.3. Possible types of restoration for sea turtles

Restoration actions to address losses of sea turtles caused by an oil spill are essentially 

compensatory in nature; restoration projects address sea turtle injuries by increasing survivorship or 

decreasing mortality due to threats. As discussed in Section 1, threats to sea turtles vary in type and 

magnitude based on geography, behavior, and density of turtles in a given place at a given time, and life 

stages affected. A first step in developing possible restoration options for sea turtles should be to gather 

and analyze existing information about threats to the management unit and species of sea turtles 

affected by the spill. Much of this information can be found in ESA recovery plans, status reviews, and 

current biological synopses (Appendix 1). Discussed below are several types of restoration techniques 

that may be considered by the Trustees in identifying restoration options for sea turtles. This subsection
88

is intended to provide some examples, but is not intended to be an exhaustive review of all possible 

restoration actions that could benefit sea turtles.

Bycatch of sea turtles in commercial and recreational fishing gear is widely recognized as a primary 

threat to sea turtles in marine areas across regions, species, and life stages; therefore, bycatch reduction 

can be a viable restoration approach for sea turtles. It is important to note that restoration funds cannot 

be used to pay for things that are already mandated by federal law (e.g., purchase of federally-required 

turtle excluder devices [TEDs] and federal law enforcement). However, there are a number of possible 

restoration options to reduce bycatch mortality, including voluntary changes to fishing gear and/or 

practices; support for bycatch reduction training, monitoring, and state law enforcement. Other 

anthropogenic threats, such as vessel strikes and habitat loss through pollution, development, and other 

forms of environmental degradation also may be considered.

Threats to sea turtles on land (i.e., those that affect nesting females, eggs, hatchlings, or basking 

turtles) include coastal development (e.g., coastal armoring, artificial lighting, and beach nourishment), 

recreational activities (e.g., beach driving, beach furniture, increased human presence), and predation of 

eggs and hatchlings. (Bolten et al 2011). Possible restoration options could include protection of nesting 

beach habitats through acquisition and preservation; implementation of management measures to 

reduce impact of artificial lighting, recreational activities, and barriers to nesting (e.g., sea walls, beach 

furniture); enhanced patrolling to minimize threats to nesting turtles, their eggs, and hatchlings; and 

ecologically sound predation control programs.

In all cases, restoration options must be screened using OPA criteria, which includes identification of 

nexuses to injury and compliance with other applicable laws. In the case of sea turtles, federal ESA 

recovery plans should be consulted and used as guiding documents to help identify restoration activities 

that reduce primary threats and associated mortality. Restoration plans are developed to describe the 

restoration options considered, accounting for variation in species and life stages injured, geographic 

areas where injures occurred, and where restoration projects might take place. Restoration plans also 

evaluate the logistical, technical, legal, and financial feasibility of approaches, techniques, and projects.

4.5. Data management in NRDA

Data management is perhaps one of the most key pieces of any NRDA. As the initial flurry of 

information is becoming organized during the first few days of an incident, responders can be narrowly 

focused on their own data collection and reporting needs. The RP may be unfamiliar with current federal 

data expectations and the process of data sharing may be a challenge. A Data Sharing Plan may be 

developed during response that outlines the data agreements and goals of RP, federal, and state 

partners. Data managers typically sit under the Planning Section or NRDA and oversee the myriad data 

collected, working to ensure that both response and trustee needs are met. It is important that they also 

work with the Scientific Support Coordinator or NRDA lead(s) to discuss other data management staffing 

and funding needs to ensure that the appropriate level of oversight can be accomplished.
89

Data sharing among Trustees, various governmental and non-governmental experts, researchers, 

and others often is often necessary to develop the NRDA. Each agency has their own approaches and 

infrastructure related to data management for NRDA. For example, NOAA’s Office of Response and 

Restoration has data management specialists trained in both response and NRDA. These roles have 

become standard when NOAA participates in spill exercises and incidents to ensure that cooperatively 

collected data are accounted for, shared among all responders, managed appropriately, and archived 

according to federal requirements. Some examples of web-based resources available to NRDA 

practitioners for data management, sharing, and visualization include: 

 DIVER (Data Integration Visualization Exploration and Reporting) – a platform for the 

management, querying, and archiving of NOAA-NRDA data such as contaminant chemistry, 

field observations, and biological data.

 ERMA (Environmental Response Management Application) - a system that provides data 

visualization and common operational picture for the NRDA. NOAA-Emergency Response 

Division, NOAA’s Office of Homeland Security, and U.S. Coast Guard also use ERMA for 

visualizing response data and making operational decisions. There are 8 regional ERMAs 

across the country and each contains the same base datasets that are important early in an 

incident, such as environmental sensitivity atlases, critical habitat, weather and ocean 

observations, environmental chemistry, and satellite imagery. 

 DARTS (Damage Assessment and Restoration Tracking System) – DOI interactive website 

used for tracking NRDA cases that includes an interactive map, and comprehensive catalog 

of case documents.

Trustee agencies and their data managers should discuss the types of data needed to address the 

components of the injury conceptual model (Figure 4-1), and what metrics could be used to determine 

when collected samples are adequate for case needs. These goals should be determined and 

communicated clearly by case management (legal and technical) in collaboration with the TWGs. For 

studies conducted by NRDA, data managers may be more directly engaged with field personnel and will 

provide specific instructions for data reporting and entry. Efficient data intake is essential to making the 

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Appendix 1: Important web-based resources

The resources below can be found on NOAA’s Office of Response and Restoration Field 

Assessment and Support Techniques (FAST) web site:

https://www.diver.orr.noaa.gov/web/guest/field-forms-and-templates

 Notification trees and current contact information in the event of an oil spill

 Rehabilitation facilities by region and state

 Nest monitoring programs by region and state

 Editable, current drafts of spill response protocols and data forms

 Evidence handling protocols and best practices

 NOAA standard aerial survey shape files

Species information, including recovery plans, biological synopses, and species status reviews

can be found at the NOAA, NMFS, Office of Protected Resources website at: 

https://www.fisheries.noaa.gov/sea-turtles

Appendices
98

Appendix 2: Maps of species distributions, nesting locations, and basking 

locations for sea turtle populations found in the U.S. and its territorial 

waters.

Species distributions

Maps A2-1 through A2-6 are intended to show the distributions occupied by sea turtle populations of 

each species that occur within U.S. territories and Exclusive Economic Zone (EEZ) (based on Wallace et 

al. 2010; available via The State of the World’s Sea Turtles (SWOT; Kot et al. 2015). Note that some sea 

turtle populations that nest in other countries regularly occur within the U.S. EEZ. 

For more details about presence and relative abundance of different life stages by species within all U.S. 

regions, see Appendix 3.
99

Figure A2-1. Distribution of green turtle (Chelonia mydas) populations relative to the U.S., its territories, and EEZ (black 

lines). Data source: The State of the World's Sea Turtles Online Database (SWOT), hosted on OBIS-SEAMAP (Kot et 

al. 2015).
100

Figure A2-2. Distribution of loggerhead turtle (Caretta caretta) populations relative to the U.S., its territories, and EEZ 

(black lines). Data source: The State of the World's Sea Turtles Online Database (SWOT), hosted on OBIS-SEAMAP (Kot 

et al. 2015).
101

Figure A2-3. Distribution of hawksbill turtle (Eretmochelys imbricata) populations relative to the U.S., its territories, and EEZ 

(black lines). Data source: The State of the World's Sea Turtles Online Database (SWOT), hosted on OBIS-SEAMAP (Kot et 

al. 2015).
102

Figure A2-4. Distribution of Kemp’s ridley turtle (Lepidochelys kempii) populations relative to the U.S., its territories, and 

EEZ (black lines). Data source: The State of the World's Sea Turtles Online Database (SWOT), hosted on OBIS-SEAMAP 

(Kot et al. 2015).

Figure A2-4. Distribution of Kemp’s ridley turtle (Lepidochelys kempii) populations relative to the U.S. and its territories
103

Figure A2-6. Distribution of leatherback turtle (Dermochelys coriacea) populations relative 

to the U.S., its territories, and EEZ (black lines).

Figure A2-5. Distribution of olive ridley turtle (Lepidochelys olivacea) populations relative to the U.S., its territories, and EEZ 

(black lines). Data source: The State of the World's Sea Turtles Online Database (SWOT), hosted on OBIS-SEAMAP (Kot et 

al. 2015).
104

Figure A2-6. Distribution of leatherback turtle (Dermochelys coriacea) populations relative to the U.S., its territories, and 

EEZ (black lines). Data source: The State of the World's Sea Turtles Online Database (SWOT), hosted on OBIS-SEAMAP 

(Kot et al. 2015).
105

Nesting locations and densities

Maps A2-7 through A2-13 show the locations and relative numbers of nests in U.S. and its territories.

These maps are intended to help spill response and NRDA personnel understand where nesting occurs 

and the relative magnitude of nests that could be affected by a spill in different areas. These maps do 

not reflect relative importance as even small numbers of nests can be important with regard to 

sustainability and recovery of genetic subpopulations. In addition, many important nesting sites occur 

outside of the U.S. and its territories. These locations are not shown on these maps and can be impacted 

by oil spills originating in U.S. territorial waters. Regional-specific information should be sought during 

the development of Area Contingency Plans. Information regarding nesting locations within and outside 

of the U.S. was accessed through The State of the World’s Sea Turtles (SWOT) database (Kot et al. 

[2015]; http://seamap.env.duke.edu/swot) and the Florida Fish and Wildlife Conservation Commission’s

Statewide Atlas of Sea Turtle Nesting Occurrence and Density; http://myfwc.com/research/wildlife/seaturtles/nesting/nesting-atlas/.

Figure A2-7. Locations and relative density of expected green turtle (Chelonia mydas) nesting in the U.S. and territories of 

the Atlantic, Gulf of Mexico, and Caribbean regions. Within the S.E. U.S., more than 95% of nesting occurs on the Atlantic 

coast of Florida, exceeding 30,000 nests during recent peak years.
106

Figure A2-8. Locations and relative density of expected green turtle (Chelonia mydas) nesting in the U.S. and territories of 

the Pacific region. American Samoa also hosts low levels of green turtle nesting, but the sites are covered by the U.S. 

Marshall Islands inset map. Note that other locations that have sporadic nesting are not shown.
107

Figure A2-9. Locations and relative density of expected loggerhead turtle (Caretta caretta) nesting in the U.S. and territories of the 

Atlantic and Gulf of Mexico. More than 80% of loggerhead nesting occurs on the Atlantic coast of Florida, exceeding 80,000 nests 

during recent peak years. Other locations that have sporadic nesting are not shown. 
108

Figure A2-10. Locations and relative density of expected hawksbill turtles (Eretmochelys imbricata) nesting in the U.S. and 

territories of the Gulf of Mexico and Caribbean regions.
109

Figure A2-11. Locations and relative density of expected hawksbill turtle (Eretmochelys imbricata) nesting in the U.S. and 

territories of the Pacific region. Note that other locations that have sporadic nesting (e.g., Guam, American Samoa, 

Commonwealth of Northern Mariana Islands) are not shown.
110

Figure A2-12. Locations and relative density of expected Kemp’s ridley turtle (Lepidochelys kempii) nesting in the Gulf of 

Mexico region. Note that other locations that have sporadic nesting are not shown. More than 98% of all Kemp’s ridley nesting 

occurs in neighboring Mexico.
111

Figure A2-13. Locations and relative density of expected leatherback turtle (Dermochelys coriacea) nesting in the U.S. and 

territories of the Atlantic, Gulf of Mexico, and Caribbean regions. Note that other locations that have sporadic nesting are not 

shown.
112

Basking locations

Maps A2-14 through A2-17 show the locations of green turtle basking areas in the Hawaiian Islands and 

numbers of turtles that may be encountered at these locations. Maps were provided by Todd Jones and 

Shawn Murakawa.

Figure A2-14. Locations and relative density of expected green turtle basking 

on Hawai’i.
113

Figure A2-14. Locations and relative density of expected green turtle basking on Maui, Moloka’I, 

Lana’I, and Kaho’olawe.

Figure A2-15. Locations and relative density of expected green turtle basking on O’ahu.
114

Figure A2-16. Locations and relative density of expected green turtle basking on northwestern 

Hawaiian islands.

Figure A2-17. Locations and relative density of expected green turtle basking on Kaua’i.
115

Appendix 3: Temporal presence of different life stages (adults, juveniles, hatchlings) for each species in each 

U.S. region.

Blue shading indicates in-water presence, pink shading indicates the additional presence of breeding and nesting turtles. Darker colors indicate periods of higher concentrations of 

turtles, lighter shading reflects anticipated lower concentrations, and "NP" indicates absence. Species that are present in U.S. territorial waters but do not nest in U.S. territories 

belong to breeding populations whose nesting sites are outside of the U.S. (e.g., hawksbills and leatherbacks in the northern Gulf of Mexico nest in the Wider Caribbean region, 

leatherbacks present in the East Pacific nest in Indonesia, olive ridleys present in the Pacific nest in Mexico and Central America).

Region Species Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec

NW Atlantic

(New York 

to Maine)

Kemp’s ridleys Juveniles Juveniles Juveniles Juveniles Juveniles Juveniles Juveniles Juveniles Juveniles Juveniles Juveniles Juveniles

Loggerheads Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Green turtles Juveniles Juveniles Juveniles Juveniles Juveniles Juveniles Juveniles Juveniles Juveniles Juveniles Juveniles Juveniles

Leatherbacks Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Hawksbills Juveniles Juveniles Juveniles Juveniles Juveniles Juveniles Juveniles Juveniles Juveniles Juveniles Juveniles Juveniles

Olive ridleys NP NP NP NP NP NP NP NP NP NP NP NP

Mid-Atlantic

(Delaware 

to Virginia)

Kemp’s ridleys Juveniles Juveniles Juveniles Juveniles Juveniles Juveniles Juveniles Juveniles Juveniles Juveniles Juveniles Juveniles

Loggerheads Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Adults

Juveniles

Green turtles Adults 

Juveniles

Adults 

Juveniles

Adults 

Juveniles

Adults 

Juveniles

Adults 

Juveniles

Adults 

Juveniles

Adults 

Juveniles

Adults 

Juveniles

Adults 

Juveniles

Adults 

Juveniles

Adults 

Juveniles

Adults 

Juveniles

Leatherbacks Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Hawksbills Juveniles Juveniles Juveniles Juveniles Juveniles Juveniles Juveniles Juveniles Juveniles Juveniles Juveniles Juveniles

Olive ridleys NP NP NP NP NP NP NP NP NP NP NP NP
116

Blue shading indicates in-water presence, pink shading indicates the additional presence of breeding and nesting turtles. Darker colors indicate periods of higher concentrations of 

turtles, lighter shading reflects anticipated lower concentrations, and "NP" indicates absence. Species that are present in U.S. territorial waters but do not nest in U.S. territories 

belong to breeding populations whose nesting sites are outside of the U.S. (e.g., hawksbills and leatherbacks in the northern Gulf of Mexico nest in the Wider Caribbean region, 

leatherbacks present in the East Pacific nest in Indonesia, olive ridleys present in the Pacific nest in Mexico and Central America).

Region Species Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec

SW Atlantic

(North 

Carolina to 

Florida)

Kemp’s ridleys Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Adults

Juveniles

Loggerheads Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Adults

Juveniles

Green turtles Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Adults

Juveniles

Leatherbacks Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Hawksbills Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Adults

Juveniles

Olive ridleys NP NP NP NP NP NP NP NP NP NP NP NP

Gulf of 

Mexico/

Northern 

Caribbean

(U.S. EEZ)

Kemp’s ridleys Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Adults

Juveniles

Loggerheads Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Adults

Juveniles

Green turtles Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Leatherbacks Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Hawksbills Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Adults

Juveniles

Olive ridleys NP NP NP NP NP NP NP NP NP NP NP NP
117

Blue shading indicates in-water presence, pink shading indicates the additional presence of breeding and nesting turtles. Darker colors indicate periods of higher concentrations of 

turtles, lighter shading reflects anticipated lower concentrations, and "NP" indicates absence. Species that are present in U.S. territorial waters but do not nest in U.S. territories 

belong to breeding populations whose nesting sites are outside of the U.S. (e.g., hawksbills and leatherbacks in the northern Gulf of Mexico nest in the Wider Caribbean region, 

leatherbacks present in the East Pacific nest in Indonesia, olive ridleys present in the Pacific nest in Mexico and Central America).

Region Species Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec

East Pacific

(contiguous 

U.S. West 

Coast)

Kemp’s ridleys NP NP NP NP NP NP NP NP NP NP NP NP

Loggerheads Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Green turtles Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Leatherbacks Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Hawksbills* Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Olive ridleys Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Central North 

Pacific

(e.g., Hawaii, 

outlying 

islands, and 

connecting 

high seas 

areas)

Kemp’s ridleys NP NP NP NP NP NP NP NP NP NP NP NP

Loggerheads Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Green turtles Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Adults

Juveniles

Leatherbacks Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Hawksbills Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Adults

Juveniles

Hatchlings

Olive ridleys Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles

Adults

Juveniles
118

Appendix 4. Nesting beach activity by state

State Region (if different) Nest Laying Season Hatching Season Ends

Florida Nassau through Flagler

Counties

15 April – 30 Sep 15 Deca

Volusia through Miami-Dade

Counties

1 Mar - 31 Oct 15 Jana

Monroe County 15 Apr - 30 Sep 30 Novb

Collier through Pinellas

County

15 Apr – 30 Sep 30 Nova

Franklin through Escambia 

County

1 May - 31 Aug 20 Nova

Texas - 30 Mar – Oct 1 17 Nov

Louisiana, Mississippi, and 

Alabama -

1 May - 31 Aug 31 Oct

Georgia

-

15 Apr - 30 Sep 30 Nov

South Carolina -29 Apr - 30 Sep 30 Nov

North Carolina - 1 May - 15 Sep 15 Nov

Puerto Rico - 1 April – 30 Nov 31 January

U.S. Virgin Islands - 1 Feb – 31 Oct 30 Dec

Hawaii - 1 May – 31 Oct 30 Dec

a or 80 days after last nest in county was deposited (whichever is earlier).

b or 70 days after last nest in county was deposited (whichever is earlier).
119

Appendix 5: General information for miscellaneous operations

This Appendix includes basic protocols for operations that are not specifically targeting the 

documentation, rescue or recovery of sea turtles, i.e., activities where personnel may not have any 

familiarity with sea turtles, such as vessel operators and shoreline workers. The forms provide 

instructions on what to do if turtles are encountered during land- and sea-based operations, with 

emphasis on reporting, providing appropriate interim animal care and assistance, and documentation.

General at-sea protocol: retrieval of oiled, dead, or debilitated sea turtles

Information is requested for ALL encounters with oiled, dead, or debilitated sea turtles. If human 

safety and conditions allow, all dead and apparently debilitated turtles (including oiled turtles) should be 

retrieved and taken to an onshore facility for cleaning and rehabilitation or postmortem examination.

Turtles should be reported and brought to shore or transferred to another vessel for transport to shore 

as soon as possible. If a sea turtle cannot be retrieved, take photographs to document it as thoroughly 

as possible.

Sea Turtle Retrieval Kit (1 per vessel):

 Large diameter (>3 feet) dip net4

 Large plastic container (~26”Lx19”Wx15”H)

 Digital camera

 Large cotton towel

 PPE (gloves, Tyvek®suits, boots, goggles)

 Data forms and protocol

1. Protect yourself using appropriate safety equipment and precautions.

2. If a turtle appears dead or does not actively dive or swim away, bring it on board (dip-nets are 

useful for small turtles less than ~3 ft carapace length). Do not pick up turtles by their flippers, 

but rather lift them by grasping both sides of the carapace. Do not place hands or other body 

parts near the mouth, even if the turtle appears weak or listless.

3. If a turtle is not moving or responsive, but does not appear decomposed, place it in a protected 

area with the rear aspect of the shell elevated at an approximately 30-degree angle with the 

head downward and neck extended.

4. Keep the turtle out of the sun and on a cushioned surface. Do not put it in water.

-If the air temperature is >75 ̊F, keep it moist with towels or wet it frequently.

-If the temperature is <74 ̊F do not apply any moisture. 

-If the air temperature is <55 ̊F place the turtle in area that is as close to around 70 ̊F as possible.

5. Determine position at sea (latitude/longitude coordinates; DD.DDDD is preferred).

6. Contact [INSERT NAME AND CONTACT INFORMATION] to report the sea turtle as soon as 

possible.

7. Take multiple photographs of the animal to clearly document any visible oil and the condition of 

the turtle at the time of recovery (i.e., before any oil is removed).

 

4Recommended net size may vary depending on operational objectives; a larger net may be deployed if 

capture of larger turtles is anticipated.
120

8. Complete the Sea Turtle Observation Form. Provide your full name and contact information, 

including a phone number. Record any relevant information about oil conditions at the capture 

site.

9. Turtles that show obvious signs of decomposition (bloating, loosening of the skin) or that are 

unresponsive after 24 hours are considered dead and should be kept cool (with ice, refrigerator, 

freezer, shade) until transferred to a sea turtle responder.

10. If a debilitated or dead turtle cannot be retrieved, complete 4-7 above, taking photographs and 

complete the entire form. Instructions on how and where to send this information will be 

provided at the number above.

General shoreline protocol: oiled, dead, or debilitated sea turtles

Information is requested for ALL encounters with oiled, dead, or debilitated sea turtles. All dead and 

apparently debilitated turtles (including oiled turtles) should be retrieved and taken to a designated 

facility for cleaning and rehabilitation or postmortem examination. Turtles should be reported as soon 

as possible.

1. Protect yourself using appropriate safety equipment and precautions.

2. If a live or dead turtle is encountered on the beach, contact [INSERT CONTACT INFORMATION (i.e.,

Wildlife Branch Lead, Sea Turtle Group Lead, State Coordinator)]. If the turtle is struggling in the surf 

(appears unable to move onto land or out to sea) or a carcass is at risk of being washed away, move 

it out of / away from water and above the high tide line. Do not pick up live turtles by their flippers, 

but rather, lift them by grasping both sides of the carapace. Do not place hands or other body parts 

near the mouth, even if the turtle appears weak or listless.

3. For live turtles, keep the turtle out of the sun and on a cushioned surface. Do not put the turtle into 

water. Arrange for immediate transport or retrieval.

-If the air temperature is >75 ̊F, keep it moist with towels or wet it frequently.

-If the temperature is <74 ̊F do not apply any moisture. 

-If the air temperature is <55 ̊F place the turtle in area that is as close to around 70 ̊F as possible.

4. For dead sea turtles, keep cool (with ice, refrigerator, freezer, shade) until transferred to a sea turtle 

responder.

5. Determine location where the turtle was discovered (latitude/longitude coordinates; DD.DDDD is 

preferred).

6. If a camera is available, take photographs of the animal to thoroughly document its condition at the 

time of recovery.

7. If a stranding responder does not document the sea turtle in the field, complete a Sea Turtle 

Observation Form and provide the form to whoever receives the turtle. Provide your full name and 

contact information, including a phone number. Record any relevant information about oil 

conditions at the location where the turtle was found.
121

General Sea Turtle Observation Form
122

Definition and qualifications of wildlife observers

Note: The following is a description of Wildlife Observer qualifications and training currently developed 

for Florida. It has been slightly modified to be more generic, but it is most applicable to areas of the S.E. 

U.S. For other regions, the information provided below is intended to serve as a template for similar 

programs.

Description of Wildlife Observers

Wildlife observers are individuals with a background in biology and conservation, either through 

practical experience in the field such as a volunteer for a resource agency, through academic training

such as a degree or coursework in the biological or environmental sciences, or an individual 

recommended by resource agency staff for their experience with wildlife. Wildlife Observers may be 

deployed during an oil spill response to observe for, and report sightings of, sea turtles during response 

activities both on land and on water (i.e. on water during skimming operations, on land during beach 

clean-up operations).

Wildlife Observer Criteria

In order to qualify as a Wildlife Observer for Protocols approved by Unified Command for the 

________________ event, each individual must: 

A. Meet at least one of the following criteria:

1. Be authorized to work under a resource agency program (For example: volunteer on a Florida 

Fish and Wildlife Conservation Commission (FWC) Marine Turtle Permit approved under Florida 

Administrative Code Rule 68E-2, possess documentation of sea turtle work under a permit 

issued by U.S. Fish and Wildlife Service or other coastal state, or be involved in the FWC 

volunteer shorebird survey network (the Florida Shorebird Alliance)).

1,2

2. Have a degree or have completed advanced coursework in the biological or environmental 

sciences.

3

3. Be a Certified Field Biologist or Wetland Ecologist.

4

4. Have documented field biology experience as a researcher, technician, intern, or student.

5

5. Be recommended by a resource agency responsible for the wildlife to be observed.

Forms of documentation required (referenced in the superscripts above):

1Permit # or authorization # issued by federal or state entity

2

Shorebird survey network contact

3Transcript listing college degrees or courses

4Certificate number

5Resume with references listing appropriate work or intern experience

B. Meet Certification Requirements:

Each individual not already on a sea turtle permit issued by the U.S. Fish and Wildlife Service or state

must also complete an on-line training course (available from FWC) and pass the test with at least an 

85% correct score. Entities that pass the on-line training course will be provided with a certificate issued 
123

by [insert relevant resource agency]. These certificates shall be good for one year only and shall only 

allow the applicant to participate as a Wildlife Observer for the given spill event unless otherwise 

indicated on the certificate.

Description of FWC training for Wildlife Observers

FWC’s online training course provides basic information on how to determine if wildlife is present 

on the beach where nighttime cleaning operations are to take place. Training also would include 

recommended actions to be taken to minimize risk to the different species of sea turtles, shorebirds, 

and beach mice that might occur on beaches or adjacent dunes throughout the Gulf of Mexico. The 

training is followed by a series of questions – a test that must be passed with at least 85% correct 

answers. Individuals who pass the test are provided with a certificate that makes them eligible to work 

as a Wildlife Observer for beach clean-up operations undertaken for the spill incident.

Wildlife Observer Responsibilities (Beach example)

Gear

1. Bring a red LED headlamp and/or flashlight, cell phone, camera, and water.

2. You will be provided with survey flags to mark nests and other natural resource items of 

interest.

3. You will be provided with 2-way radios or cell phone numbers to ensure communication 

between you and the crew supervisor.

General Duties

1. Come prepared to work from sunset to sunrise.

2. Come prepared to walk the beach ahead of the crew (all- terrain vehicle may be available, but 

don’t expect to be driven).

3. YOU are responsible for informing and advising the crew on how to proceed if there is a wildlife 

issue.

4. Stay away from ANY oiled areas of the beach, which means you should have no need to bring 

protective gear. If you locate an oiled turtle crawl or nest, ask for assistance from the crew to 

place the markers.

5. Provide a written report the morning after your survey with date, time spent, and activities 

accomplished including wildlife observed and any actions taken or incidents, email to supervisor

and State Trustee contact.

6. Be familiar with all protocols for minimizing adverse effects to wildlife.

Wildlife Protection Duties 

1. Your main duty is to look for all wildlife and habitat that could be affected by the cleaning crews. 

You should walk or ride ahead of the crews to determine the presence of nesting sea turtles, 

shorebirds, or sensitive habitat. Try to stay at least 100 – 300 feet in front of the crews or 

equipment (closer than further away for equipment) but no more than 1⁄2 mile (2600 feet). Sea 

turtles could come up on the beach within the area in between you and the crew, so you must 

continually double back and recheck the area.
124

2. If you see a sea turtle crawl: determine if the turtle is still on the beach; look for a landward and 

seaward crawl; 

a. if both crawls visible, likely the turtle has completed nesting and returned to the 

water—use survey flags (3-8 flags) and mark the crawl and nest area, being careful not 

to disturb the crawl or nest site; 

b. if both crawls are NOT visible, very quietly and slowly walk landward to see if the turtle 

is on the beach; if you see the turtle, back away and quietly leave the area; tell the crew 

supervisor to keep the crews at least 200 feet away and stay quiet with lights off (red 

LED lights are ok if directed away); after the turtle returns to the water, you can flag the 

area and allow the crew to move forward. [Add any additional contact information].

c. advise the crews or vehicles to only cross the crawl seaward of the wrack /high tide line.

d. advise crews and machine operators to stay clear of the 10-foot buffer zone around 

marked sea turtle nests or posted shorebird nesting sites.

3. In areas where shorebird nesting areas are posted and marked, look out for chicks and birds 

moving around seaward of the marked area to the wrack line and tide line. 

4. Advise crew to stay away from posted and marked bird nesting areas and make sure the birds 

have moved away from where equipment or crews are before moving forward.

5. Advise crews to stay away from vegetated areas on the beach and the dunes. [Add any site 

specific information]

6. Report all stranded wildlife on the beach, oiled or not, to the wildlife hotline [Insert number]. 

This includes birds, sea turtles, and marine mammals. [Add contact information]

7. Take pictures of oiled wildlife, but do not use a flash if a turtle is on the beach.
125

Appendix 6: Chain of custody and evidence handling

Oil spills have the potential to result in legal proceedings, thus spill responders are typically asked to 

follow chain of custody (COC) and special sample and data handling procedures. These guidelines are 

intended to provide instructions for common scenarios. There is no single correct was of maintaining 

COC. Law enforcement from your federal or state agencies can assist with questions and should be 

consulted whenever necessary. As protocols may be updated over time, the latest instructions should be 

confirmed with NOAA or USFWS (as appropriate) General Counsel. Although the COC and evidence 

handling may seem daunting at first, the primary objectives are good record keeping and security, with 

the goal of preserving the integrity and validity of materials. These principles are good practices 

regardless of the circumstances. This Appendix includes two related sections: chain of custody and

handling of evidence.

Chain of custody (COC)

Chain of custody is a written record of the origin of evidence and provides a list of people that have 

had possession of that evidence. The COC record is primarily intended to address questions involving the 

integrity of samples or other evidence collected in support of the natural resource damage assessment 

or other legal claims. Evidentiary items that responders working with sea turtles may encounter include: 

carcasses, oil samples collected from turtles, biological/diagnostic samples, data forms, and electronic 

photographic data. Generally, any material collected from a case should be documented under COC. If 

you are unsure if an item is considered to be evidence, be conservative and document it. The best COC 

record is clearly written and thoroughly documents the history of an evidence item, starting with the 

collector or initial recipient, and as it passes from person to person, i.e., there are no “breaks” in the 

chain. Anyone that takes possession of evidence or alters evidence (such as someone who runs an 

analysis on a sample or performs a necropsy) should appear as having received that evidence on the 

COC record. The only exception is couriers used for shipping of sealed packages containing evidence

(e.g., delivery personnel). In this instance, means of delivery is entered on the COC, but couriers do not 

have to sign the COC. In addition, the COC passes from person to person, not facility to facility, e.g., it is 

not appropriate for one person within a facility to accept custody of an item and another person to 

release it. The last recipient must be the person who releases the item(s).

A COC record format has been developed for sea turtle spill response, including directed capture 

and documentation of strandings, and is included in this Appendix. Other COC forms may be formatted 

for specific purposes (e.g., scientific collections, photographs), but the basic elements and principles 

described here apply. There are both written and electronic fill-in versions of two generic forms, a 

Primary Form and a Subsample Form. The Primary Form should be used to document animals (alive or 

carcass) and any items collected in the field, such as stranding reports or field data sheets, external oil 

samples, fishing gear, and photographs. The Subsample Form is used for anything collected from items 

listed on the primary form, such as clinical samples (e.g., blood, feces) or necropsy samples (Fig. A6-1). 

Typically, an animal will have one primary form and one or more subsample forms. You may use the 

written or electronic form, but try to avoid combinations of written and typed entries for the descriptive 
126

fields (all except for the release/receipt fields). If you make a mistake, line through the error (single line), 

add the correction, and initial the change. Never scratch out, erase, use white-out, or otherwise obscure 

entries. This rule applies to COC records as well as any other documents, e.g., stranding forms, and is 

good scientific practice. Use a black or blue pen for all written entries. Write clearly and legibly.

Figure A6-1. General organization of primary and secondary chain of custody (COC) forms. The data collected during 

initial discovery of the animal or upon receipt are captured in the primary COC. Samples collected from any of those items, e.g., 

necropsy or clinical samples from the turtle, are documented in one or more subsample forms. Any further subdivision or 

subsampling of items is entered into a subsequent subsample form.

Who starts a Primary COC record? Ideally, it is a person who is involved with initial collection of the 

animal. Subsample forms are started by a technician, veterinarian, or person leading necropsy, i.e., the 

individual primarily responsible for collecting samples/data. If an animal is collected by a member of the 

public or someone unfamiliar with COC, the person who receives the animal may initiate the COC and 

enter the relevant information in the “received from” field. Only one person initiates a given COC 

record. The following are example forms to illustrate how to fill out a COC record. The first example 

shown on the next page is the Primary Form for a dead, stranded loggerhead turtle.

Subsample COC 

2

Subsample COC 

1

Primary COC

-Live turtle/carcass

-External oil sample

-Field photographs

-Field/stranding

report or data sheet

Necropsy samples:

-Tissues in formalin

-Frozen tissues (listed)

Subsample of frozen 

tissue #1

Tissues for histology

Clinical samples:

-Blood

-Feces

-Urine
127

Case number: This number is 

assigned by law enforcement, it is left 

blank unless otherwise instructed.

Date and time of collection: Enter 

the complete date and time (use 

military format or indicate am/pm) 

Agency/affiliation: Affiliation of the 

person initiating the form.

Seized/Collected by: Person initiating 

the form. Do NOT enter multiple 

people.

Source of evidence/property:

Includes any information relevant to 

the source of evidence. “Taken from” 

generally is left blank as it applies to 

a law enforcement action. “Received 

from” is filled out if some else was 

the primary source of the item, for 

example if a member of the public 

brought in an animal or item. “Found 

at” includes the physical location and 

coordinates of the stranding.

Defendant/Company name:

Assigned name of the spill 

Item number: All items are given 

sequential individual numbers. If 

possible, avoid assigning the same 

number; use alphanumeric 

combinations (e.g., 1A, 1B) if 

necessary.

Description of evidence: Include the 

stranding identification number, any 

other identifier applied, and species.

James Smith

Allison Doe

The shaded fields document any transfer of items and who released or received them.

IMPORTANT: The first person to release any items should be the same person as 

listed in the “Seized/collected by” field at the top of the form. The numbers of items 

transferred are entered in the left column. In this simple example, all items were 

given from the initial responder, James Smith, to Allison Doe. The parties sign the 

form and the delivery method (in person) is circled.
128

The next action that may happen is submission of a sample for analysis. In the example above, the 

primary stranding responder, James Smith, has transferred everything to Allison Doe at a facility where 

the carcass is stored. Among the items were two external swabs that were collected to determine the 

identity of an unknown substance on the carcass. Allison needs to ship these samples to a laboratory.

The original primary COC record should remain with the main evidentiary item, typically the live 

animal or the carcass. The COC is copied, and then the items are signed as released on both the original 

and copied forms. The signed copy is sent with the sample to the laboratory. A notation is then entered 

on the original COC record. This procedure is done the same for the Subsample Form, as shown in the 

next section. Here is what the bottom of the forms should look like:

Original (still at the same facility as the animal)

Copy signed for release (sent with sample and signed upon receipt)

The courier, FedEx in this example, does not sign for custody. Sealing of evidence will be covered 

in the next section. This is how the COC is split to accommodate sending items to various 

people/locations. The end result should be that the original COC has notations of where all items are or 

were sent. The copy sent out with sample now serves as the COC record for that specific sample. If the 

animal is transferred, then the original primary COC record goes with it and a copy is retained at the 

facility as the record for any samples remaining in-house. If the animal is released into wild, retained as 
129

a long-term captive, or if the carcass disposed of, keep the COC record with the animal’s record unless 

otherwise instructed.

The Subsample Form is used whenever material is derived from an item on the Primary Form.

Typical examples are clinical samples, e.g., blood collected from a live animal, necropsy samples, or 

division of a sample into smaller quantities. Simply put, if you collect anything from a live or dead 

animal, initiate a Subsample COC. Continuing with the example of the loggerhead, here is how the

Subsample Form would be filled out if this turtle was alive and samples were collected in rehabilitation.

A subsample form is started by the person collecting the samples and all item collected are entered.

 TO UNIVERSAL BLOOD LAB 12/12/2010

Eric Smith, DVM

Eric Smith, DVM

SHIPPED TO UNIVERSAL MICRO LAB 12/12/2010

Date and time of 

collection: Date and time 

of collection.

Collected by: veterinarian, 

lead technician or biologist.

Source: Include any specific 

identifiers for the animal 

and species.

Clinical samples collected from JXM2010121201, Loggerhead 

turtle; Name: “Turtle”

SHIPPED TO DIAGNOSTIC SERVICES LAB 12/12/2010
130

As in the previous example, specific items are signed as released and their disposition is noted on the 

original COC record (shown here) and a signed released copy (not shown) is sent with the sample(s).

Based on this COC record, Item 2 and four blood smears from Item 3 would still be in Eric Smith’s 

possession.

A subsample form can be used for individual samples, or multiple samples. If all of the samples listed 

on the form go to a single recipient, then the original subsample form should be sent with the sample(s)

as no items on that form would be left in possession of the collector (a copy should be retained in the 

animal’s record). If individual samples are being sent to different recipients or are retained, then keep 

the original form with the animal’s record, and send signed copies as described above. It is standard that 

some types of samples, such as blood smears or cytology slides, are collected in many replicates. It is 

acceptable to list the number of replicates and how many are released. In the previous example, serum 

and one blood smear are sent for clinical pathology, and one serum sample and four blood smear slides 

are retained at the facility. A live clinical case likely will have many subsample forms for its duration in 

rehabilitation.

In summary, here are the steps for COC and shipping a subset of items listed on a given form: 

1. Copy the original COC record (Primary Form or Subsample Form) that has the item on it.

2. Sign a release of the sample on BOTH the copy AND the original.

3. Note where the item was shipped on the original form and keep the original.

4. Send the signed copy with the shipped sample(s).

5. The person receiving the sample signs the copy and keeps the COC as the record for that

sample(s).

Helpful practices for COC records within facilities/organizations:

1. Have the fewest people possible serve as evidence custodians, and make sure that these

individuals are familiar with the guidelines. Evidence can be signed over to one or two

designated custodians within an organization, which facilitates transfer of custody.

2. Keep track of anyone who leaves your organization that is listed as a holder of evidence,

especially if it will be difficult to reach them. Be sure that they sign over custody to another staff

member before they leave. This measure is especially important when temporary personnel are

brought in.

3. Do not create gaps in the COC record. If you are not the last person to have custody of a

sample, then you cannot release it. Chain of custody is from individual to individual, not from

organization to organization.

4. Be aware that anyone that assumes custody of evidentiary material is subject to be called upon

for legal purposes, such as to verify custody and handling of a sample. This responsibility should

not be taken lightly.
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Handling of evidence

Sealing samples/evidence

When evidence is collected, it should be preserved in a way that ensures integrity during storage 

and shipment. All items should be clearly labeled/tagged with identifiers, species, contents, date of 

collection, and evidentiary item number. The collector that is the primary evidence holder, i.e., the 

person listed in the “seized/collected by” field of the COC should seal the sample using tamperproof 

tape as soon as possible after collection, and before it is released to the next person. Tamperproof tape 

is initialed and dated in a manner that would be visibly disrupted if the item was opened/accessed. Here 

are some examples:

Jars are sealed by wrapping tape around the lid or around the 

entire jar, as shown. The initials and date overlap an area that 

would be broken if opened.

Plastic bags of all shapes and sizes are commonly used to hold 

evidentiary items/biological samples. The opening should be 

completely sealed as shown here, and initialed and dated along 

the edge. Any tampering would be clearly visible. Clean and dry 

the surface before applying tape. Take time to seal containers 

thoroughly, avoiding wrinkles, to reduce accidental loss of the seal.

If a sample is accessed, and the seal broken, it 

should be resealed and the action noted in 

laboratory notes. For bags, an unsealed part of 

the bag should be cut open, and then resealed.

In this example, the bag was originally sealed 

on 12/13/2010 and then accessed and resealed 

on 3/2/2011. The original seal is left intact.

Note that the evidentiary item number is

included on the container label.
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Helpful practices for sealing evidence

1. Place small items and items that are difficult to seal, such as blood tubes and slides, in a bag and

seal the bag.

2. Clean and dry surfaces thoroughly before applying tape. Avoid wrinkles and exposed adhesive

surfaces.

3. If sealed items are to be frozen, place them in a second bag before freezing. The second bag will

reduce potential damage to the tape and the likelihood of accidental loss of the seal after

freezing.

4. Use evidence tape that is known to withstand freezing. Some brands, including the precut

individual strips of tamperproof tape, tend to come off during freezing.

Photographic digital evidence

Most photographic evidence is in a digital format. Use designated cameras and memory cards. A 

placard that includes identifiers, such as stranding number and pathology accession numbers, date, and 

a scale should appear within the photos and/or be taken at the beginning and end of a sequence of 

photos. It is a good practice to begin each case with a photo placard labeled “start” and the time, and 

end the photographic series for a case with a placard labeled “end” and the time. It is important that 

photos remain unaltered and sequential. Do not delete any photos on the camera until a secure, 

immutable, “original” copy has been made as per Section 3.4.3.

Security

All items collected as evidence should be stored in a secure, locked area. Freezers containing 

evidence should be locked. Only keyed locks, not combination locks, should be used. It is best if three or 

fewer people are designated key holders and primary evidence custodians for a given facility. An entry 

log should be maintained for freezers containing evidence. All access should be documented by date, 

time, individual, and purpose. Any evidence deposited or removed should be clearly noted.
133

Primary COC Form
134

Subsample COC Form
135

COC Page 2 (Primary and subsample)
136

Example Freezer Log
137

Appendix 7: Collecting external samples of oil or suspicious material

Instructions for making sampling kits using readily available materials

(note: special laboratory-grade materials are preferred if only a small (trace) amount of oil is present)

Materials:

1. 3 or 4 in. square, non-sterile cotton gauze

2. 12 in. roll of aluminum foil

3. Pint size sealable plastic bag or whirlpak with label (do not use completely transparent bags as the

label easily smears or is less legible)

4. Clean metal forceps or wooden tongue depressors

Instructions:

A. Put on clean disposable gloves. Remove an approximately 10-12 inch length of aluminum foil,

taking care not to touch the dull side.

B. Using metal forceps or two wooden tongue depressors (like chopsticks), remove a square of

gauze from the pack and place it onto the dull side of the foil. Fold the foil in half with the dull

side, covering the gauze. Be careful not to touch any other surface with the gauze.

C. Fold over the sides of the foil to enclose the gauze on three sides.

D. Fold over the open end of the pouch to completely enclose the gauze. The gauze will be

removed from this end for use. Place the pouch into a sealable plastic bag until needed.
138

Collection of external samples

A. After putting on the necessary personal protective equipment and taking photographs of the oil

or suspect material, open the sample bag and foil or jar and carefully grasp the gauze using 

clean metal forceps or disposable wooden tongue depressors (as with chopsticks). 

B. Thoroughly swab the area of interest. 

C. Make sure that the material has been clearly transferred onto the gauze. The gauze should be 

visibly discolored by the substance. Preferably, it should also contain accumulated solid material 

(as shown).

D. If using aluminum foil, place the gauze square into the premade foil pouch with the dull side 

inward. Fold the foil so that it completely encloses the gauze. Place the aluminum pouch into a 

sealable plastic bag. If using a glass jar, carefully place the gauze into the jar and close the lid.

E. Label the bag or jar (using indelible ink) with the animal identifier (stranding or field ID), species, 

and date.

F. Seal the bag or jar with evidence tape and sign and date the edge of the tape.

G. Keep the sample cool and transfer it to a -20°C (or colder) freezer as soon as possible.

As protocols may be updated over time, the latest instructions should be confirmed with NOAA or USFWS 

(as appropriate) General Counsel.
139

Appendix 8: Stranding response

Required equipment for stranding response

 GPS unit

 Designated use digital camera

 Multiple appropriately-sized containers for holding turtles of the expected size classes

 Clipboard with blank stranding and chain of custody forms and writing instruments

 Dry erase board (or notecards) for creating photo placard

 Measuring tape (flexible, nonmetallic)

 PIT tag scanner

 Oil sampling kits

 Trash bags

 Personal Protective Equipment (oil resistant protective outwear [e.g., Tyvek® suit], rubber 

boots, nitrile or rubber gloves, duct tape, face/eye protection)
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Outline protocol for turtle retrieval from oil spill response zones 

1. If oil is visible on beach (or suspected based on oil in area) put on Personal Protective Equipment 

(PPE – Tyvek® suit, rubber boots, nitrile or rubber gloves, eye protection) before going into oiled 

area, and place two plastic bags at the place of exit from beach. Upon leaving, any oiled disposable 

PPE goes into one bag for hazardous waste disposal and oiled boots go in the other for later use.

2. Create a photo identification card (paper or dry erase board) with designated Spill Name, 

Date/Time, GPS coordinates or detailed location description, and Stranding ID #. Photograph the 

photo card by itself.

3. Take multiple photographs of the turtle including at least one with the photo card, but do not cover 

up parts of the turtle with the placard. Make sure all areas of the body, including any abnormalities, 

are represented in the photos.

4. Visually inspect turtle. Take close-up shots of any visible oil. If you see or smell any oil on the turtle 

or any material you suspect to be oil, take close up photos that clearly show the material and 

proceed to instructions for Visibly Oiled Turtles (below). For dead turtles, if no oil is observed, turn 

the carcass over, further inspect it for oil, and take photographs of the underside.

5. Take a final photo of the photo card, completing the photo series for that animal.

6. Complete the basic descriptive portion of the stranding report, including your name, date, and 

location.

7. For LIVE TURTLES, transport the animal to the nearest designated intake facility or transfer to the 

individual who has been designated to transport the turtle, if applicable.

8. For DEAD TURTLES, complete remainder of the stranding report, including measurements, place the 

carcass in plastic bag; include paper label with Stranding ID # inside bag with carcass. Place label on 

outside of bag with Stranding ID #. Cover the carcass with ice or keep as cool as possible.

9. Complete a primary Chain-of-Custody Form upon transfer of live and dead turtles to the intake 

facility or individual transporting the turtle, if applicable. Provide all samples taken and forms 

completed along with turtle to intake facility. Make sure forms are completely filled out and all 

samples are labeled and sealed according to evidence collection protocols. Do not download photos 

from memory cards until evidentiary copies have been made.

Visibly oiled or suspect oiled sea turtles:

1. If you see oil or substance suspected to be oil, sample the material using the provided gauze using

metal forceps or wooden tongue depressors. Do not touch the area that might have oil on it, the 

gauze, or inside the sampling materials with the nitrile gloves. Thoroughly swab the area of 

interest making sure that the material has been clearly transferred onto the gauze (visibly 

discoloring it).

2. Place the gauze square onto a piece of aluminum foil with the dull side to the sample. Fold the foil 

so that it completely encloses the gauze. If using a premade foil pouch, carefully insert the gauze 

into the foil pouch and fold the end closed. Place the foil with the gauze into a sealable plastic bag. If 

using a certified glass jar, place the gauze directly inside and firmly close the lid.

3. Label the bag or jar (using indelible ink) with the information from the photo placard.

4. Seal the bag or jar with evidence tape, if available, and sign and date the edge of the tape.

5. Keep the sample cool and transfer it to a -20°C (or colder) freezer as soon as possible.
141

Instructions for completing a Sea Turtle Stranding and Salvage Network (STSSN) 

Report Form (Atlantic, Gulf of Mexico, Caribbean)

Observer’s Name / Address / Phone:

The observer is the person who handled and collected data on the turtle in the field. Please include 

your full name with middle initial if you have one. Please give a complete address and phone number 

where you can be reached in case we need to contact you for clarification of the report. Include an email 

address if available.

Stranding Date:

This is the date the turtle was first encountered. If you did not investigate and document the turtle 

until a later date, please note that on the form. Turtle number by day is used to keep track of the 

number of turtles any individual STSSN participant documents on a single day – your first turtle of the 

day is 01, second of the same day is 02, etc. Time is the time you saw the turtle on the beach or in the 

water.

Species:

Refer to the Sea Turtle Identification Key (ID placard) to determine species based on characteristics 

detailed on the back of the form. Take multiple photos of the turtle – including straight down views of 

the carapace, plastron, and head; if the turtle is entangled or has any injuries, take photos to document 

those anomalies. If you are unsure of species ID, take several photos from different angles and try to 

salvage the carcass and contact your state coordinator for assistance in species identification.

Stranding Location:

If the turtle was found along a Gulf of Mexico or Atlantic Ocean beach or in the water, check 

“Offshore”; if the turtle was found landward of an Atlantic or Gulf beach, inside a bay, pass, inlet, 

lagoon, river, harbor, bayou, etc., check “Inshore”. Describe the specific location where the turtle was 

found using major reference points that can be found on maps or nautical charts. Do not use local 

landmarks that cannot easily be found on maps. Good reference points include: inlets, lighthouses, 

county or state lines, roads that intersect the beach, park boundaries. If the location is obscure, or 

difficult to describe, include a map with the stranding location marked when you submit the stranding 

report form. If the turtle was found floating, please clearly indicate this on the stranding report form. If 

you use a GPS unit or other device (e.g., mobile phone) to determine the latitude and longitude of a 

stranding please indicate this.

Condition of Turtle:

Check the code that best describes the stranded turtle at the time of stranding. For example, if a 

turtle strands and later dies, it is classified as alive. If the stranding seems intermediate between two 

codes, pick the one that fits best.

Alive (Code 0): Eye blink response; breathing (breaths may be several minutes apart); may or 

may not be active / moving around.
142

Fresh dead (Code 1): Should initially question whether it is alive; may have rigor mortis; eyes 

should be clear; no smell of decomposition; no evidence of bloating. If the turtle smells at all or 

is bloated, it is not fresh dead!

Moderately decomposed (Code 2): Mild to moderate smell of decomposition; mild to moderate 

bloat; bulging eyes, if present; soft tissue may feel spongy; scutes and skin may be beginning to 

detach.

Severely decomposed (Code 3): Foul smell; severe bloat or already de-gassed (collapsed); scutes 

and skin detaching or missing; bony structures may be disarticulating.

Dried Carcass (Code 4): Completely desiccated, only dry skin and bones; little to no smell.

Skeleton, bones only (Code 5): Bones only with no soft tissue remaining.

Final Disposition:

ALL TURTLE STRANDINGS WITHIN A DESIGNATED OIL SPILL RESPONSE AREA NEED TO BE SALVAGED 

FOR FUTURE NECROPSY / ANALYSIS. CONTACT YOUR STATE COORDINATOR FOR INSTRUCTIONS.

During regular operations: check the disposition code that best describes what you did with the 

stranded turtle. To avoid duplicate reports being received on the same turtle, try to never leave an 

unpainted carcass on the beach. It is best to paint the turtle and bury it above the high tide line. If 

nesting occurs in the area, bury the carcass well off the nesting beach behind the dune line to prevent 

digging into any nests. Codes 1-4 are used for dead turtles only.

Code 2 turtles (buried on or off the beach) - include turtles disposed of at local landfill locations. 

Codes 6 & 7 are for live animals. If you check code 6 (alive, released), please describe when and where 

the turtle was released in the box at the bottom of the form. If you check code 7 (alive, taken to a rehab. 

facility), please write the name of the facility where the turtle was taken in the blank provided. If a turtle 

was found floating and the carcass (or live turtle) was not recovered, check code 8 (left floating). If none 

of the codes describes what you did with the turtle, please explain in the box at the bottom of the form.

Sex:

Since immature sea turtles cannot be sexed externally, you should most often check undetermined. 

Loggerhead and green turtles < 92 cm straight carapace length (SCL), Kemp’s ridleys < 60 cm SCL, and 

hawksbills <80 cm SCL are generally considered immature. Adult male turtles will have a tail that 

extends well beyond the posterior tip of the carapace. If you document a turtle with a long tail, please 

measure the length of the tail beyond the carapace and record the measurement in the blank provided. 

If you necropsy a turtle and determine the sex through visual exam of the gonads, please check the box 

provided.

Tags:

Check all four flippers of the turtle for flipper tags or evidence of lost tags (tear-outs, holes, or scars). 

If found, record all tag numbers, where each tag was located on the turtle (example: XXX111-left front 

flipper, XXX112-right front flipper) AND the return address inscribed on the tag; if evidence of lost tags

are present, note the location. Examine the carapace for living tags; if found, record the location in the 

space provided on the form. If you have a PIT tag scanner, thoroughly scan all flippers (dorsal and 
143

ventral), and the shoulders/neck region and record the tag number and location of any tag found. 

Always check the scanner first using a test tag to make sure that it is functioning properly. ANY TURTLE 

THAT HAS ANY TAGS OR EVIDENCE OF LOST TAGS SHOULD BE SALVAGED FOR FURTHER EXAMINATION –

CONTACT YOUR STATE COORDINATOR.

Carapace Measurements:

Record all measurements taken in the appropriate blanks and be sure to circle the unit of 

measurement – centimeters (cm) or inches (in). Straight-line measurements are taken ONLY with 

calipers. If you do not have calipers, do not fill in the blanks for straight-line measurements. If you do 

have calipers and take straight-line measurements, please take curved measurements as well. Curved 

measurements are taken with a flexible measuring tape. The proper locations for obtaining standard 

carapace measurements are shown on the stranding form. If the measurements taken are estimates 

(due to carapace damage or decomposition), please indicate this on the form.

Remarks:

Please provide as much information as possible about the stranding. Note any wounds or 

abnormalities, tag locations, entanglement, etc. (you can also draw on the diagrams). All information 

provided will be coded as part of the turtle’s record. If the turtle is entangled, try to salvage the 

entangling material(s) and contact your state coordinator. PLEASE DO NOT LEAVE THIS SECTION BLANK –

NOTE IF NO WOUNDS OR ABNORMALITIES WERE FOUND.
144

Sea Turtle Stranding and Salvage Network (STSSN) Report Form (Atlantic and 

Caribbean)
145
146

U.S. West Coast Sea Turtle Standing Report
147
148

Pacific Islands Sea Turtle Standing Report

Pacific Islands Stranding Form
149
150

Appendix 9: Directed capture

Required equipment for directed capture operations

 GPS unit

 Designated use digital camera

 Satellite phone

 Long-handled dip-net (2-4’ in diameter, netting with stretched mesh ~3-5”, 12-15’ handle)

 Multiple appropriately-sized containers for holding turtles of the expected size class

 Plastic kiddie pool (4-5’ diameter) for holding turtles during sampling and cleaning

 Disposable oil absorbent pads 

 Cloth towels

 Field data forms, index cards, and chain of custody forms

 Personal protection equipment (Tyvek® suits, disposable gloves, close-toed shoes, eye/face 

protection, duct tape)

 Secure hard drive

 Water resistant field notebook

 Digital inclinometer

 Infrared thermometer (laser directed)
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Sea turtle directed capture protocol

1. Only target search area conditions specified by operations (oil and oiled habitat).

2. When a turtle is observed, mark and record the waypoint. Using a long-handled dip-net, capture 

the turtle if it is seen to be oiled. Do not chase or capture vigorously swimming turtles or turtles 

that are not visibly oiled.

3. If the turtle is captured, bring it aboard in the net and set it within a kiddie pool. Carefully remove 

the turtle from the net and place it on a clean, unused absorbent pad within the pool. Always use 

PPE when handling oiled sea turtles.

4. Create a photo identification card (3” x 5” index card) that includes the vessel name, turtle ID,

capture position (lat/long), and the name of the spill. The turtle ID consists of the three letter 

initials of a designated member of the capture crew, four digit year, two digit month, two digit 

day, followed by the sequential number for turtles captured that day (e.g., Jane A Doe captures a 

turtle on 5/12/2017 and it is the second turtle captured that day; the ID will be JAD20170512-02; 

if 6 turtles are caught, the last will end in -06).

5. Using a designated camera (for oil spill turtles only), take a photograph of the photo card as the 

first image for that animal. Next, place the photo card near the turtle and take dorsal and ventral 

photos. Take a few close images of oil or suspicious material anywhere on the body or within the 

mouth (if possible) – clearly documenting external oil. It is not necessary to include the photo card 

in these closer images. Take a photograph of the photo card as the last image for the animal. 

6. Take a temperature reading by aiming the thermometer at the shoulder area or the prefemoral 

area between the base of a rear flippers and plastron (Fig. A9-1).

7. Using oil absorbent pads, wipe the oil from the shell, skin, and head. Do not attempt to remove 

every bit of oil - the goal is to wipe the majority of the loose oil from the turtle.

8. Place the turtle on a wet towel in a clean (non-oiled), numbered plastic bin and tape the photo 

label to the outside. Cover the bin with a clean (non-oiled) towel. The bin must be sufficiently 

ventilated. Place the bin in the shade or in a climate controlled area such that ambient 

temperature is no warmer than the low 80's (F). If a climate controlled cabin is used, maintain 

temperatures no colder than the high 70's (F). Pay close attention to animals throughout the day. 

Do not allow containers to be inadvertently left in the sun during operations. The towels can be 

dampened with water to control temperature.

9. A member of the capture crew initiates the chain of custody form and completes the AT-SEA 

TURTLE DATA SHEET.

10. A data sheet is also completed for turtles that are observed but not captured and for captured 

turtles that are unoiled. Any unoiled turtles that are active and do not have any apparent 

abnormalities should be immediately released.

11. As soon as possible after a turtle is captured, notify shore-based operations to inform them that a 

turtle will be brought in for care.

12. When search effort is concluded, call shore-based operations and report the total number of 

turtles being brought in and estimated time of arrival so that ground transportation and 

rehabilitation facilities can be prepared.

13. Closely follow the agreed upon return time to facilitate timely care and treatment of oiled turtles.
152

Directed capture ancillary procedures

Handling of GPS units and data

GPS data, including all vessel tracks and waypoints should be downloaded daily onto a designated 

secure hard drive or server. Transfer all data into a folder labeled according to the following convention: 

vessel name_two digit month.two digit day.four digit year (e.g., Sea Spray_05.12.2017).

Handling of turtle photos

Only use designated cameras and memory cards. It is crucial that photos remain unaltered and 

sequential. Do not delete any photos on the camera, even those taken inadvertently. Follow response 

protocols for uploading or copying images. After these official copies have been made and confirmed, it 

is permissible to makes additional copies of the images for other response uses and to reuse the camera 

/ memory card.

Crew leader daily log

Each directed capture team leader keeps a daily log recording the vessel used, height of the vantage 

points used to sight turtles, eye level of the observers, time of departure and return, sea state, weather, 

sighting conditions, characteristics of encountered oil (e.g., sheen, slicks, mousse), and any observations 

of other wildlife within or near oil, especially any oiled animals (taxa – as specific as possible, sighting 

coordinates).

Figure A9-1. Examples of standard dorsal and ventral photographs used to document external oiling. The arrowheads and red dots 

indicate two areas where body temperature can be measured using infrared thermometers.
153

At-Sea Turtle Data Sheet
154

At-Sea Effort Log
155
156

Appendix 10: Transport of sea turtles

Live sea turtles

Live turtles must be shaded and otherwise protected from extremes of heat and cold (not above 

90°F and not below 50°F). If a turtle is transported in ambient temperatures greater than or equal to 

75°F, it should be cooled by keeping a wet towel on the carapace and by periodically pouring water over 

the turtle. Water and wet towels should not be used when transporting turtles at temperatures less 

than 75°F or at any time they are exposed to an air-conditioned environment. 

A variety of containers may be used to transport sea turtles depending on the size of the animal, 

including kiddie pools for larger turtles, plastic or cardboard pet crates, or banana boxes. The containers 

must allow air circulation, the bottoms must be padded, and the container should not include any 

material that could be accidentally ingested. Hatchlings and post-hatchlings should be transported in a 

container with a damp or moist towel. Sea turtles are not transported in water.

Only one animal is transported per container for turtles larger than 10 cm carapace (shell) length.

Secure all containers during transport such that they do not slide around or tip over. Minimize bouncing 

and jostling of the containers to the degree possible.

Dead sea turtles

Keep carcasses as cool as possible by placing them in coolers and/or covering them with ice.
157

Appendix 11: Rehabilitation and release

Rehabilitation facilities may receive live and dead sea turtles from within the response zone. This 

Appendix includes procedures for documentation, treatment, and sampling. An important aspect of 

these procedures is confident identification of individual animals. There are two primary identifiers that 

are assigned to sea turtles during this process: a field identifier and a log number. The field identifier 

(stranding or capture ID) consists of the three letter initials of the person that first documents the turtle, 

4-digit year, 2-digit month, 2-digit day, followed by the sequential number for turtles captured that day.

For example, Jane A Doe documents a turtle on 5/12/2017 and it is the second turtle she documents

that day - the ID will be JAD20170512-02; if 6 turtles are documented by Jane A Doe on that day, the last 

will end in -06. This number typically is recorded on the COC form when the turtle is presented to a 

rehabilitation facility. This identification format minimizes duplicative identifiers, but is too long for easy 

reference and labelling of samples. When turtles are received at the rehabilitation center, they are 

logged into the Live or Dead Sea Turtle Intake Log, as appropriate, and receive a shorter number that 

will be primarily used for in-house identification and labelling of any samples. All turtles that are found 

alive should be entered on the Live Log, even if they die during transit. Do not apply additional names to 

turtles as this will create confusion and risk loss of important information.

Included in this Appendix is a list of essential supplies necessary to receive, evaluate, stabilize, and 

treat oiled sea turtles. This list should be considered provisional and requires consultation with specific 

facilities to ensure that it is adequate and complete.
158

Outline protocol for admitting sea turtles

Live turtles* Dead turtles

General Intake

1. Initiate or receive and sign Chain-ofCustody Form.

2. Enter turtle into Live Turtle Intake Log 

and assign log number.

3. Perform physical examination and 

complete Sea Turtle Intake Form.

4. Place temporary identification on turtle.

5. Review stranding report and complete 

any missing information.

6. Collect oil sample if one did not 

accompany turtle.

7. Take dorsal and ventral photographs with 

photo placard (include log number, turtle 

stranding/capture identifier as appears 

on COC, date, and facility name). Take 

additional photographs of any oiled areas 

(including mouth).

8. Initial blood collection.

Post-examination

9. Washing procedures.

10. Initial treatments (e.g., fluid therapy).

Rehabilitation

11. Assessment and additional treatment.

12. Implantation of flipper tags/PIT tag prior 

to release.

General Intake

1. Initiate or receive and sign Chain-ofCustody Form.

2. Enter turtle into Dead Turtle Intake Log and 

assign log number.

3. Review stranding report and complete any 

missing information.

4. Collect oil sample if one did not accompany 

turtle.

5. Make a carcass tag that consists of the field 

identifier (as it appears on COC) and dead 

turtle log number.

6. If fresh dead (no odor or bloating), place 

the turtle in a plastic bag, attach the carcass 

tag, completely cover in ice, and contact 

your stranding coordinator for further 

instruction.

7. If decomposed, place the carcass in a 

plastic bag, attach the tag, and freeze the 

carcass if not to be necropsied within 24 

hours.

*Note that all sea turtles found alive are entered into the Live Turtle Log, even if they die in transit. Turtles that are 

dead upon arrival are handled according to instructions for deceased turtles (right column).
159

Intake and treatment protocol (developed during DWH spill)

The following procedures describe intake and treatment in situations where multiple animals are 

admitted. These instructions should be reviewed in consultation with the attending veterinarian(s) and 

may be modified as dictated by medical judgment, animal welfare needs, and numbers of animals 

admitted for care. Additional therapy, such as administration of antibiotics, is at the discretion of 

attending veterinarian. At no point should paperwork or related procedures delay care and treatment.

Any such difficulty should be immediately reported to Wildlife Branch personnel.

Intake Processing: On arrival, turtles are quickly and briefly checked to ensure they are responsive. The 

most lethargic are processed first. Intake photos are collected, weight obtained, and the animals are 

assigned an in-house ID number (log #) and a temporary flipper band or shell marking if needed.

1. Examination: Two assistants are assigned to each turtle, depending on size - one holder, one 

recorder / extra set of clean hands. The turtle is presented to veterinarian that starts physical 

examination with a general evaluation including heart rate measured by Doppler and respiratory 

rate.

2. Blood: For rapid evaluation, blood may be collected for a point-of-care analyzer immediately after 

thoroughly cleaning a small spot over the external jugular vein (alcohol, chlorhexidine or 

betadine). Remaining blood is processed for regular CBC/plasma chemistry including hematocrit 

tubes (for in-house PCV/TS and one for laboratory), 4 blood smears (2 for laboratory and 2 backups in case samples are lost/broken), and whole blood in a lithium heparin tube for centrifugation 

and plasma recovery.

3. Initial treatments: After blood collection and recording of heart and respiratory rates, the eyes are 

stained with fluorescein and the rest of the physical examination is performed. During this time, if 

there is extensive oil on the corneas, a small amount of mayonnaise or ophthalmic ointment is 

applied to try and loosen the oil. Mayonnaise seems to work best to loosen without apparent 

additional irritation to eye. Fluids, supplemented as necessary, may be administered at the 

discretion of the veterinarian.

4. General cleaning: If the turtle appears stable, it is wiped down with vegetable oil and/or 

mayonnaise to loosen the oil and then washed with liquid detergent (e.g., Dawn®) and tap water 

at ambient temperature. A soft scrub brush is used on the larger surfaces and soft toothbrushes 

work well on skin folds around the cloaca and inguinal area. Turtles are thoroughly rinsed and reevaluated. The condition of the skin is better visualized after initial de-oiling.

5. Sensitive areas: Eyes and periorbital tissues are gently wiped with cotton swabs with saline or 

artificial tears or antibiotic ointment. The mouth is opened and the oral cavity and cranial 

esophagus are cleaned using a cotton gauze tightly clamped in a hemostat with a small coating of 

vegetable oil or mayonnaise. Depending on the degree of oiling, several or many oil/mayonnaise

gauzes may be needed to clean the esophagus.

6. Internal oiling: A mixture of 2 to 3 parts mayonnaise and 1 part cod liver oil may be administered 

by lavage if oil ingestion is suspected.

7. Perform daily rechecks including notation of appetite, attitude, feces, activity, etc. The 

CBC/plasma chemistry should be repeated in 10 days to 2 weeks, or earlier as necessary.
160

Criteria for medical clearance of oiled sea turtles for release 

The intent of these guidelines is to provide sound criteria for medical clearance of sea turtles in 

rehabilitation facilities such that they are expected to survive upon release back into the wild. The 

locations and manner of reintroductions will be determined by the federal permitting authority in 

consultation with experts and will consider the best available information on biology, ecology, as well as 

threat from oil impact. Decisions regarding release strategy are separate from the medical clearance 

criteria, which pertain only to the health status of the individual animal. Once sea turtles meet the 

criteria below, they will be considered eligible for release. Individual criterion may be omitted, in 

addition to those exceptions specifically mentioned below, under emergency situations that require 

expedited release when determined to be in the best interest of animal welfare. 

Normal swimming and 

diving ability1

Animal is bright, alert, active, and does not have any abnormal neurological signs, 

problems swimming or diving, or buoyancy problems. 

Normal feeding behavior Animal is actively feeding and passing feces (consistency and character within 

normal limits) 

Good nutritional 

condition 

Based on external appearance of muscle condition and adipose status, and positive 

trend in body weight during rehabilitation. 

CBC compatible with 

good health 

No anomalies on blood cell counts or morphology based on best available reference 

data or blood parameters otherwise deemed suitable for release.2

Blood chemistries 

consistent with stable 

clinical status 

Blood biochemical parameters are within normal limits based on best available data 

or blood parameters otherwise deemed suitable for release.2 

Resolution of any specific 

clinically diagnosed 

problems 

Resolution may be assessed based on, but not limited to: return of blood values to 

normal limits, healing of any wounds or other anomalies that reasonably may be 

considered a significant threat to survival, resolution of any radiographic 

abnormalities (with the exception of scarring or other persistent effects compatible 

with clinical resolution). 

No medication 

administered for 2 weeks 

Especially antimicrobials, antifungals, and anti-parasitic medications. Does not 

include nutritional supplementation or sedatives. 

1

Ideally, diving ability and buoyancy will be re-assessed at a staging location prior to release if distant transport of 

>6 hours is required. 

2Anomalies in blood values (e.g., calcium and phosphorus) that may be associated with captive conditions will not 

necessarily preclude release. Furthermore, such findings may be used to justify timing of release.
161

Initial supply procurement list for rehabilitation of oiled sea turtles

Item Unit Minimum order 

per facility Per no. of turtlesa

1" wide Tyvek® wristbands - white or light color (to 

write on)- for turtle ID on flipper pack of 500 2 None

1" wide Tyvek® wristbands - red (for ID of 

fibropapilloma turtles around flipper) pack of 500 1 None

Sharpie® permanent marking stick (MeanStreak),

white for turtle ID on carapace Box of 8 1 per 20

Sharpie® red (for ID of fibropapilloma turtles) Box of 8 1 per 20

Tyvek® tags Box of 1000 1 per 20

Dawn® soap (1 gallon bottle) gallon bottles/case of 4 2 cases per 20

Soft tooth brushes Individual 12 per 20

Mayonnaise (in single-use disposable packets) 12 g portion/case of 200 1 per 20

Cod liver oil (17 oz) Individual 6 per 20

Cotton swabs (Q-tip® or similar) Box of 500 1 per 20

Oil absorbent pads (PIG® or similar) Box of 50 1 per 20

Contractor trash bags, 3 mil box of 20 4 per 20

Contractor trash bags, 1.2 mil box of 250 1 per 20

Hazardous sharps containers, small (5 quarts or 

more) Individual 4 per 20

Nylabone® - Giant size (for turtle mouth opening) Individual 1 None

Nylabone® - wolf size Individual 1 None

Nylabon®e - regular size Individual 1 None

Nylabone® - petite size Individual 2 None

Oral (beak) speculum for birds, medium Individual 2 None

Oral (beak) speculum for birds, large Individual 2 None

Compression bags for fluids Individual 1 None

Sterile syringes, 1ml, MonojectTM brand Pack of 100 2 per 20

Sterile syringes, 3ml, MonojectTM brand Pack of 100 2 per 20

Sterile syringes, 6ml, MonojectTM brand Pack of 100 1 per 20

Sterile syringes, 12 ml MonojectTM brand Pack of 40 1 per 20

Sterile syringes, 20 ml MonojectTM brand Pack of 40 1 per 20

Sterile syringes, 60 ml MonojectTM brand (cath tip) Pack of 40 1 per 20

MonojectTM hypodermic needles 20G x 1-1/2” Box of 100 2 per 20

MonojectTM hypodermic needles 22G x 1-1/2” Box of 100 2 per 20

MonojectTM hypodermic needles 23G x 1" Box of 100 2 per 20

MonojectTM hypodermic needles 25G x 1" Box of 100 2 per 20

10 drop/ml extension sets Individual 50 per 20

Chlorhexidine solution (1 gallon) Individual 5 per 20

Isopropyl alcohol (1 gallon) Individual 2 per 20

23G winged infusion sets Individual 50 per 20

Betadine surgical scrub (1 gallon) Individual 2 per 20

Roccal-D® Solution (1 gallon) Individual 2 per 20

a

The number of turtles the order volume will accommodate. The order should be repeated for every incremental 

increase of this number of animals. “None” indicates a one-time purchase for each facility. This list may be 

modified / amended for specific spills and for resupply during prolonged events.
162

Item Unit Minimum order 

per facility Per no. of turtles

Green top Vacutainer® tubes 3 ml pack of 100 1 per 20

Red top Vacutainer® tubes 3 ml pack of 100 1 per 20

Green top Vacutainer® tubes 6 ml pack of 100 1 per 20

Red top Vacutainers® tubes 6 ml pack of 100 1 per 20

Alcohol Prep pads - medium size box of 200 1 per 20

TegadermTM 15 x 20” Box of 50 2 per 20

4 x 4” Gauze pad case of 1200 5 per 20

Fluorescein eye stain Box of 300 1 None

KY jelly® (4 oz tube) Individual 5 per 20

Vet Wrap® case of 18 rolls 1 per 20

Elasticon® tape box of 4 1 per 20

Red rubber catheter tubes (12Fr) Pack of 100 1 per 20

Red rubber catheter tubes (12Fr) Pack of 100 1 per 20

Lactated Ringers Solution 1000 ml Individual 25 per 20

0.9% NaCl 1000 ml Individual 25 per 20

Sodium Bicarbonate 8.4% (50 ml bottle) Individual 10 per 20

Calcium gluconate 23% (500 ml bottle) Individual 1 per 20

Potassium chloride (10 ml bottles) Tray of 25 1 per 20

Epinephrine (30 ml) Individual 1 per 20

Atropine sulfate (100 ml) Individual 1 per 20

Dexamethasone (100 ml) Individual 1 per 20

50% Dextrose (50 ml) Individual 5 per 20

Fortaz® (ceftazidime) 2 gm vials Individual 25 per 20

Metronidazole (oral) 250 mg tablets Individual 1 per 20

Sporamox® (itraconazole) 10 mg/ml Individual 5 per 20

Triple antibiotic ointment tubes Individual 50 per 20

Puralube® ophthalmic ointment Individual 50 per 20

B-Complex injectable 100 ml Individual 2 per 20

Sterile Water for Irrigation 1000 ml Individual 20 per 20

Sterile NaCl for Irrigation 1000 ml Individual 20 per 20

Powder-free Nitrile gloves, small case of 1000 1 cases per 20

Powder-free Nitrile gloves, medium case of 1000 4 cases per 20

Powder-free Nitrile gloves, large case of 1000 1 cases per 20

Safety goggles Individual 10 None

Tyvek® suits, medium case of 25 3 per 20

Tyvek® suits, large case of 25 2 per 20

Tyvek® suits, extra-large case of 25 1 per 20

Masks (Duckbill or with respirator) 1 box of 20 2 per 20

Sharpie® marker, fine point Box of 12 1 per 20

Sharpie® marker, extra fine point Box of 12 1 per 20

Clipboards, Redi-rite® stainless w/pencil storage Individual 10 None

Dry Erase board, 24 x 36" Individual 1 per 20

Dry Erase Markers assorted colors Multi-pack 1 per 20
163

Item Unit Minimum order 

per facility Per no. of turtles

Formalin 10% buffered, 5 gal cube Individual 1 None

Evidence strips 6 1/2 x 1 1/4", 100 strips Individual 3 per 20

Evidence box sealing tape, 3" wide Individual 10 per 20

Write-on bags, 4 x 6”, 2 mil case of 1000 1 None

Write-on bags, 6 x 9”, 2 mil case of 1000 1 None

Write-on bags, 9 x 12”, 2 mil case of 1000 1 None

Cryovials® (2 ml) case of 250 2 None

Cryovials® (4 ml) case of 250 2 None

Cryovial boxes case of 10 1 None

I-chemTM 300 series (20ml, clear) case of 72 2 None

I-chemTM 300 series (20 ml, amber) case of 72 1 None

I-chemTM 300 series (125 ml, clear) Case of 24 10 None

Aluminum foil (1000') Individual rolls 5 per 20

Wooden tongue depressors 6” Pack of 100 10 per 20
164

Live Oiled Sea Turtle Intake Form
165

Live Sea Turtle Intake Log
166
167

Dead Sea Turtle Intake Log
168
169

Appendix 12: Necropsy (postmortem examination)

Included in this Appendix are the Sea Turtle Gross Necropsy Report and Sea Turtle Necropsy Sample 

Checklist. The forms guide a systematic postmortem examination and collection of samples that are 

routinely analyzed for assessment of compounds of interest during oil spills. These forms may be 

amended as necessary for specific conditions or considerations related to individual spill events. In 

addition to these forms, a final necropsy report, in the format of choice used by the veterinarian of 

record (designated by NOAA/USFWS), will be produced and may include the following: 1) a written 

description of gross findings, gross/provisional diagnoses; 2) histological findings (depending on 

postmortem condition); 3) a list of any ancillary diagnostic tests and results, final diagnoses, cause of 

death determination; and 4) any comments related to assessment, diagnoses, or interpretation of 

findings.

Also provided in this Appendix is a list of supplies necessary to conduct necropsies and sample fluids 

and tissues for oil and dispersant-related compounds. Amounts required for an initial order and scale for 

resupply are indicated, but will depend on life stages, postmortem conditions, and other specific 

circumstances. Equipment already possessed by most facilities capable of performing necropsies (e.g., 

knives, saws, scales) is not included.

Decontamination of non-disposable instruments

Instruments used for oil or PAH sampling need to be thoroughly washed and decontaminated after each 

use. Do not reuse an instrument without decontamination, even for collection of samples from the same 

animal as cross-contamination can create erroneous results. Note that the washing process requires 

time for drying. It is best to plan ahead for sampling needs and have several sets of instruments on 

hand. The decontamination procedures must be done using metal or glass containers; the instruments 

must not come into contain with any plastics. 

1. Thoroughly clean instruments using a high-quality detergent (Alconox® or similar)

2. Rinse and dry thoroughly

3. Thoroughly rinse the instruments using 99.9% pesticide-free isopropanol

4. Allow to dry completely prior to use
170

Photodocumentation during necropsy

Each examination is carefully photo-documented using the following instructions (see examples below):

1. Make a photo identification placard (e.g., using a dry erase board or similar) that includes the

turtle’s identifier, species, date, name of the examiner, and time that the examination begins.

2. Photograph the placard as the first photo for the examination (A). Include a ruler or other scale

in photographs, if possible, but do not obscure the subject. If in doubt, take photos with and

without an internal scale.

3. Photograph all parts of the body, including complete images of the dorsum (B), ventrum (C),

and an oblique photo showing the neck and shoulder region (D).

4. Photograph any external oil or suspicious substance prior to sampling. Take close-up images of

any injuries or other external abnormalities.

5. Following removal of the plastron, photograph the pectoral musculature and pericoelomic fat

to demonstrate nutritional condition (E).

6. Carefully photograph any oil or suspicious material within the oral cavity or digestive tract (F),

as well as any internal abnormalities. Oil tends to adhere to any keratinized epithelium, thus it

frequently will coat the mouth or esophagus if oil has been ingested.

7. The final photograph of the necropsy is of the photo placard with the time indicating when the

examination ended (G).

Thus, the complete sequence of photographs of the examination begins and ends with the

photo placard, which helps validate the origin and content of the images.

First

Last
171

Supply procurement list for sea turtle necropsies

Item Unit Minimum order per 

facility Resupplya

Powder-free Nitrile gloves, small case of 1000 1 per 100 

Powder-free Nitrile gloves, medium case of 1000 1 per 100 

Powder-free Nitrile gloves, large case of 1000 1 per 100 

Sharpie® markers (12 per box) box of 12 1 per 100

Cable ties case of 1000 1 per 500

Tyvek® tags case of 1000 1 per 500

Contractor bags, 3 mil box of 20 4 per 50

Contractor bags, 1.2 mil box of 250 1 per 100

Write on bags, 4 x 6”, 2 mil case of 1000 1 per 100

Write on bags, 6 x 9”, 2 mil case of 1000 1 per 100

Write on bags, 9 x 12”, 2 mil case of 1000 1 per 100

Cryovials® (2 ml) case of 250 2 per 100

Cryovials® (4 ml) case of 250 2 per 100

Cryovial® boxes case of 10 1 per 100

Glass syringe 5 ml Individual 5 None

Sterile syringes, 3 ml, MonojectTM brand, luer lock box of 200 1 per 500

MonojectTM hypodermic needles 20G x 1” box of 100 1 per 50

I-chemTM 300 series (20 ml, clear) case of 72 4 per 50

I-chemTM 300 series (20 ml, amber) case of 72 1 per 50

I-chemTM 300 series (125 ml, clear) Case of 24 25 per 50

Cotton tipped applicators, sterile pack of 200 1 per 500

Microscope slides pack of 144 1 per 100

Red biohazard bags pack of 100 1 per 100

Aluminum foil (1000') individual roll 2 per 50

Culture swabs pack of 50 1 per 100

Scalpel blades pack of 100 4 per 50

Alcanox® detergent Case of 9 boxes 1 per 100

Isopropanol (99% pesticide free) 4L bottle 1 per 50

Ethanol, biotech grade 4L bottle 1 per 500

Formalin, 10% neutral phosphate buffered 20L cube 1 per 50

Cal-Ex® 10L cube 1 per 500

Tissue cassettes case of 1500 1 per 100

Razor blades pack of 100 10 per 100

Tissue cassette markers pack of 12 1 per 100

Formalin containers, 1 L case of 100 1 per 50

Formalin containers, 5 L case of 10 1 per 50

Bleach (1 gal) individual bottle 5 per 50

Simple Green® (1 gallon) individual bottle 5 per 50

Roccal-D® (1 gallon) individual bottle 1 per 50

Dawn® soap (56 oz) individual bottle 2 per 50

DVDs pack of 100 2 per 50

CD/DVD labels pack of 300 1 per 150

CD sleeves pack of 50 2 per 50

File folders, 1/3 tab w fasteners pack of 50 1 per 50

a

The number of turtles the order volume will accommodate. The order should be repeated for every incremental 

increase of this number of animals. “None” indicates a one-time purchase for each facility. This list may be 

modified / amended for specific spills and for resupply during prolonged events.
172

Gross Necropsy Form
173
174
175
176

Necropsy Sample Checklist
177

Appendix 13: Release of de-oiled and non-oiled sea turtles

All live sea turtles collected during the spill events are intended for release back into the wild, 

whether they were oiled or not. Turtles that are cleared for release by the attending veterinarian are 

candidates for immediate release. The goal is to return turtles to the wild, as soon as possible following 

medical clearance and once environmental conditions are conducive to their long-term survival.

Decisions on the timing and location of release are made by the federal permitting authorities 

(NOAA/USFWS) and coordinated with the Unified Command (if release is during active spill response 

operations), particularly if any media will be present.

Release options, discussion, and evaluation

Option A: Release at or near original stranding or capture location(s). 

In order to release stranded turtles at or near the original site of collection, the following conditions 

must be met at the proposed release area:

1. Containment of the spill source.

2. Absence of recoverable surface oil as determined by aerial and/or shipboard observation and as 

demonstrated by absence of clean-up operations to recover surface oil.

3. Opening of prior fishing closures to harvest of fish and invertebrates for human consumption (as 

a proxy for food web evaluation).

Option B: Release in habitat(s) away from stranding or capture location(s).

If the aforementioned criteria (for release at or near stranding location) are not met at the time of 

medical clearance, turtles may be released at an alternative location that is deemed not to be under

threat from an oil spill. Sea turtles of the same species (preferably the same recovery unit/genetic 

subpopulation) and life stage must be known to occur at the proposed release site. Propensity for 

turtles to return to original areas of capture should be anticipated for neritic phase turtles, thus release 

should be timed such that risk of exposure at the original area of collection is minimal should the turtle 

return. 

In addition, sea turtles captured during transitional phases of their life history (hatchlings, posthatchlings, oceanic juveniles) may require alternative release locations that are biologically suitable for 

their size at the time of release. Selected habitat and locations must be known to contain sea turtles of 

the same species and size class.
178

Safe handling and release protocols

Guidelines for safe transportation of sea turtles should be followed at all times. The PIT tag number 

and other identifier for each turtle are recorded prior to release along with the release location 

(latitude/longitude). A log should be prepared in advance and each animal checked off as it is released.

Once turtles arrive at the designated release location the following measures are implemented:

Shoreline releases:

 Hatchlings: In general, releases should occur at night. At the time of release, hatchlings should be 

placed on the beach at a distance from the waterline that is roughly equivalent to the original nest 

site (if free from oil) and allowed to crawl to the water on their own. Flashlights or other artificial 

lights may not be utilized during hatchling releases. A quick check of the release area with a small 

flashlight fitted with a red LED light source or red filter that eliminates short wavelength light a short 

time after release will ensure that all hatchlings have reached the water. Occasionally, individual 

hatchlings may need assistance in reaching the water. In such cases, they may be moved closer to the 

water or placed in the shallows and allowed to swim off on their own.

 Juveniles and adults: Place turtle at the water’s edge or directly in the water. Do not make animals 

crawl across land to reach water. Do not allow onlookers to crowd around animals or to position 

themselves between the turtle and open water.

At-sea releases:

 If turtles are aboard multiple release vessels: release animals from one vessel at a time, so that all 

vessel operators are aware of where turtles are being released. If multiple release vessels are 

involved, the lead sea turtle biologist shall direct the order of release and the location of all vessels, 

including press, during release.

 All vessel engines (both the releasing vessel and observing vessels) shall be in neutral, preferably 

turned off, during the release.

 For releases of multiple turtles, animals should be spread out along the line, not released all in one 

location.

 Turtles shall be removed from their respective transport bins and placed immediately by hand into 

the water. Turtles shall not be handled by media personnel, held out of the water once taken from 

the holding bin, or dropped into the water from any height.

 Newly released turtles should be observed for a sufficient time period to ensure they are behaving 

normally.

 Vessels must exercise extreme caution when departing the release location to ensure released turtles 

are clear of the area.

General:

Any turtle that does not dive or exhibits any indication of a persistent abnormality should be 

recaptured for additional evaluation and rehabilitation. All release vessels should be equipped with a dip 

net of suitable size to recapture released turtles. 
179

Appendix 14: Nesting beaches

Sea turtle nesting beach survey and turtle/nest protection protocols

This document addresses loggerhead (Caretta caretta), green (Chelonia mydas), hawksbill 

(Eretmochelys imbricata), Kemp’s ridley (Lepidochelys kempii), and leatherback (Dermochelys coriacea) 

sea turtle nesting beach surveys and turtle and nest protection efforts on beaches where regular nesting 

surveys are conducted. If the protocols in this appendix conflict with the permitted procedures in a 

particular area, then the permitted actives will take priority under the guidance by USFWS in 

consultation with the Sea Turtle Group Lead. Pertinent contact information for notification of nests and 

related activities should be added to the protocols below.

Protocol: Conducting nesting beach surveys

Until such time as beaches are officially identified and designated as “oiled,” nesting surveys will 

proceed as usual in accordance with existing sea turtle permitting guidelines. If oil is present on beach 

and the beach has been identified for clean-up activities, sea turtle permit holders must comply with any 

hazardous material training requirements communicated from the Unified Command. Every effort will 

be made to ensure continued cooperation with the nesting survey network and to ensure continuity of 

the survey and nest inventory methods.

Protocol: Encountering nesting sea turtles and/or exposed eggs on the beach

If a nesting sea turtle is encountered on the beach while a sea turtle permit holder is conducting 

normal activities authorized under their existing sea turtle permits, the turtle should be observed to 

assess its behavior and condition after egg laying while she is covering her nest. Females that appear 

weak or injured might not complete the nesting process or may drop eggs on the beach. If a turtle has 

not yet nested or is in the process of nesting, then wait to check her condition. She may still be able to 

lay a clutch even in a distressed condition. The turtle should not be approached until nesting activities 

have been completed and she is returning to the water. If the nesting female appears to be oiled or in 

distress, please contact the regular stranding hotline for the State/Territory in which the turtle is located 

as indicated below.

Any uncovered eggs in a nest on the beach should be carefully covered with damp sand. Loose eggs 

on the sand surface may be retrieved and properly buried on the beach in accordance with the nest 

relocation protocols in the existing sea turtle permitting guidelines. The nest should be marked in 

accordance with the Nest Marking protocols below.

Protocol: Protecting nests

Nest Cleaning

During daily surveys, if oil and/or tarballs or tar mats are evident on the beach, please call the 

number identified for the State in which the nest is located; these organizations will in turn contact the 

local Incident Command System Hazmat clean-up crew to request the oil and/or tarballs and tar mats be 
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removed. Only designated Hazmat clean-up crew members can remove oil and tar materials from the 

beach.

Upon arrival at the scene, the designated Hazmat clean-up crew will follow the Sea Turtle Nest 

Protection Protocols for Clean-up Crews on Beaches (attached) to minimize the likelihood of impacts to 

incubating nests and turtles on the beach.

Nest Relocation

During an oil spill, determinations regarding relocation of nests to protect them from oil impacts will 

be made by USFWS in consultation with the Sea Turtle Group Lead. The presence of oil and/or tarballs 

and tar mats on a beach in and of itself does not justify nest relocation. If a nest meets the standard 

criteria for relocation, it should be moved to an oil-free location and away from the path of clean-up 

activities, in accordance with the sea turtle permitting guidelines referenced above.

Nest Marking

Nest marking will proceed in accordance with the existing sea turtle permitting guidelines. The goal 

of this marking method is to clearly identify the nest area and protect it from response activities. 

Visually inspect the site to determine whether a nest exists. Nests should not be dug into simply to verify 

the presence of eggs. The entire disturbed area (where digging has occurred) should be delineated with 

stakes. Nest site must be marked with a radius of at least three feet or up to ten feet, depending on the 

width of the beach, centered at the approximate location of the clutch. The stakes should extend about 

36" above the sand. To further identify the nest site, surveyor's ribbon can be tied from the top of one 

stake to another to create a perimeter around the nest site. Additionally, a nest sign can be attached to 

one of the stakes used to create the perimeter (contact information on signs). A nest-identifying number 

should be indicated on at least one of the nest perimeter stakes. 

Protocol: Marking nests to determine hatching success

Mark nests so that you can locate the clutch even if no hatchling emergences occur. Triangulation 

requires measuring the exact distance from the approximate clutch location to two separate marking 

stakes on the dune that are aligned so that a straight line between them orients directly toward the 

location of the clutch (Figure A14-1). Both stakes should be labeled with an identifying nest number. As 

added insurance, an aluminum marker can be buried by hand approximately hand-deep and 24" from 

the approximate clutch location in a standardized direction on either side of the nest. This metal marker 

can be found later with a metal detector. The measured-distance marking stakes should be used to find 

the egg chamber location by extending the tape to the previously recorded distance between each stake 

and the clutch (measured at ground level) and making a large arc in the sand. The clutch will be found 

where the arcs cross in the sand.

Nest inventory is the evaluation of the contents of a nest. Nest inventories should be conducted in 

accordance with sea turtle permitting guidelines and entered onto a Nest Inventory Data Sheet. A nest 

inventory may only be conducted either 72 hours after the first sign of emergence or 70 days after the 

eggs were deposited (80 days for leatherbacks), whichever occurs first. Inventory of nests may be 

conducted under NRDA or as part of any pre-existing, permitted monitoring effort.
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All marked nests should be checked daily to ensure that marking materials remain in place and are 

intact and to determine whether oil or tar is present. In the event that nest markers are lost due to high 

tides or storms, the sea turtle permit holder shall coordinate with the sea turtle permitting agency to reestablish the nest location using the secondary dune or landward markers and existing landmarks, and 

confirm the location using existing GPS readings.

Nest Caging

If there are concerns that emerging hatchlings may depart from the nesting beach and encounter oil 

in the water, nests may need to be screened with restraining cages to enable collection and relocation

of hatchlings. If caging is necessary, caged nests must be monitored regularly beginning at 40 days from 

egg deposition. 

Determinations regarding the disposition of hatchlings (i.e., allow to enter the ocean at the nest site 

or collect and release hatchlings elsewhere) will be made by USFWS in consultation with the Sea Turtle 

Group Lead.

Dune or Seawall

Water

Nest

A-1

A-2

B-1

B-2

Figure A14-1. Site A stakes are directly landward of the 

nest in dune vegetation or at the base of a seawall. Site B 

stakes are in a similar position as Site A but located at an 

angle from the nest. Stakes A-1 and B-1 should be sunk 

deeply so that they are not conspicuous to someone not 

looking for them. Precisely measure the distance from 

stakes to the clutch location. Then, sink additional stakes 

(A-2 and B-2) directly between the clutch and the dune 

stake(s).
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Sea turtle hatchling encounter protocol for beach clean-up crews

Encountering sea turtle hatchlings on the beach 

Unmarked sea turtle nests may exist on some beaches and clean-up crews may encounter hatchlings 

from these nests. If sea turtle hatchlings are encountered on the beach, please follow the guidelines 

listed below:

1. All hatchlings must be allowed to crawl to the water undisturbed.

2. If hatchlings will emerge onto an oiled beach or water, place hatchling(s) in a clean, rigid container, 

more than 10-inches deep, lined with damp (not wet), unoiled sand, and loosely covered with a lid 

or towel to provide a dark environment while allowing for air flow. Any containers housing turtles 

should not contain any material that could be accidentally ingested. 

3. Do not place the hatchling(s) in water.

4. No more than 15 hatchlings should be placed together in a single container.

5. The descriptive location of the hatchling(s), including the GPS location, should be recorded; avoid 

obscuring any hatchling tracks so that the nest can be visually relocated if necessary.

6. The container should be shaded and otherwise protected from extremes of heat and cold (not above 

90°F and not below 50°F). 

Immediately contact the regular stranding hotline for the State in which the hatchlings were located

[INSERT CONTACT INFORMATION].
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Nest Inventory Data Sheet
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Appendix 15: Best management practices to protect sea turtles during response 

operations

Best management practices to protect sea turtles during in-situ burn operations

Sea turtles can be adversely affected during corralling/booming of oil and oiled floating Sargassum

seaweed or other converged material. Turtles may also be in the oil whether or not there is Sargassum

present. The concern with in-situ burning is that any live turtles in the boomed oil and/or oiled 

Sargassum or other converged material could potentially be burned when the oil is ignited.

Best management practices to reduce in-situ burns impacts to sea turtles

 Collect all live and dead turtles according to the Retrieval of Oiled, Dead, or Debilitated Sea 

Turtles Protocol whenever possible.

 The best possible mitigation measure is to have turtle rescue vessels (with trained rescue 

personnel, if available) accompany the burn taskforce into the scheduled burn area and to 

search all material to rescue turtles prior to burning, while oil is being boomed or otherwise is 

awaiting burning. If this is not possible then the following should be considered:

o Send turtle rescue vessels (with trained rescue personnel, if available) into the next 

day's projected burn area to search for and rescue turtles. Feasibility will depend on the 

size of the projected area and whether material has already been boomed or otherwise 

collected.

o Have a trained observer (if available) or a crew member dedicated to looking for sea 

turtles (as well as marine mammals and other taxa) during corralling operations and 

record each sighting event, including GPS location, species (if known), description of

encounter on the Sea Turtle Observation Form.

o Have a trained observer on board the ignition or support vessel (or other small vessel 

carrying the observer) to visually inspect each portion prior to ignition. Note that it may 

be difficult to see turtles in thick corralled oil, so multiple observers, searching from 

different angles, would be ideal.

o Immediately report any wildlife within the burn area to [INSERT CONTACT 

INFORMATION].

o If possible, all Sargassum that is not-oiled or is only very lightly oiled should be avoided.

o If possible, a survey should be conducted in the burn area after the burn is complete 

and all dead sea turtles should be counted and collected, or at least photographed.
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Best management practices to protect sea turtles during skimming operations

Use of oil skimmers can adversely affect sea turtles through possible capture and/or entrainment.

Best management practices to reduce skimmer impacts to sea turtles

 Collect all live and dead turtles according to the Retrieval of Oiled, Dead, or Debilitated Sea 

Turtles Protocol whenever possible.

 The best possible mitigation measure is to have turtle rescue vessels (with trained rescue 

personnel, if available) accompany the skimming taskforce to search all material to rescue 

turtles prior to skimming. If this is not possible then the following should be considered:

o Send turtle rescue vessels (with trained rescue personnel, if available) into the next 

day's projected area to search for and rescue turtles. Feasibility will depend on the size 

of the projected area and whether material has already been boomed or otherwise 

collected.

o Have a trained observer (if available) or a crew member dedicated to looking for sea 

turtles (as well as marine mammals and other taxa) during skimming operations and 

record each sighting event, including GPS location, species (if known), description of

encounter on the Sea Turtle Observation Form. 

o Immediately report any sea turtles to [INSERT CONTACT INFORMATION].

o If possible, all Sargassum that is not-oiled or is only very lightly oiled should be avoided.
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Best management practices to protect sea turtle nests from beach clean-up operations 

Included are two protocols related to protection of sea turtle nests: 1) instructions for clean-up 

operations on nesting beaches that are actively monitored by sea turtle programs; and 2) instructions 

for clean-up operations on beaches that are not regularly monitored for sea turtle nests. In addition, in 

the event of a spill, these protocols will be accompanied by a list of all nesting beaches within the spill 

area where daily surveys are performed and relevant contact information. Note: alternative BMP’s are 

required for the state of Texas during nesting season because Kemp’s ridley turtles regularly nest during 

the day.

Protocol 1: For beaches where nesting surveys are conducted daily: 

1. Clean-up activities are restricted to full daylight time only.

2. Ensure daily sea turtle nesting surveys by sea turtle permit holders have been completed before 

work begins each morning. The clean-up crew leader must contact the appropriate individual 

identified on the attached list (or his/her designee) daily to determine if nesting surveys have 

been completed and clean-up activities can begin.

3. Sea turtles may still be nesting or hatchlings may emerge after sunrise, so it is imperative that 

clean-up crews watch for nesting and hatchling turtles while they are on the beach and 

immediately cease activities in the immediate area and report the event to the individual 

identified on the attached list (or his/her designee). Clean-up vehicles should travel slowly to 

enable a better opportunity to spot turtle crawls and avoid colliding with nesting and hatchling 

turtles.

4. Nesting turtles should not be approached, and all vehicles and personnel must remain a 

minimum of 50 feet away until the turtle has re-entered the water. If hatchlings are 

encountered, personnel and vehicles should stop all activity until all hatchlings have safely 

entered the surf.

5. Look for any marked nests before beginning beach cleaning activities in an area. Nests will be 

marked with at least eight stakes, four around the nest perimeter and four more around a 10-

foot buffer zone (Figure A15-1). Do not remove or destroy any stakes or flagging, even if they 

are up in the dune. These may be back-up stakes that were placed to ensure that a nest can be 

found at a later date should the nest perimeter stakes be lost.

6. No mechanical equipment or hand tools should be used within the flagged buffer area of a nest.

7. Removal of contaminated sand over a nest should occur only under the direction of the sea 

turtle permit holder. In such cases, clean-up crews should gently remove contaminated sand 

within the flagged area of a nest by hand and replace it with clean, sand taken from an area 

adjacent to the flagged nest area. The surface layer of oiled sand should be removed only to the 

minimum depth necessary without impacting the top of the nest. If nest flagging was removed 

to access the nest area, it must be securely replaced after clean-up activities have been 

completed.

8. All excavations and temporary alteration of beach topography shall be filled, covered, or leveled 

to the natural beach profile prior to 8:00 p.m. each day.
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NOTE: If the clean-up crew observes signs that the turtle dug into the sand, contact the permit 

holder immediately. Under no circumstances should stakes be driven into the sand within the 

disturbed area created by the turtle

Figure A15-1. Marked sea turtle nest.
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Protocol 2: For beaches where nesting surveys are not conducted or are not conducted daily: 

Note: Every effort is made to conduct daily nesting surveys in the area of the spill/clean up area. If the 

area is not easily accessible to conduct daily nesting surveys, a sea turtle permit holder will accompany 

the clean-up crew.

1. Clean-up activities are restricted to full daylight time only.

2. Sea turtles may still be nesting or hatchlings may emerge after sunrise, so it is imperative that 

clean-up crews watch for nesting and hatchling turtles while they are on the beach and 

immediately cease activities in the immediate area and report the event to the individual 

identified on the attached list (or his/her designee). Nesting turtles should not be approached, 

and all vehicles and personnel must remain a minimum of 50 feet away until the turtle has reentered the water. If hatchlings are encountered, personnel and vehicles should stop all activity 

until all hatchlings have safely entered the surf. Clean-up vehicles should travel slowly to enable 

a better opportunity to spot turtle crawls and avoid colliding with nesting and hatchling turtles.

3. Ensure a sea turtle nesting survey by sea turtle permit holders have been completed before 

beginning beach cleaning activities in an area. [In some cases, there may be marked nests on 

some partially surveyed beaches (steps 1-6 on the preceding page should be followed for 

existing nests).]

4. Follow any turtle crawls and look for signs that the turtle dug into the sand (Figure A15-2). Using 

stakes and two layers of flagging, mark the entire disturbed area created by a turtle digging

(Figure A15-3). Under no circumstances should stakes be driven into the sand within the 

disturbed area created by the turtle.

5. Follow Steps 5-6 in Protocol 1.

6. All excavations and temporary alteration of beach topography shall be filled, covered, or leveled 

to the natural beach profile prior to 8:00 p.m. each day.
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ATTACHMENT

SURVEYED BEACHES AND SEA TURTLE CONTACTS*

SURVEYED BEACHES CONTACT NAME PHONE NUMBER

To be completed for spills within sea turtle nesting areas using current names and contact information.

*If the beach to be cleaned is not identified on the above list or does not fall within a County where all beaches are surveyed,

then clean-up crews should follow Protocol 2. If you have any questions about whether a beach is surveyed or not, contact

[INSERT CONTACT INFORMATION].

Figure A15-2. Examples of sea turtle crawls (tracks).

Figure A15-3. Marked sea turtle nest. Note that a second band of flagging 

should be added to clearly indicate the nesting area.
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Appendix 16: Memoranda of Understanding/Agreements relevant to sea turtles 

and oil spill response activities

Memorandum of Agreement: Oil spill planning and response and the Endangered 

Species Act of 1973
191
192

Memorandum of Understanding: National Marine Fisheries Service and U.S. Fish and 

Wildlife Service joint jurisdiction over sea turtles
193
194
195
196
197