Justification of change for OMB Control No. 0648-0387

JUSTIFICATION OF CHANGE
INTERNATIONAL DOLPHIN CONSERVATION PROGRAM
OMB CONTROL NO. 0648-0387
The Tuna Tracking & Verification Program (TTVP) intends to request voluntary collaboration
with middle, junior, and high schools across the country. Interested science teachers and
students will be asked to volunteer to purchase cans and pouches of tuna at their local retail
markets and forward the samples (the individual cans or pouches of tuna) to the TTVP. Once the
samples are received by the TTVP, the remaining portion of the program’s usual spot check
audit will be conducted by contacting distributors or manufacturers of these samples to supply
documentation (as already described in the approved collection) which supports the dolphin-safe
claim found on the product.
It is expected that up to a maximum of 50 schools may participate each year. For each
participating school, a science teacher will ask for 1 – 2 students to volunteer to purchase 2 tuna
cans or pouches. Information on where the samples were purchased, when, & how much they
cost (this is usually found on the included receipt) will also be requested. It will be optional for
each school to send photos of the class participation for eventual inclusion on the
DolphinSafe.Gov website. The teachers and students will not be reimbursed for their purchases.
However, TTVP promotional material may be sent to each participating school, as well as ageappropriate curriculum for use in their class.
Additional Respondents and Responses
Although there will probably be no more than 15-25 schools participating per year, we are
requesting approval for up to 50 schools. Thus, the maximum number of respondents and
responses is 150 (i.e. 50 schools x 2 student respondents/responses per school + 1 teacher
respondent/response per school).
Additional Burden Hours
Thirty minutes per student respondent x 100 student respondents = 50 estimated annual hours of
burden to the public, for tuna purchases.
Thirty minutes per teacher respondent for packaging & shipping samples back to the TTVP x 50
teachers = 25 additional hours estimated annual hours of burden.
50 hours for purchases + 25 hours for shipping = 75 total estimated additional burden hours.
Additional Total Annual Cost Burden to Respondents
Two samples per student respondent x $1.75 per sample = Estimated $3.50 cost per student
respondent.
Fifty schools per year x $3.50 per student respondent x 2 student respondents per school =
Estimated annual maximum cost to the public of $350.
Note – The shipping costs will be covered by the TTVP; thus it is not included as an additional
cost burden to the respondents.

Additional Annual Cost to Federal Government
No additional cost to the Federal Government should be realized. Instead, a substantial cost
savings is expected, since the samples were previously collected via travel trips requiring airfare
purchase, car rental & gas, and per diem expenses.

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