(most likely to affect sea otters that could 

 ingest oil in the process of grooming and eating 

 shellfish from contaminated shellfish beds, baleen 

 whales whose food-filtering baleen plates may be 

 fouled by oil and cause large quantities of oil 

 and oil-contaminated food to be ingested, and 

 seals and sea lions that feed on fish that become 

 easier to catch because oiling affects their 

 ability to evade capture) ; 



disruption of mother-pup bonds or transport of 

 toxic substances from parent to offspring through 

 the mother's milk and from the skin or fur of an 

 oiled mother (nursing seal, sea lion, and sea 

 otter pups and cetacean calves) ; and 



increased vulnerability to predation (sea otters, 

 sea lions, and seals preyed upon by killer whales, 

 sharks, and eagles) . 



The Commission further noted that long-term effects on all 

 species may include such things as premature pupping, increased 

 incidence of spontaneous abortion, congenital and genetic birth 

 defects, mortality, and morbidity. These could be caused by such 

 things as direct exposure to toxic dispersant and hydrocarbon 

 compounds, eating fish and shellfish that have picked up and 

 accumulated toxic compounds by absorption or ingestion of tainted 

 prey, starvation due to reduction of food supplies, and 

 destruction of kelp beds which may be essential for successful 

 rearing of sea otter pups. 



In its letter to the Services, the Commission outlined 

 several different types of required response actions, including: 



(1) where possible, animals in danger of death due to contact 

 with oil must be located, cleaned, rehabilitated, and held 

 until fit for release either at the original capture sites 

 once the spill is cleaned up or in new, uncontaminated 

 areas ; 



(2) beach, boat, and aerial surveys must be conducted to 

 document when, where, and how many animals may have been 

 exposed to spilled oil, and how many were killed or 

 debilitated by the contact; 



(3) complete necropsies, including histopathology, toxicological 

 screens, and stomach content analysis, must be done on 

 representative samples of all species found dead in or near 

 areas exposed to oil or dispersants to document cause of 

 death; 



77 



