Comparing JNCC, ACCOBAMS, and BOEM/PSO Guidelines for Marine Mammal Observers
- Virginie Wyss
- Aug 22
- 4 min read
Updated: Sep 20
Introduction
Marine Mammal Observers (MMOs) and Passive Acoustic Monitoring (PAM) operators play a crucial role in protecting marine species during offshore activities such as seismic surveys, pile driving, or offshore wind construction.
Several international guidelines regulate their work, with different requirements depending on the region: JNCC (UK), ACCOBAMS (Mediterranean/Black Sea), and PSO/BOEM (USA – Gulf of Mexico and California).

This article tries to compare these protocols, focusing on exclusion zones, pre-watch, ramp-up, species sensitivity, and observer requirements but as every case is different (different activities, species, depths and so on), please always refer to the updated version of Guidelines. (They can be found at the end of the article).
Exclusion Zones
JNCC (UK): Standard exclusion zone 500m or 1000 m, but can be larger depending of activities and injury zones.
ACCOBAMS: Exclusion zone needs to be dynamically modelled, it is not a set distance.
PSO/BOEM (USA): for geophysical survey it varies between 100m to 1500m depending on species and type of survey. (In some scenarios, an additional buffer zone applies).
For example it could be 200m, 500m or 1500m for baleen whales, sperm whales, beaked whales or Kogia depending on survey type, but 100m to 500m for other species depending on activities.
Pre-watch (Pre-shooting search)
JNCC: Varies between 30 and 60 minutes depending on activities, for geophysical surveys the requirement for 60 minutes watch applies in waters deeper than 200m.
ACCOBAMS: 30 minutes it can be prolonged to 120 minutes if deep divers are present. Beaked whales being the species of concern.
PSO/BOEM USA: usually 30 minutes minimum, extended to 60 minutes in critical habitats or for endangered species.
Soft Start / Ramp-up
JNCC: Gradual increase of source level, usually 20-40 minutes may be 15-25 minutes for some geophysical surveys
ACCOBAMS: Don't specify a ramp-up time other than for sonar.
PSO/BOEM: At least 20 minutes, may be shorter for some survey types
Target Species and Sensitivity
JNCC: General protocol applied to all marine mammals (seals as well as cetaceans)
ACCOBAMS: General protocol applied to all cetaceans, with additionnal mitigation for beaked whales.
PSO/BOEM: Highly species-specific under the Marine Mammal Protection Act (MMPA) and Endangered Species Act (ESA). Includes cetaceans, manatees, and sea turtles.
Observer Requirements
JNCC: Minimum of one MMO (two if operating 24/7). PAM is recommended but not always mandatory.
ACCOBAMS: MMO + PAM are both mandatory, with certified training required.
PSO/BOEM: Protected Species Observers (PSOs) must be trained and approved by BOEM/NOAA. PAM monitoring is mandatory during nighttime operations.
As an MMO/PAM working often in the field I would recommend ideally 3 MMOs and + 1-2 PAM to allow focus and good quality work during a 24h shift.
Shutdown Protocols
JNCC: JNCC currently does not require shutdowns except for marine mammals in the mitigation zone during the soft start of piling. For all other activities, the only requirement is to delay the start of the operations if a marine mammal is in the mitigation zone during prewatch. (Note this might change when the revision of the geophysical survey guideline is published).
ACCOBAMS: for seismic or aiguns source, Shutdown if the marine mammals is within the exclusion zone or if beaked whales are detected. with a mandatory 30-minute clearance before resuming.
PSO/BOEM: Shutdown of geophysical surveys for marine mammals within 100-1500m depending on the species. (shutdowns not required for turtles or some delphinids); for Piling shutdown requirements are project specific.
Summary Table
Criteria | JNCC (UK) | ACCOBAMS (Med/Black Sea) | PSO/BOEM (USA) |
Exclusion zone | 500m or 1000m in general | dynamically modelled, it is not a set distance | 100 m to 1500 m depending on species and activities |
Pre-watch | 30–60 min | 30–120 min (if deep divers around) | 30–60 min depending on species |
Ramp-up | ≥15-25 min or 20-40 min | at least 30 min for sonar; time not specified for other activities | 20 min (may be shorter) |
Target species | All cetaceans and seals | All cetaceans with some additional measures for Beaked whales | Species-specific (MMPA/ESA) (Marine mammal, manatee, sea turtles) |
Observers | MMO mandatory, PAM recommended | MMO + PAM mandatory | Certified PSO (BOEM/NOAA) + PAM at night |
Shutdown | Delays for all operations if marine mammal in mitigation zone, shutdown required only during soft start of piling | yes, if in exclusion zone or if species like beaked whales are detected. | 100–1500 m depending on species and activities |
Training & reporting | Mandatory | Mandatory, ask for a report. | BOEM/NOAA certification + reports |
Conclusion
The three frameworks share a common goal: minimizing acoustic impacts on marine mammals during offshore operations. However:
JNCC provides a general, flexible framework widely adopted worldwide.
ACCOBAMS applies stricter rules in the Mediterranean/Black Sea, emphasizing species sensitivity.
PSO/BOEM (USA) enforces species-specific rules.
Together, these protocols ensure offshore development can proceed while safeguarding vulnerable marine life.
In my opinion, it would be important to include sharks, moonfish and other sensitive species to the guidelines.
If you want to start a career as a Marine Mammal Observer (MMO):
I would say that the JNCC certificate is the one to get first, as it is widely recognised and accepted almost everywhere. The training lasts two days in person: I did mine with Carolyn Barton (who kindly corrected the article🙏🏼 ) in Inverness and Carolyn is very up to date with the regulations.
The course is now also available online.
If you plan to work specifically in the Gulf of Mexico or the Mediterranean, it is wise to obtain the other relevant certifications as well. The PSO certificate requires only half a day of additional training, while the ACCOBAMS certification takes about one full week. However, during the ACCOBAMS courses you will also learn to use PAMGUARD, an acoustic monitoring software, which qualifies you to work as a PAM operator (Passive Acoustic Monitoring) in addition to being an MMO.
Here are the different guidelines for the 19.09.2025 :
ACCOBAMS Guidelines:
For JNCC for geophysical survey
JNCC for Piling activities :
JNCC for unexploded ordnance:
JNCC for the use of PAM in UK waters :
Boem Guidelines.




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