Breaking Down the New CDC Cruise Order
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On Friday, the CDC announced it would be allowing the No-Sail Order to expire at the end of October. With that announcement came a list of requirements that cruise lines and ships would have to meet to resume sailing. In today’s blog, we will take a deeper dive into those requirements and when cruising might resume. The full document we are referencing below can be viewed here (PDF file).
CRUISING WON’T RESUME IMMEDIATELY
The first thing to note is something in the opening paragraph: “(the) CDC will take a phased approach to resuming cruise ship passenger operations in U.S. waters.” As we’ve been saying for months now, the return to the seas will be slow and methodical. This is an important point. The cruise lines will not simply re-start operations and immediately have all ships and itineraries available. It will likely start with a limited number of ships sailing shorter voyages to private islands and limited other destinations. While things could certainly proceed at a faster pace, it is likely that it will take four to six months for the major cruise lines to get all their ships back into service. This is assuming that they meet all the requirements outlined in the CDC document and below. It should be noted that this order applies to any ships that carry 250 or more persons (crew and passengers) who will spend at least 24 hours onboard. (Meaning that this does not apply to passenger ferries, ships under this occupancy number, or day transports.)
PHASE BY PHASE
The steps needed for a safe return to the sea have been categorized into “phases” by the CDC. Here is the overview of these phases:
PHASE ONE – Crew safety, including testing and safeguards designed to protect those who work onboard. Cruise ship operators will also build laboratory capacity necessary to test future passengers
PHASE TWO – Simulated voyages, testing the ability of the ship operators to enact the required protocols and to mitigate the COVID-19 risk
PHASE THREE – Certification of each ship as it meets the requirements necessary to return to service
PHASE FOUR – Return to service in a manner that mitigates COVID-19 risk among passengers, crew, and U.S. communities.
SPECIFICS – PHASE ONE
One of the first things each cruise line must do is submit their plan of action to the CDC. Many have already done this, but the plan must be approved by the CDC before they can move forward. You can see an example of the plans here and here.
The cruise lines must agree to test every crew member on a weekly basis and submit the results to the CDC. The CDC may, at their discretion, change the frequency of such tests and/or conduct oversight of specimen collection and testing.
Crew transfers and new crew arrivals will be done under strict protocols. New crew members will be tested and quarantined until they are cleared. Transfers will only be allowed from ships without any positive tests in the previous 28 days.
SPECIFICS – PHASE TWO
Prior to any simulated voyages, the cruise line must receive approval from port and local health authorities for any places in the U.S. where the ship intends to dock. This agreement must include a plan for where sick passengers or crew would be taken (which hospital, for example) and also a housing agreement for any potential quarantine needs. The ports and cruise lines must also agree to minimize the number of ships at a port on any given day, as to not overwhelm any local medical or emergency resources should they be needed.
When the simulated voyage or voyages occur, they must meed the following standards:
Before a simulated voyage can occur, the cruise line must submit the specifics of the planned drill to the CDC, including the time and location of the test, the contact information for all parties involved, and a list of procedures to be tested.
SPECIFICS – PHASE THREE
When conditions have been met, the cruise lines may apply for a “Conditional Sailing Certificate” from the CDC. They must submit the following:
Once received by the CDC, the application will be reviewed. If the certificate is issued, the ship can then begin sailing under the conditions outlined in the protocols and in the application. If the application is rejected or incomplete, the CDC will have the cruise line modify the submission to meet the requirements. The CDC may, at any time, inspect the ship or interview any crew member in its service. The cruise lines may also submit modifications and amendments to the CDC to be considered at any time.
SPECIFICS – PHASE FOUR
Once approved, the cruise line must abide by certain rules when booking passengers on an approved voyage. Those conditions include:
Should a voyage be affected by COVID-19, the following procedures must be followed:
WHAT HAPPENS NOW?
An important part of the new order is the requirements over the next 60 days. Here are the highlights of those specifications:
As you can see, there is a lot that needs to be done. The good news is that the cruise lines have been working on many of these procedures for months, so a lot of the heavy lifting has already been done.
The application process for the simulated cruises and for the certification is a questionable point. Just how long will the CDC take to review and approve these applications? One would hope that it would be done in, to quote the CDC’s own words, a “timely manner” but it is more likely that there will be some delays due to these processes.
The issuance of this new order is certainly a step in the right direction. But it cannot be stressed enough that implementing all of these requirements will take time and it is certainly possible that more cruises may have to be canceled or modified. But the path back to the seas is more clear now and the process of implementing it can now begin in earnest.
We look forward to that day.