Welcome to Phase 2B of the Centers for Disease Control and Prevention’s Conditional Sail Order! What is Phase 2B, you ask? It’s a set of technical instructions for what cruise lines need to do when conducting simulated voyages in order to test the efficacy of the cruise ship operator’s ability to mitigate the risks of COVID-19 onboard. Earlier this month, the CDC waived the simulated voyages altogether so long as a cruise line requires that 95% of passengers on board are fully vaccinated against COVID-19.
The Technical Instructions for Simulated Voyages by Cruise Ship Operators under CDC’s Framework for Conditional Sailing Order isn’t the most fun read out there, so we boiled down the major points so cruisers can decide if a simulated cruise is the right move for them.
CDC’s Rules for Simulated Cruises
The first thing cruise lines need to do before operating a simulated sailing is make sure they request approval from the CDC at least 30 days prior to the sail date.
This 30-day notice must include the following:
- the dates and location of the simulated sailing
- a written agreement (or a multi-port agreement) with ports and local health authorities where the cruise ship intends to dock or make port during a simulated voyage
- a copy of the cruise ship operator’s proposed written notification to volunteer passengers so they understand the risks involved in participating
- a copy of the cruise ship operator’s proposed informed consent form to be signed by all persons who will be participating as volunteer passengers in the simulated voyage
- provide one or more points of contact for persons who will be overseeing and implementing the proposed simulation for each cruise ship
- provide the protocols or practices to be simulated, which must incorporate the requirements for conducting simulated voyages under these technical instructions
- signatures of the cruise ship operator’s responsible officials: CEO or equivalent, CCO or equivalent and the highest ranking medical officer
Got it? Good, because there’s more. A lot more.
Eligibility for Conducting a Simulated Voyage
Before they can sail, all cruise ship operators must verify that they meet the following eligibility criteria:
- the cruise line’s plan for restart must be determined complete and accurate by the CDC
- the cruise ship operator has continued to submit the Enhanced Data Collection (EDC) form as specified in the CSO.
- the cruise ship operator has observed and continues to observe all elements of the No Sail Order response plan
- the cruise ship operator has arranged for and submitted and continues to arrange for and submit laboratory test results as required by CDC for every crew member on board ships operating in U.S. waters
- if the cruise ship received any ship-to-ship transfers in the last 14 days, crew were only transferred from a cruise ship with no confirmed COVID-19 or COVID-like illness during the 14 days before the transfer occurred
- if the cruise ship received any land-based embarking crew, such crew were laboratory tested for SARS-CoV-2 upon embarkation and quarantined per CDC technical instructions
- establish medical and housing contingencies with each port of call in the event of an outbreak among both crew or passengers.
Okay, so now we’re ready to sail? Not even close.
Requirements For Volunteers
Volunteers for these test cruises can’t just hop on board and have fun. They have a laundry list of protocols and requirements they must adhere to.
- the minimum number of required volunteer passengers for each simulated voyage must be at least 10% of the maximum number of passengers permitted onboard for restricted voyages
- the cruise ship operator must advise volunteer passengers of CDC’s Travel Health Notice for COVID-19 and Cruise Ship Travel prior to the simulated voyage
- all volunteer passengers must be informed in writing that they are participating in a simulation of health and safety protocols that are unproven and untested in the United States for purposes of simulating a cruise ship voyage and that sailing during a pandemic is an inherently risky activity
- all volunteer passengers must be at least eighteen years old or older on the day of the simulation and at the time that their consent to participate is obtained
- volunteers need proof of vaccination or a written documentation from a healthcare provider or self-certified statement that the volunteer passenger has no medical conditions that would make a COVID-19 infection more severe
- the simulation must be conducted with the signed informed consent of all participants and not as a condition of employment or in exchange for consideration or future reward
- all volunteer passengers must be evaluated for signs and symptoms of COVID-19 prior to embarkation and disembarkation
- all volunteer passengers must agree in writing to post-disembarkation specimen collection for COVID-19 testing at 3 to 5 days after completion of the simulated voyage
- to facilitate contact tracing, the cruise ship operator must advise all volunteer passengers to notify the cruise ship operator if they develop symptoms of COVID-19 within 14 days after the voyage
Okay great, now can we cruise? No, the CDC has MORE!
Requirements Relating to the General Components of Simulated Activities
We told you this wasn’t a fun read, remember? Here’s another laundry list of general requirements for cruise lines to follow:
- at least one simulation must be conducted for each ship for which the cruise ship operator intends to commence restricted passenger voyages
- the cruise ship’s color-coding status must be Green or Orange at the time of the simulated voyage
- the cruise ship operator must maintain a list of all passengers, crew, port personnel, and other persons who participated in the simulated voyage.
- if the cruise ship operator has entered into a Phase 2A agreement with the port or local health authority of more than one port and the cruise ship operator intends for the ship to dock at more than one U.S. port during restricted passenger voyages, then the simulated voyage(s) must include each U.S. port
- simulated voyages must be between 2-7 days in length with a least one overnight stay to test the efficacy of the cruise ship operator’s ability to mitigate the risk of COVID-19 onboard the cruise ship, including through embarkation, disembarkation, and post-disembarkation testing.
- the cruise ship operator must meet standards during the simulated voyage for hand hygiene, use of face masks, and social distancing for passengers and crew, as well as ship sanitation, as required by CDC technical instructions or orders
- the cruise ship operator must modify meal service and entertainment venues to facilitate social distancing during the simulated voyage.
- embarkation, disembarkation, onboard activities, recreational activities, medical evaluations, transfer of symptomatic passengers or crew, onboard and shoreside quarantine, and shore excursions must all be included in simulations to ensure their efficacy and safety
*game show host voice* But wait! There’s more…..
Cruise lines must have lab capabilities for testing before and after the cruise and results must be available before boarding. At least 75% of all passengers need to provide their post disembarkation COVID-19 test 3 to 5 days after completion of the simulated voyage for testing.
During simulated voyages, the threshold for COVID-19 cases is met when 1.5% of passengers test positive or 1.0% of crew test positive. Should either happen, the cruise ends immediately. The cruise line would then have to make changes to their procedures and protocols and restart the voyage from the beginning.
The Silver Lining
As we mentioned above, cruise lines don’t have to worry about ANY of these requirements so long as they require 95% of passengers be fully vaccinated. From our point of view, all of these hoops to jump through and protocols to follow are just a sneaky way to make vaccines mandatory on cruises.
If you wan’t to cruise again, it’s looking more and more like vaccines will be mandatory because the alternative is going to have cruise line executives losing sleep and pulling out their hair in frustration.
Let us know what you think of the CDC’s new guidelines for simulated cruises in the comments!