Cruise Lines Still in Early Stages of Framework, What’s Next?

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On April 2, 2021, the CDC finally released phase two of the Conditional Sailing Order (CSO). It has been five months since the CDC released phase one; while there are a total of five phases the cruise lines will need to work through before they are allowed to sail with guests once again.

We look at why the process is taking so long, what the cruise lines have done so far, and what they will need to do in the upcoming period to enable cruises to start up again.

Phase 1: Mass Testing and Lab Capacity Building

Phase one could and should have been a relatively short phase, as this step only includes some basic procedures. However, several factors ensured the phase took longer than anyone in the cruise industry had expected.

First of all, the arrival of the second wave of infections worldwide caused lockdowns to happen everywhere. Second, the vaccine’s arrival, and the high-efficiency percentages that all vaccines are showing, was a game-changer.

However, the vaccine’s arrival caused phase one to be relatively redundant if the cruise lines will be sailing with a 100% vaccination grade. Phase one included the following steps:      

  • Conduct screening testing of all crew on board                                                        
  • Develop onboard lab capacity for the testing of the symptomatic crew, close contacts, and future passengers                                                   
  • Conduct embarkation testing of all crew

Most cruise ships are now fitted with PCR testing capabilities, quarantine facilities have been created onboard, and all essential crew onboard has been tested.

CDC Sign
Photo Credit: Katherine Welles /

Phase 2A: Voyage Preparation- April 3, 2021

The second stage of the CSO is focused mainly on voyage preparations. Cruise lines will have to make routine testing strategies to test all crew members regularly. This rule comes on top of many other rules the CDC requires that will severely restrict crew freedom onboard the vessels.

The cruise lines will need to develop the port, medical, and housing agreements approved by port and local health authorities. This rule is one of the features that the CDC has made prominent in the guidelines it released; however, it is also one that has been implemented by most cruise lines already through their outbreak prevention plans.

The next rule is one of the trickier ones, and one that not many will understand: After agreements are approved, embark non-essential crew with testing and a 14-day quarantine. The CDC has just released guidelines for international travel.

People (tourists or US citizens) coming from abroad, if vaccinated, are not required to undergo any quarantine. However, crew members, who the cruise lines will vaccinate, will need to undergo quarantine. Expect the cruise lines to raise some questions about this.

Phase 2A will likely take a month at best but likely much longer. Agreements with ports and health authorities will need to be drawn up and approved by the CDC.

As soon as the approvals are there, the non-essential crew (waiters, bar staff, cabin cleaners, entertainment, tours, front desk, etc.) will need to be flown to the vessels and undergo a two-week quarantine.

CDC Framework Phases

Phase 2B: Voyage Preparation- Simulated (trial) Passenger Voyages

Phase 2B will see the long-awaited test voyages come to fruition. According to the CDC, before a cruise operator will be allowed to sail with passengers, the operator must show they can perform one or a series of test voyages showing the ability to mitigate the spread of COVID onboard.

Of course, before the companies can apply for the test voyages, they will need to ensure all previous steps have been fully completed. After this, the companies will go through the following:                        

  • Request approval from CDC to conduct simulated (trial) voyage
  • Conduct simulated voyage, which will have inspectors from the CDC onboard, or looking on through digital means.
  • Complete after-action report

The simulated voyages will need to consist of embarkation and disembarkation procedures, including terminal check-in, onboard activities, including dining and entertainment, private island shore excursions, evacuation procedures, transfer of symptomatic passengers or crew, or those who test positive for SARS- CoV-2, from cabins to isolation rooms, quarantine of all remaining passengers and non-essential crew.

Norwegian Cruise Ship at Port of Miami
Photo Credit: Ovidiu Curic /

Phase 3: Conditional Sailing Certification

Phase three seems to be comprised of a few relatively short steps and should be concluded reasonably quickly. Phase three consists of the following:                                            

  • Meet CDC’s standards for the protection of crew in US waters       
  • Fulfill requirements for the simulated voyage(s)                                                                   
  • Apply for COVID-19 Conditional Sailing Certificate

While steps two and three seem reasonably straightforward, step one is the testing, quarantine, and other covid related measures for crew members the cruise lines have to implement and adhere to before sailing can commence.

CDC Flag

Phase 4: Restricted Passenger Voyages

We’re almost there. At this point, the cruise lines have to apply for the conditional sailing certificate. When the cruise lines receive the certificate, they can officially start sailing again with passengers.

Of course, the previously mentioned sanctions, which were released back in October still count. Even if 100% of the guests are vaccinated, cruise lines cannot make voyages longer than seven days, and social distancing and other measures will still be needed.

Also Read: Which Cruise Lines Have a COVID Vaccine Requirement?


The conclusion can be reasonably straightforward. The CDC’s release of guidelines this week only brings us marginally closer to a start of cruising. The guidelines clarify matters for the cruise lines, and there are some extra measures the ships will need to adhere to.

When will we see cruises with passengers leaving from the US? Looking at the amount of work that is still ahead of the cruise lines, it could be many months before seeing any cruises leaving from the US in any meaningful way. Norwegian Cruise Line, in an email to investor website Barron’s, stated:

“While disappointed in this overdue announcement, we remain optimistic that cruising will resume from US ports before the end of the summer.”

Optimistic might not be the right word here from the spokesperson. As Norwegian Cruise Line has now removed all voyages from their website leaving from US ports in July and August.

Uncertainty abounds at the moment; the wait is now for official announcements from the major cruise lines.

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