On Wednesday, the CDC issued additional technical instructions for Phase 2B of CDC’s CSO. The new guidance is for cruise ship operators in U.S. waters to conduct simulated voyages in advance of restricted passenger voyages under a COVID-19 Conditional Sailing Certificate. This bulletin summarizes the CDC’s 14-page document. You can find the full technical instructions on the CDC’s website here. 

Additionally, the instructions do provide an option to forego simulated voyages, as discussed in BA’s last cruise bulletin. These can be avoided if cruise operators sign and submit to CDC an attestation that 98% of crew and 95% of passengers are fully vaccinated prior to sailing. 

Notifying and Requesting CDC Approval to Conduct a Simulated Voyage

An operator must notify CDC and request approval to conduct a simulated voyage at least 30 days prior to the simulation. The 30-day timeframe is suggested as a guideline. CDC will respond to submissions within 5 business days. Additionally, this notice and request for approval must:

  • Specify the dates, name of ship, and location of the proposed simulation.
  • Submit documentation of the port / multi-port agreement with all U.S. port and local health authorities where the ship intends to dock during a simulated voyage.
  • Include the operator’s written notification and consent form to volunteers.
  • Identify contact for person(s) overseeing the proposed simulation for each ship who are physically present during the simulated voyage. 
  • Include the protocols or practices to be simulated.
  • Signed by the operator’s responsible officials.
  • Certify that all of CDC’s requirements relating to the protection of crew onboard cruise ships in U.S. waters have been satisfied and continue to be met.

Eligibility for Conducting a Simulated Voyage

As part of the cruise ship operator’s notification and request to conduct a simulated voyage, a cruise ship operator must verify that it meets the following eligibility criteria:

  • Operator has observed and continues to observe all elements of the CDC’s previously announced technical instructions/orders in addition to following the most current CDC recommendations related to COVID-19  (i.e. Enhanced Data Collection, No Sail Order response plan, crew testing, hand hygiene, use of face masks, social distancing, ship sanitation, etc.)
  • Operator has a port / multi-port agreement with all U.S. port and local health authorities where the cruise ship intends to dock during a simulated voyage.
  • Ship must have Green or Orange color status at the time of the simulated voyage.
  • Operator must fulfill the CDC’s technical instructions for Phase 2A of CDC’s CSO (see BA’s summary here). 
  • CDC may conduct oversight and inspection of simulated voyages at its discretion, including through in-person or remote means allowing for visual observation.

Requirements Relating to Volunteer Passengers

A cruise ship operator must observe the following requirements relating to volunteer passengers:

  • Simulated voyage must be at least 10% of the maximum number of passengers permitted onboard for restricted voyages as per the terms of the cruise ship operator’s Phase 2A port agreements.
  • 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 is an inherently risky activity. 
  • All volunteers must be at least 18 years old on the day of the simulation.
  • Operator must ensure all volunteer passengers have either: 
  • Proof of being fully vaccinated against COVID-19 
  • If not fully vaccinated, written documentation from a healthcare provider or self-certified statement that the volunteer passenger has no medical conditions that would place the volunteer at high risk for severe COVID-19 as determined through CDC guidance. 
  • 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 volunteers must be evaluated for signs and symptoms of COVID-19 prior to embarkation and disembarkation. 
  • All volunteers must agree in writing to post-disembarkation COVID-19 testing 3 to 5 days after the voyage; at least 75% of volunteers must be tested within the time frame; CDC may lower the 75% threshold requirement for future simulated voyages based on lessons learned from previous voyages and other factors.
  • To facilitate contact tracing, the cruise ship operator must advise all volunteers to notify the cruise ship operator if they develop symptoms of COVID-19 or are diagnosed with COVID-19 within 14 days after the voyage. 

General Components of a Simulation and Simulated Activities

A simulated voyage must mimic the following shipboard activities:

  • Simulated voyage must include each U.S. port included in the proposed itinerary.
  • Operator must maintain a list of all passengers, crew, port personnel, and other persons who participated in the simulated voyage. 
  • Voyages must be between 2-7 days in length with a least one overnight stay; CDC recommends a minimum voyage length of 3 days with 2 overnight stays.
  • The following activities must be simulated for each ship (one on simulation or several) before commencing restricted passenger voyages: 
  • Embarkation and disembarkation procedures, including terminal check-in.
  • Onboard activities, including seating and meal service at dining and entertainment venues.
  • Medical evacuation procedures.
  • Transfer of symptomatic passengers or crew, or those who test positive for SARS-CoV-2, from cabins to isolation rooms.
  • Onboard and shoreside isolation and quarantine of at least 5% of all passengers and non-essential crew.
  • Recreational activities that the cruise ship operator intends to offer as part of any restricted passenger voyages, e.g., casinos, spa services, fitness classes, gymnasiums.

Shore Excursion Components of a Simulation and Simulated Activities 

If planned during restricted passenger voyages, port of call shore excursions, including private islands, must be simulated. The following measures must be observed:

Port of call shore excursions:

  • Self-guided or independent exploration by passengers is prohibited.
  • Shore excursions must only include passengers and crew from the same ship.
  • Operator must ensure shore excursion tour companies facilitate social distancing, mask wearing, and other health measures throughout the tour.
  • Operators must have a protocol for managing persons with COVID-19 and close contacts at all foreign ports of call. At a minimum, the protocol must include:
  • Disembarkation and housing of persons with suspected or confirmed COVID-19 needing shore-based hospital care and their travel companion(s) for the duration of their isolation or quarantine period.
  • Commercial repatriation of U.S.-based persons with COVID-19 and close contacts only after meeting criteria to end isolation and quarantine per CDC guidance. 

Private-island shore excursions: 

  • Only one ship can port at the island at any one time.
  • Testing protocols for island staff expected to interact with volunteers or crew.
  • Mask use and social distancing must be observed on the island.

Requirements Relating to Laboratory Testing on Simulated Voyages

  • Operator must conduct laboratory testing of all passengers on the day of embarkation and debarkation with same day results using one of the following testing instruments and processes:
  • Previously approved Phase 1 shoreside laboratory, or
  • Previously approved Phase 1 onboard point-of-care equipment, or
  • Other testing instruments and processes approved by CDC.
  • Passengers who test positive for SARS-CoV-2 should be denied boarding.
  • Passengers who show documentation of recovery from COVID-19 in the past 90 days can be excluded from testing.
  • For debarkation testing, results must be available before the passenger leaves the cruise ship, seaport, or offsite testing location, but specimen collection and testing can occur onboard or shoreside.

Operators must immediately end a simulated voyage if a threshold of 1.5% of COVID-19 cases is detected in passengers or 1.0% of COVID-19 cases is detected in crew. In addition, if a simulated voyage is ended early, the operator will need to repeat the voyage. 

An after-action report submitted to the CDC will include elements such as any deficiencies observed in protocols; post-disembarkation test results; conclusions on the efficacy of its protocols and “lessons learned”; discussion of best practices on voyages outside of U.S. waters; and, observations of the CDC’s inspections during the voyage.

What does this mean for the return of cruising from U.S. ports?

The quickest way for operators to resume sailing will be to avoid simulated voyages through the requirement of vaccines, at least temporarily until the CDC relaxes some of these policies. However, for those lines that are not ready to resume under those circumstances, simulated voyages cannot be avoided. 

Each line will have to submit a simulated voyage request for each ship it plans to resume restricted passenger voyages on, conducting at least one simulation for that ship prior to the restricted passenger voyages. Only after the simulated voyage is complete can the operator apply for a COVID-19 Conditional Sailing Certificate for that vessel. As of May 5, 2021, the CDC has 51 ships that are Green or Orange status that are eligible to apply for simulated voyages. 

What is not clear, according to Frank Del Rio on NCLH’s earnings call today, was what requirements are also applicable to restricted sailings for fully vaccinated ships. He agreed that the route for those lines that have announced fully vaccinated ships has far fewer hurdles to resume cruising, and that the latest guidelines relax some of the burdensome and costly testing requirements. 

However, he shared his disappointment at first read, saying “at first glance, the path forward is a bit rockier and steeper than originally anticipated.” Not going into too much detail, the disappointment sounded like it was coming from the requirement of masks for vaccinated passengers. They have a meeting this afternoon to clarify some of these “unacceptable” elements.

As for a July resumption in the U.S? Del Rio stated that for NCLH, it is not possible to add any additional ships to sail from U.S. ports for July given the timing of the CDC’s response to their April proposal of fully vaccinated cruises. Their focus right now is on the 7 vessels NCLH has announced for resumption outside the U.S.


After sorting through the technical guidelines for the simulated voyages one would need to ask – Why would any cruise operator even contemplate doing simulated voyages for each vessel? Instead, it would seem much more prudent to move ahead toward the sailings with vaccine requirements in hopes of deploying more ships faster and then being able to open those sailings up at some point in the near future (Nov/Dec) to ALL cruisers – vaccinated or not! 

What about the idea of close to 100% of persons onboard a ship being vaccinated and still requiring passengers to wear masks, social distance, and be in a bubble when going ashore? Where is the threshold of what is an acceptable and enjoyable cruise vacation experience vs. a cruise product needing reservations for limited lounge chairs around the pool due to social distancing; takeaway food in plastic containers; and, having to wear a mask while tanning on a private island where all of the people are vaccinated and the private island is not even in the U.S.?!   

Cruise operators and ports still need to focus their attention on developing port agreements which have their own set of onerous hurdles to overcome in order to start sailing in the U.S. Some ports, such as Galveston and Port Canaveral, are providing crew vaccination clinics to assist the industry in their compliance efforts for a faster restart. 

Cruise lines are still trying to target Alaska for cruise operations in mid-July. With self-guided / independent exploration by passengers in these ports being prohibited and only being able to operate shore excursions that must only include passengers and crew from the same ship, there will be minimal positive economic and social impacts on the SE Alaska communities, thus the visitor experience will also be greatly underserved. The true essence of Alaska will be missed.

As a tourism industry and in conjunction with all of us as stakeholders we should be demanding from our Representatives that cruise operators be treated fairly and not be overly burdened and suppressed by onerous bureaucratic requirements imposed by the Federal government. No other business sector has paid this heavy of a price throughout this pandemic. In turn, the impacts on ports and communities from Florida to Alaska have been devastating and will have lasting impacts.  There needs to be a continued effort to minimize and/or eliminate the burdens placed upon the cruise industry in order to swiftly open this sector of the tourism industry here in the U.S.