COVID-19 Outbreak Prevention Consulting for Cruise Ships

Passenger cruise ships are their own unique environment, making the issue of attaining and maintaining the highest public health standards essential in preventing and responding to disease outbreaks among passengers and crew. Cruise ships have been mistakenly identified in the past, due to Norovirus, as basically the only place where this virus occurs, which is patently untrue.

Unfortunately, with COVID-19, there have been a few incidents where several ships have had cases that have garnered significant morbidity and some mortality. The industry has had to suffer, not only from a 'no sail' order from the CDC, which will be discussed below, but also from high ranking, scientific advisors in Washington as floating petri dishes.

EHA Consulting Group, Inc. has had a 35-year experience with the cruise industry and is prepared to be your primary source in guiding you to interpret and implement the latest, ever-evolving, public health guidelines and best practices onboard your vessels to comply with the CDC and other government agencies around the world, but most importantly to have a verifiable system to assuage passenger anxiety.

As a result of the COVID-19 pandemic, effective April 15, 2020, the Centers for Disease and Prevention (CDC) extended, the no sail order and the suspension of further embarkation for cruise ships in all waters under United States jurisdiction.

This order remains in effect for 100 days from the date of issue, unless lifted earlier by the Director of the CDC. Of course, the order may be extended if future public health conditions continue to warrant it.

To ultimately obtain permission and resume operations in U.S. waters the Cruise Line Companies are required to provide the CDC and the U.S. Coast Guard (USCG) an appropriate and robust plan to prevent, mitigate and respond to the spread of COVID-19 on their vessels. These plans must include:

  • Onboard surveillance of passengers and crew with acute respiratory illnesses, influenza-like illnesses, pneumonia, and COVID-19, including reporting to HHS/CDC on a weekly basis on overall case counts, methods of testing, and number of persons requiring hospitalization or medical evacuation.
  • Reports on the number of persons onboard the cruise ship and any increase in the numbers of persons with COVID-19 made to HHS/CDC and USCG on a daily basis for as long as the cruise ship is within waters subject to the jurisdiction of the United States.
  • Onboard monitoring of passengers and crew through temperature checks and medical screening, including addressing frequency of monitoring and screening.
  • Training of all crew on COVID-19 prevention, mitigation, and response activities.
  • Protocols for any COVID-19 testing, including details relating to the shore-side transport, administration, and operationalization of laboratory work if onboard laboratory work is not feasible.
  • Onboard isolation, quarantine, and social distancing protocols to minimize the risk of transmission and spread of COVID-19.
  • Onboard medical staffing, including number and type of staff, and equipment in sufficient quantity to provide a hospital level of care (e.g., ventilators, facemasks, personal protective equipment) for the infected without the need for hospitalization onshore.
  • An outbreak management and response plan to provision and assist an affected cruise ship that relies on industry resources, e.g., mobilization of additional cruise ships or other vessels to act as “hospital” ship for the infected, “quarantine” ship for the exposed, and “residential” ship for those providing care and treatment, including the ability to transport individuals between ships as needed.
  • Categorization of affected individuals into risk categories with clear stepwise approaches for care and management of each category.
  • A medical care plan addressing onboard care versus evacuation to on-shore hospitals for critically ill individuals, specifying how availability of beds for critically ill at local hospitals will be determined in advance and how the cruise ship operator will ensure acceptance at local medical facilities to treat the critically ill in a manner that limits the burden on Federal, State, and local resources and avoids, to the greatest extent possible, medivac situations. If medical evacuation is necessary arrangements for evacuation must be made with commercial resources (e.g., ship tender, chartered standby vessel, chartered airlift) and arrangements made with a designated medical facility that has agreed to accept such evacuees. All medical evacuation plans must be coordinated with the U.S. Coast Guard.
  • Detailed logistical planning for evacuating and repatriating, both U.S. citizens and foreign nationals, to their respective communities and home countries via foreign government or industry-chartered private transport and flights, including the steps the cruise ship operator will take to ensure those involved in the transport are not exposed; (the use of commercial flights to evacuate or repatriate individuals, both within or from the United States, is prohibited).
  • The projected logistical and resource impact on State and local government and public health authorities and steps taken to minimize the impact and engage with these authorities; all plans must provide for industry/cruise line management of suspected or confirmed cases of COVID-19 without resource burden on Federal, State, or local governments.
  • Plan execution in all U.S. geographical areas—all plans must be capable of being executed anywhere in international, interstate, or intrastate waterways subject to the jurisdiction of the United States; and
  • Cleaning and disinfection protocols for affected cruise ships.

An appropriate plan shall be designed to minimize, to the greatest extent possible, any impact on U.S. government operations or the operations of any State or local government, or the U.S. healthcare system.

The cruise ship operator shall further ensure that the plan is consistent with the most current CDC recommendations and guidance for any public health actions related to COVID-19. Where appropriate, a cruise ship operator may coordinate the development, implementation, and operationalization of a plan with other cruise ship operators, including an industry trade group.

The terms and conditions of the No Sail Order and Other Measures Related to Operations signed on March 14, 2020, as modified, and extended by this order, shall remain in effect. Consequently, it remains ordered:

  • Cruise ship operators shall not be allowed to disembark passengers and crew members at ports or stations, except as directed by the USCG, in consultation with HHS/CDC personnel and, as appropriate, as coordinated with Federal, State, and local authorities.
  • Cruise ship operators shall not reembark any crew member, except as approved by USCG, in consultation with HHS/CDC personnel, until further notice.
  • Cruise ship operators shall not embark any new passengers or crew, except as approved by USCG, or other Federal authorities as appropriate, in consultation with HHS/CDC personnel.
  • Cruise ship operators shall not commence or continue operations (e.g., shifting berths, moving to anchor, or discharging waste), except as approved by USCG, in consultation with HHS/CDC personnel, until further notice.

While in port, the cruise ship operator shall observe health precautions as directed by DHHS/CDC personnel.

Some of the challenges in responding to the afore-referenced bullet points may well drastically impact life at sea as cruise lines have advertised and passengers have experienced and expected.

Areas of immediate concern may be retrofitting HVAC systems with hospital-grade HEP13 filters, which can remove approximately 99.9% of all particulates that are greater than 0.1 microns. Upgrading of cleaning and sanitization and disinfection will probably be less difficult but needs to be properly thought-out complete with training modules and, of course, there is, what expectations will be placed on passengers and crew in terms of appropriate social distancing as well as potential utilization of masks.

We are also prepared to discuss the very real issues of port visits, activities and requirements for these ship-sanctioned activities since having a stellar program on board, just to be negated in the middle of the cruise in a port without the same level of protection, could negatively impact the voyage as well as the ultimate viability of cruise lines.

We at EHA stand ready to assist any and all cruise lines in their quest to achieve a compliant, healthy, and enjoyable experience for passengers and crew.