CDC Requesting Comments From Public Regarding Cruise Ships Sailing Again

[rallydave]

https://www.seatrade-cruise.com/news/breakthrough-opening-cdc-seeks-public-comment-cruise-operations-covid-19-era?NL=ST-004&Issue=ST-004_20200724_ST-004_539&sfvc4enews=42&cl=article_1_b&utm_campaign=STRADE_News_Seatrade Cruise News Weekly Headline_News_NL_07242020_872&utm_emailname=STRADE_News_Seatrade Cruise News Weekly Headline_News_NL_07242020_872&utm_medium=email&utm_source=Eloqua&utm_MDMContactID=04296ed0-12fe-4c8a-a0f9-1855a7492dca&utm_campaigntype=Newsletter&utm_sub=Seatrade Cruise News Latest Headlines&eM=dd71f9cac1f372bccde63ff20d0b35f7736bdda7a135f2560c14b4f1e951ac88&eventSeriesCode=ES_SEATRDCRSCTNT&eventEditionCode=MTM00SCC&sessionCode=S_STRDCRSNEWS

 

Above is a link to an article describing a new request by the CDC to the general public asking for written input for the requirements for Cruise Lines to sail again.  There is a link in the article to the CDC page where you can comment.  Please note, this comment period will be open until Sept. 21 so according to the article, the no sail order which now ends on Sept. 30 will most likely be extended so that the comments can be coordinated and work on the protocols by the cruise lines and CDC can be negotiated so that cruises can again occur.

[howiefrommd]

This is a bit different than normal.  Usually anytime a  Federal Agency will be potentially promulgating rules, they publish the proposed rule(s) in the CFR.  There is usually a comment period post publication of proposed action.  The Agency reviews the comments and incorporates their response in another CFR publication, finalizing the regulation.

 

In my experience, this is not a fast process.  Every comment must be reviewed by Agency staff, they are usually categorized, then they review the comments vs. the proposed regulations and make changes/adjustments (if appropriate). 

 

I am a bit surprised they are doing it this way as it will only lengthen the process.  

[mrlevin]

I am definitely going to send in my comments.  😀

 

I just want to see them published in Federal Register.  😀

[Travelcat2]

I can only imagine what a mess that will be - having passengers from mega-ships, huge ships, large ships, medium size and small ships trying to come with one set of protocols. 

Edited July 24, 2020 by Travelcat2

[CruisetheCs]

Having some experience in the past with the regulatory process, I would think this will take months to finalize any rule or guideline.  By soliciting comments, CDC is going to have to address outright the spectrum of problems that Covid poses onboard, on excursions, in ports, etc.  

 

Until there is a vaccine it is difficult for me to imagine how CDC will be able to come up with cruise ship guidelines that are compatible with current recommendations to slow transmission on land. So maybe delaying rules while seeking input is a reasonable strategy for CDC and the safety of passengers.

 

As for protocols for various size ships, CDC is faced with that issue no matter whether they seek input or not.  

[Travelcat2]

 

Crystal's new protocols address excursions in ports, etc.  Very well done on their part.

 

Yes - the CDC will need to address the issue of various ship sizes but it could be done without input a lot easier.  Perhaps they have a small review board that will read passenger input and only pass on (for further review) things that would be a real possibility.

[Wendy The Wanderer]

I don't see the actual comment page from either of the links.  Anybody penetrated that particular hurdle?

[howiefrommd]

31 minutes ago, CruisetheCs said:

Having some experience in the past with the regulatory process, I would think this will take months to finalize any rule or guideline.  By soliciting comments, CDC is going to have to address outright the spectrum of problems that Covid poses onboard, on excursions, in ports, etc.  

 

Until there is a vaccine it is difficult for me to imagine how CDC will be able to come up with cruise ship guidelines that are compatible with current recommendations to slow transmission on land. So maybe delaying rules while seeking input is a reasonable strategy for CDC and the safety of passengers.

 

As for protocols for various size ships, CDC is faced with that issue no matter whether they seek input or not.  

I think months is being very ambitious.  In my experience, health and safety regs can take a year or two.  

[rallydave]

38 minutes ago, Travelcat2 said:

I can only imagine what a mess that will be - having passengers from mega-ships, huge ships, large ships, medium size and small ships trying to come with one set of protocols. 

Don't see why the size of ships will affect the protocols.  The more passengers, the bigger the ship so yes the average sq. ft. per person will vary a little bit but, not enough to make a difference in the protocols.  Six feet apart is six feet apart no matter how big or small the ship is.

 

And, on land, don't know of any different protocols based on size of a facility.  Believe it will be just as difficult on a small ship with fewer passengers as a monstrosity of the sea with many passengers to keep people spread out.  Yes, there are lines on the monstrosities but, simply walking down a hallway or passing thru rooms on a smaller ship will still have the same rules about keeping six feet apart.

[Wendy The Wanderer]

Just now, rallydave said:

Don't see why the size of ships will affect the protocols.  The more passengers, the bigger the ship so yes the average sq. ft. per person will vary a little bit but, not enough to make a difference in the protocols.  Six feet apart is six feet apart no matter how big or small the ship is.

...

 

I agree that the protocols will be the same. Their implementation and consequences may vary among different sizes of ships.  For instance, if all staff have to have their own cabins, that's going to have a huge impact on profitability.

[howiefrommd]

15 minutes ago, Travelcat2 said:

 

Crystal's new protocols address excursions in ports, etc.  Very well done on their part.

 

Yes - the CDC will need to address the issue of various ship sizes but it could be done without input a lot easier.  Perhaps they have a small review board that will read passenger input and only pass on (for further review) things that would be a real possibility.

When comment is made via the Federal Register, every comment must be cataloged and responded to.  It is quite a lengthy and work intensive effort.  I would imagine there would be many respondents from many different areas, to include, but not limited to: Cruise Lines, Insurers, Public Health Entities, Other regulatory Agencies, Attorneys, Organizations representing the entities that would be regulated, Airlines, Hotels, Consumers, Investment world, etc.  I have seen in some cases ten of thousands of responses.  Many of the groups, send in mass letters via their constituents/members.  

[mrlevin]

14 minutes ago, Wendy The Wanderer said:

I don't see the actual comment page from either of the links.  Anybody penetrated that particular hurdle?

 

https://www.regulations.gov/docket?D=CDC-2020-0087

[howiefrommd]

6 minutes ago, rallydave said:

Don't see why the size of ships will affect the protocols.  The more passengers, the bigger the ship so yes the average sq. ft. per person will vary a little bit but, not enough to make a difference in the protocols.  Six feet apart is six feet apart no matter how big or small the ship is.

 

And, on land, don't know of any different protocols based on size of a facility.  Believe it will be just as difficult on a small ship with fewer passengers as a monstrosity of the sea with many passengers to keep people spread out.  Yes, there are lines on the monstrosities but, simply walking down a hallway or passing thru rooms on a smaller ship will still have the same rules about keeping six feet apart.

I agree. When we look at regulations in the land based world, there is no difference in regard to their size.  As an example, all Hospitals in the United States, Territories and Commonwealths are required to meet the regulations set forth by CMS.  The same level of safety requirements that are required at a massive University Hospital are the same as those in a 6 bed hospital in Guam.  

[Bellaggio Cruisers]

Just looked at some of the comments. I think everyone is saying much the same. I really don’t need my name in the federal register so I will not comment. 
Many folks mention the fact that ships are cleaner than planes and hotels etc. And most would like to cruise again. Some also feel that the cruising industry is being treated harsher than others. 

[Travelcat2]

Protocols may be the same but they will need to be handled differently.  Spaces are tight on larger ships and the challenges are huge.

 

The comment about hospitals is interesting since special areas had to be constructed/redone in order to accommodate the increase in patients.  Some schools cannot accommodate distancing - they need more space (and likely should be looking at vacant buildings, churches, etc.).  Cruise ships do to have the ability to add space to their ships.  Some restaurants cannot reopen as they cannot accommodate current protocols.  

 

The point is that cruise lines need to submit their plans on how they will accomplish what needs to be accomplished on their ships.  It is for this reason that I do not see all cruise lines resuming cruising at the same time.

[howiefrommd]

Most people/organizations who understand the rule making process submit comments do so via mail.  I have seen during some of the OBRA CFR responses in excess to 100,000 comments submitted.  Some are like catalogs, with 100's of pages.  You find this specially from the community that the regulations pertains to, lawyers and advocacy groups.  , 

[Pcardad]

They will auto scan them and upload them - I doubt they are going to be read.

 

It won't take 2 years to sail again...people will sacrifice 10% of the population to save the economy first...people can be quite brutal in a pack.

[cwn]

12 minutes ago, Pcardad said:

.....It won't take 2 years to sail again...people will sacrifice 10% of the population to save the economy first...people can be quite brutal in a pack.

I totally agree. With out an economy it won’t matter if any cruises sail. 

[Travelcat2]

Pcardad - kindly explain your last post.  "cwn" took it one way and I took it another.   I get the part about it not taking 2 years to sail again.  It is what you posted after that I am not sure I understood.  It seems to me that the resumption of cruising will help our economy (based on what I'm reading in the news).  It will help not only the cruise companies but the airlines and hotels as well as the tourist dollars that passengers bring to the ports that they visit.  Seattle alone is losing hundreds of millions of dollars this year.  

[Pcardad]

I think, at some future point if it goes on long enough and gets bad enough, people will stop fighting the virus and allow it to spread....sacrificing people to put the fight behind them and move on with their lives. Pretty dark but we, as people, don't do nice things when we are a mob.

[Travelcat2]

23 minutes ago, Pcardad said:

I think, at some future point if it goes on long enough and gets bad enough, people will stop fighting the virus and allow it to spread....sacrificing people to put the fight behind them and move on with their lives. Pretty dark but we, as people, don't do nice things when we are a mob.

 

Wow - very dark but probably true.  Thank you for the explanation!

 

[pappy1022]

17 hours ago, Travelcat2 said:

I can only imagine what a mess that will be - having passengers from mega-ships, huge ships, large ships, medium size and small ships trying to come with one set of protocols. 

They are all cruise passengers regardless of the size of the ship so their comments are just as important as those few on small luxury lines. Despite size and capacity differences, all cruise ships have a lot in common and although the implementation of the new rules may differ, the goal is all the same. I don’t think it is reasonable nor practical to have different standards for different classes of ships. The ability to implement those rules based on size and other parameters will differ in terms of difficulty.

[pappy1022]

I’ve worked with the US government and governments throughout the world to implement cyber security systems and processes for chemical and oil & gas facilities. The way it works, and is likely to work for the cruise industry, is that the government establishes standards and guidelines and then the company has to submit plans to meet those standards. It doesn’t matter if a plant or oil field is small, medium or large. If there is a risk, it must be mitigated to the standards. For example, one of the standards is to isolate the process control equipment from being accessed through the internet or from any external network. For some plants this was as easy as disconnecting the process control equipment from the company network and for other more complex systems, finding a way to provide secure external access or data exchange with more elaborate solutions. I can see the CDC process being the same. Regent may implement solutions differently from the mega ships but no matter the size of the ship, the ship will have to show compliance with their solution. It won’t matter if there are 300 passengers or 3,000 passengers. Every ship will have to comply with the guidelines and standards. I don’t believe that there will be different standards for different sized ships so all ideas submitted by the public are relative to finding one common set of standards and guidelines. As a side note, this process takes a long time. Governments are notoriously slow and deliberate in setting standards and reviewing plans.

[mj_holiday]

Having worked in process development and control, yes, this can take a long time.  But in the middle of all the inputs, just may be something no one else has thought about that can be valuable.  I would rather this take a long time and be right, than done quickly and result in passengers and crew getting stuck on ship somewhere where ports close to them.

[howiefrommd]

14 hours ago, Pcardad said:

They will auto scan them and upload them - I doubt they are going to be read.

 

It won't take 2 years to sail again...people will sacrifice 10% of the population to save the economy first...people can be quite brutal in a pack.

I can assure you that each comment will be read and responded to.  Although retired from Federal Service (and in the private sector now),  I routinely worked with regulations, and the corresponding review and approval process.  I have been involved with regulations from HCFA/CMS, CDC and FDA and I will say the my colleagues (primarily physicians and scientists) were very dedicated to their mission.  We were certainly not there for the money,  fame, nor politics.