The no sail order that kept cruise ships from sailing out of U.S. ports expired on Saturday, yet the ships remain at anchor and will be until January at the earliest. The CDC published a conditional return to sailing order on Friday which went into effect on Monday, giving cruise lines all of two days to determine its impact on their plans to resume sailing in December. After digging through the 40-page order, the major cruise lines have cancelled all of their December cruises and are now hoping to resume sailing operations in January.

It has been difficult for me to stay objective through this process as I see how much damage the CDC’s actions are doing to one of America’s favorite vacation options. I have indulged myself in prior articles, but I am endeavoring to keep this one neutral, at least as much as I can. When the CDC issued their conditional return to sailing order, they laid out safety measures the cruise lines would need to comply with to ensure passengers are as protected as possible against the COVID-19 outbreaks that hit the industry hard earlier this year. I applaud them for that, and the cruise lines are already prepared to implement all of the measures in the CDC order. They have been since this past summer. What the cruise lines were not prepared for was the added layer of bureaucracy the CDC levied with their certification requirements, and that is what led to this latest set of cruise cancellations.

Certification is a bureaucratically necessary evil. It is to be tolerated to ensure the profit motivated cruise industry doesn’t cut corners…I get that. Most of the safety and sailing certifications cruise lines require to operate out of U.S. ports fall under the authority of the Coast Guard, with the exception of health and hygiene. The CDC carved out a niche for themselves in the area of hygiene and sanitation safety when Norovirus outbreaks began hitting cruise ships. I for one am glad they did…I have read the CDC reports that complement the industry in general for their ability to make cruising safer than most land-based activities. At the same time, the CDC’s Vessel Sanitation Program allows for them to hold individual cruise ships accountable for compliance with the program’s requirements without penalizing the rest of the cruise industry.

The CDC’s conditional return to sailing order is the first time since this all began back in March that the CDC has given cruise lines a clue as to what would be expected of them by way of COVID-19 risk mitigation and management before being allowed to return to sailing. Not surprisingly, the cruise lines are way ahead of the CDC having already developed plans and protocols that exceed the safety requirements the CDC outlined in their conditional return to sailing order.

Nothing by way of the substantive safety requirements levied in the order is giving the cruise lines cause for concern. So why did they cancel their December sailings? Probably because they didn’t anticipate the certification process the CDC levied on them. That certification process requires that cruise lines give the CDC a 60-day notice of their intention to return to sailing along with several other challenging bureaucratic hoops they need to jump through. It also keeps the CDC in the driver’s seat when it comes to permitting cruise ships to return to sailing. That alone pushed any return to cruising off into January, and possibly later depending on how quick the CDC is to approve the cruise lines’ certifications.

Rather than keeping the ban in place on the entire industry, the CDC’s conditional return to sailing order shifts accountability to the individual cruise lines and even cruise ships, which I suppose could be seen as progress. Personally, I am not optimistic as my reading of the order left me concluding that much in this added layer of bureaucracy is gratuitous and aimed at solidifying the CDC’s unprecedented expansion into oversight of the cruise industry. It seems to me that obtaining the CDC’s certification could be a very arbitrary process. I worry about how the CDC plans to handle the work this added layer of bureaucracy will add to their already taxed resources. It may well be necessary, but without the resources to implement it, cruise ships may be stuck at anchor for some time to come. We won’t know for sure until January. Until then…we wait with fingers crossed.