Former U.S. President Ronald Reagan once remarked, “All great change in America begins at the dinner table.” For the cruise industry, however, next year’s most significant public health regulatory changes won’t necessarily affect the food prepared on board but rather the water that passengers and crew drink, bathe in, and wash with.
The forthcoming revisions to the Vessel Sanitation Program (VSP) Operations Manual mark a pivotal shift in cruise ship public health standards, expanding the focus beyond Acute Gastroenteritis (AGE) prevention to include Legionella control. Rebranded as the ‘Vessel Sanitation Program Environmental Public Health Standards’, the updated guidelines aim to close regulatory gaps, improve disease prevention, and align with the latest scientific research.
From enhanced disease surveillance protocols to stricter potable water standards and new hot tub regulations, these changes are poised to raise the bar for health and safety across the cruise industry. In this article, we’ll unpack the key proposed amendments and assess their potential impact on cruise operators and crew members alike.
Table of Contents
Acute Gastroenteritis (AGE) Surveillance
In our earlier article, “This Year’s Most Interesting VSP Inspection Findings,” we discussed several violations flagged by VSP inspectors concerning the management of public vomiting or diarrhea incidents. While the current VSP 2018 Operations Manual does not explicitly mandate investigations into these events, it does provide some guidance.
Section 13.4.3.5 Useful Information states that VSP “may request” records following such incidents. This phrasing implies an expectation of thorough follow-up. The rationale is clear: investigating these events is essential to determine whether the individuals involved meet the criteria for a reportable AGE case. If they do, immediate isolation is critical to curbing the spread of illness.
The anticipated 2025 update is expected to address this gap by requiring detailed documentation of follow-up actions, including clinical assessments by on board medical staff. These evaluations would confirm whether the individual qualifies as an AGE case and whether isolation is warranted.
Another key change is the proposed requirement that “all fields of the AGE surveillance log must be completed, even if an entry is zero or non-applicable.” Explanatory comments will need to be provided in the notes column for any incomplete fields, ensuring greater clarity and consistency in record-keeping.
While these revisions introduce stricter documentation and follow-up protocols, they are unlikely to significantly impact on board operations. The changes primarily focus on reinforcing practices that, for many cruise lines, are already part of their established procedures, enhancing both accuracy and accountability in disease surveillance.
Potable Water
One of the most significant updates to the potable water standards is the potential incorporation of long-established requirements from the VSP Construction Guidelines. If adopted, these revisions would mandate the exclusive use of potable water in specific areas and connections throughout the ship. While most modern vessels will already comply with these standards, older ships may face costly retrofits to comply.
As outlined in Section 22.9.3 Fixtures That Require Potable Water (VSP 2018 Construction Guidelines), potable water must be supplied to the following areas and fixtures, regardless of their location on the vessel:
- Showers and sinks (including non-cabin areas)
- Chemical feed tanks for potable or recreational water systems
- Drinking fountains
- Emergency showers and eye wash stations
- Food areas
- Handwash sinks
- HVAC fan rooms
- Medical facilities
- Deck and window cleaning facilities
Utility sinks located in engine or mechanical spaces are exempt from this requirement.
Another notable update has sparked considerable discussion in the media, primarily due to a recent CDC report linking outbreaks of Legionnaires’ disease to private balcony hot tubs on two cruise ships. Since the VSP’s primary mission has traditionally focused on preventing the spread of acute gastroenteritis into U.S. ports, the potential introduction of Legionella sampling requirements marks a significant shift in its regulatory approach. Currently, the manual only mandates monthly testing for E. coli in the potable water system.
Proposed revisions include mandatory Legionella testing of potable water systems at least every six months. The number of samples would depend on the vessel’s size and complexity, covering locations such as:
- Potable water storage tanks
- Water heaters and hot water storage
- Hot water return lines
- Representative points of use in cabins, galleys, and recreational areas
- Decorative water features
- Misting systems
- Salon and pedicure devices
- Technical water sources with aerosolization exposure risks to passengers or crew
To specifically address the risk posed by whirlpool spas, spa pools, and jetted tubs, quarterly testing is being proposed. Vessels with no prior legionellosis cases and consistent negative results over two years may qualify for a reduced testing frequency of every six months. These updates, which align closely with current EU SHIPSAN guidelines, represent a broader evolution in VSP’s sanitation standards by expanding the focus to include Legionella control alongside acute gastroenteritis prevention.
Recreational Water Facilities (RWFs)
The war on Legionella continues with stricter cleaning and maintenance protocols proposed for jetted tubs located in passenger cabins. Under current guidelines, cleaning and disinfection is required either weekly or between occupancies, whichever comes first. However, the revisions put forward seek to implement more rigorous standards:
- Standard Jetted Tubs (tubs with water or air jets but no heating element):
- Drain daily.
- Clean and disinfect between occupancies or at least every seven days.
For heated jetted tubs, which maintain a constant temperature between 77°F and 104°F (25°C–40°C), two approaches are under consideration:
- Non-Variance Option:
- Drain, clean, and disinfect daily.
- Post safety signage alerting users to the absence of automated halogen and pH control systems, highlighting the increased risk of respiratory infections.
- Variance Option:
- Drain every three days and clean and disinfect twice a week or between occupancies.
- This option is expected to require an approved variance from VSP—a formal document permitting modifications or waivers of specific guidelines. To qualify, vessels would need to install automated halogen and pH equipment to comply with VSP’s free residual halogen and pH standards for public whirlpool spas and spa pools.
These proposed measures reflect a growing emphasis on mitigating Legionella risks while aiming to strike a balance between public health priorities and operational feasibility.
Additional potential revisions to RWF standards include:
- A requirement that facilities failing to meet VSP’s halogen range standards be immediately closed, a rule currently only explicitly stated for pH levels.
- Clarification that water clarity in an RWF must be assessed by ensuring that drain covers at the bottom of the pool are visible when the water is still.
From all the proposed revisions to the VSP manual, these changes are likely to generate the most pushback from cruise lines. For ships with a high number of private jetted tubs, these requirements could dramatically increase crew workload or necessitate significant investment in automated halogen and pH systems.
Food Safety
The proposed updates to the food safety section of the VSP manual generally aim to resolve discrepancies between the 2018 edition and the FDA’s revised 2022 Food Code. Among the most impactful changes is the inclusion of new provisions for time as a public health control for Potentially Hazardous Food (PHF), now reclassified as Time/Temperature Control for Safety Food (TCS).
Key Updates: 6-Hour Time Control Option
For the first time, a 6-hour time control option is considered for managing these foods without continuous temperature regulation. The proposed requirements include:
- Initial Temperature: Food must have an initial temperature of 5°C (41°F) or lower when removed from temperature control.
- Monitoring: Food temperature must be monitored to ensure it does not exceed 21°C (70°F).
- Labelling: Food must be clearly marked to indicate:
- The time it was removed from temperature control.
- The discard time, 6 hours later.
- Discard Conditions: Food must be discarded if it exceeds 21°C (70°F) or reaches the 6-hour time limit.
- Restrictions: Food managed under the 6-hour rule cannot be returned to temperature control.
Clarifications: 4-Hour Time Control Option
The proposed revisions also offer more detailed guidance for the existing 4-hour time control option:
- Initial Temperature Exception: Foods may have an initial temperature of 21°C (70°F) or lower before being placed on time control if all the following conditions are met:
- They are ready-to-eat fruits or vegetables that become TCS/PHF after cutting, or ready-to-eat hermetically sealed items that become TCS/PHF after opening.
- The food is labeled to indicate the discard time, 4 hours from the point it became TCS/PHF, regardless of service duration.
- The food temperature remains at or below 21°C (70°F) throughout the 4-hour period.
Other Proposed Changes
Another notable amendment proposes lowering the minimum water temperature for handwashing sinks in food areas from 38°C (100°F) to 29.4°C (85°F). This adjustment reflects current research indicating that effective handwashing can be achieved at lower temperatures, potentially reducing energy consumption. However, it raises questions about how this change aligns with the broader, holistic approach to Legionella prevention. For sinks without user-adjustable temperature controls, the post-mixing valve threshold will remain unchanged at 49°C (120°F).
Housekeeping
The housekeeping section of the manual, which focuses on outbreak prevention and management, introduces proposed revisions that specifically address the use of on-site disinfectant generators, such as those producing hypochlorous acid (HOCl), commonly known as electrolyzed water. Systems like EcoloxTech™, used by Norwegian Cruise Line, are examples of such technology.
To comply with the updated standards, cruise lines utilizing these systems must ensure the following documentation is available for review during VSP inspections:
- Effectiveness Studies: Proof of efficacy against human norovirus (or a validated surrogate).
- Operating and Maintenance Procedures: Detailed protocols for system operation and maintenance, including key parameters like concentration, contact time, pH, approved surfaces, and other relevant factors.
Additionally, the revised standards introduce an explicit requirement that “surfaces must be cleaned thoroughly prior to disinfection.” This update is intended to eliminate the practice of “spraying and praying,” where disinfectant is applied to unclean surfaces—typically using sprayers—without first ensuring the surfaces are clean. Research has consistently shown that effective cleaning is a critical first step in the disinfection process.
The Winds of Change
The transition to the revised VSP manual represents a pivotal moment in cruise industry regulations, one that is likely to influence global public health frameworks. For example, the EU SHIPSAN ‘European Manual for Hygiene Standards and Communicable Disease Surveillance on Passenger Ships’ is expected to undergo updates in mid-2025, signaling a broader evolution in maritime health standards. It is reasonable to anticipate that other regional guidelines for cruise ship public health will be revised in response to the new VSP manual, further harmonizing international standards and creating a unified global approach to health and safety.
While these updates aim to raise the bar for public health practices, they also introduce a range of challenges. Compliance with the revised standards may require substantial investment, particularly for older vessels or those operating in international waters, where overlapping regulations add complexity. Moreover, the increased workload for crew members cannot be overlooked, with many cruise lines facing the need to reassess crew complements or implement new systems to meet the revised requirements. Cruise operators must consider these operational impacts carefully to avoid turning these changes into an exercise in documentation rather than meaningful, actionable improvements.
Yet, despite the challenges, the overarching mission remains clear: to protect the health of passengers and crew while setting new benchmarks for sanitation and safety at sea. As the cruise industry navigates this era of transformation, Mahatma Gandhi’s words resonate: “The future depends on what you do today.” By embracing these new standards, the industry has the opportunity to set a lasting precedent for health and safety, fostering not only a healthier future but also greater passenger trust—a future where public health and confidence chart the same course.