December 3, 2021 | Circular No. 11359

Dear Member,

On November 30th, the government issued a new Interim Order (IO #8) related to Transport Canada’s vaccination mandate for federally-regulated workers in the marine transportation sector and the resumption of cruise ship operations in Canadian waters.  Although many of the IO’s provisions are similar to those found in its predecessor, IO #7 (as per our CL 11333), it does provide additional details with repect to requirements for cruise ships and passengers, as outlined below:

Pre-notification requirements

Foreign cruise ships must notify the Minister of the date when the cruise ship is scheduled to arrive in Canadian waters at least 45 days before that date (notification to be sent to  Note that this is a change from the previous Interim Order, which provided for a 60 day notification period.

Vaccination and testing requirements

Before a cruise ship (domestic or foreign) is operated in Canadian waters, the ship’s authorized representative must verify the vaccination status of passengers and crew as per below:

  • Every passenger who is 12 years and 4 months of age or older must be fully vaccinated (or have appropriate documentation to support an exemption on medical or religious grounds).
  • Every passenger and every person who intends to be on board as a passenger must be tested in accordance with Transport Canada’s testing framework, as specified in Ship Safety Bulletin 18/21.  Please note that the most recent version of this Bulletin does not provide any details on testing of passengers, other than to indicate that additional information will be provided through period updates to the document.
  • Every crew member must have received the first dose of a Covid vaccine as of November 15, 2021 and be fully vaccinated at of January 24, 2022.
  • Every crew member who is not fully vaccinated must provide the results of molecular Covid test taken within 72 hours of embarkation (and undergo subsequent testing every 3 days thereafter if the vessel is on a voyage of more than 6 days).

Covid-19 Management Plan

Any cruise ship (domestic or foreign) that plans to resume operations in Canada must implement a vessel specific Management Plan.  This plan must outline that appropriate measures are in place to ensure compliance with passenger vaccination requirements, appropriate testing of passengers, protection of passengers and crew during port-of-call stops, and management of Covid outbreaks on board.  In the case of foreign cruise ships, the plan’s measures must also comply with  U.S. and E.U. frameworks for the resumption of cruise activity.

The cruise ship’s authorized representative must notify the Minister that they have implemented this plan 45 days before the ship first operates in or enters Canadian waters.  Notification should be submitted to

Ship to Shore Checklist

The cruise ship’s authorized representative must develop a checklist regarding procedures to be followed when the cruise ship is at a port of call, including measures to limit the spread of Covid during the embarkation and disembarkation of passengers.  The checklist must be signed by the port authorities where the cruise ship is scheduled to call and by the appropriate public health authorities.

The cruise ship’s authorized representative must notify the Minister that they have developed this checklist 45 days before the ship first operates in or enters Canadian waters.  Notification should be submitted to

Reporting Requirements

The cruise ship’s authorized representative must provide the Minister with a report on passengers which includes the total number of fully vaccinated passengers on board, the number of passengers who are not fully vaccinated for medical or religious reasons, the number of passengers who tested positive for Covid while on board (and their vaccination status), and the number of passengers denied boarding due to non-compliance with the IO.  Such reports will have to be provided on a weekly basis of first operating in or first entering Canadian waters. Reporting methods will be provided through periodic updates to Ship Safety Bulletin 18/21.


Members should note that the above is our preliminary assessment of the key requirements for cruise operations in Canadian waters, and that some measures may undergo further changes as the public health context continues to evolve.

We will continue to monitor developments on the cruise file and revert with additional information as it becomes available.


Karen Kancens
Vice President