Variances

Requirements

Cruise lines submit variances when a process or event is not allowed or covered in VSP's current guidance.

VSP must approve variances before ships start the process or event.

Variances are also required for galley tours when:

• Food is being prepared
• Passengers walk through the galley

Process and approval

Plan about 1 month for the variance review process:

• Request the appropriate template from VSP.
• Email the required documents to vsp@cdc.gov.

If approved, VSP emails the final documentation and approval memo for the variance. If not approved, VSP may request modifications and resubmission.

Variance revisions

Update and resubmit a variance when:

• A ship has a new cruise line owner
• A ship's name changes
• A new ship needs to be added to an approved variance
• Process or event procedures change

Note: Updates to the VSP standards may affect approved variances.

Multiple ships

Variances can cover more than one ship:

• List each ship on the variance request.
• Document any procedural differences between ships.
• Submit an updated variance request to add a ship to an approved variance.

Email vsp@cdc.gov to remove a ship from an approved variance.

During inspections

VSP reviews variances and procedures during inspections. VSP checks for:

• Variance request documentation
• VSP approval memo
• Required records (health questionnaires, medical clearance list, recreational water facility monitoring documents, etc.)

Resources

Variance templates

• Baby-only water facilities
• Interactive food and beverage activities and galley tours
• Heated jetted tubs
• 24-hour acute gastroenteritis surveillance report
• Chlorine generation
• Hand sanitizer storage
• Potable water tanks
• Recreational water facility signage
• Recreationally caught fish

Related sections in the standards

VSP 2025 Environmental Public Health Standards:

• Section 12.13 Variances
• Section 6.6 Jetted Tub Operations
• Section 7.1.1.2 [Food Safety] Monitoring Duties
• Section 13.8 Baby-Only Water Facility