The appropriate laws of the Flag state with regards to alcohol consumption must be published on all travel documentation, cruise line Internet websites and prominently displayed within all bars onboard a vessel.
The cruise line company’s policy must detail that these laws are to be complied with at all times except then they are amended by the laws of a Port State, in whose territorial waters the vessel sails. The vessel will be expected to always comply with any law of a Port State which has a more rigid requirement concerning age and service to young people.
These variations must also be displayed on the internet, travel documentation and prominently displayed onboard within all bars
Company policy must also detail in depth the criteria with regards to the handling of intoxicated passengers, crewmembers and the dangers of alcohol to minors.
The cruise line company’s crew education (and not only that of bar staff) must include the applicable laws and age criteria, including the fact that to deliberately deviate from the laws is a criminal act e.g. provide or sell alcohol to a minor and as such will be reported promptly to the Flag State, Port State (if applicable) and law enforcement.
Violators must not be promptly dismissed from the company but presented for investigation with regards to the conduct of a criminal act.
The cruise line company’s crew education must also focus on the needs to verify identification, fake personal identification, taking positive action to prevent intoxication and prompt reporting of incidents.
The cruise line company’s reservation system must identify all minors at the time of booking and this information must require the age of the person at the time of sailing.
The cruise line company’s reservation system should automatically send an email to a parent boarding with a minor and reminding them to review the drinking age limit requirements, the various laws and the company’s policies.
The cruise line company’s policies should also include the fact that a parent, guardian or adult who willingly provides alcohol for a minor while onboard, or on an organized excursion may be in violation of a law and company policy; that all incidents will be reported and investigated fully.
The cruise line company’s reservation system and onboard revenue system must have a way of categorizing minors and any special age limits with regard to the purchase of wine, beer and spirits.
Certain companies use a code of their boarding cards to provide an indicator of a person’s age but while they have codes for minors and young adults, some companies do not have a code for adults able under law to purchase hard liquor. There should be such a code.
Example One cruiseline uses M1Minor under the age of 18
M2Person over 18 but under 21
No CodePerson 21 and over
Comment: This leaves the system open to abuse, the printed code can be removed and this leaves no marking which of course is that indicator that a person is 21 and over. This is the reason they punch holes in cards. A quicker solution is to also have a M3 code printed on cards. This reduces the possible confusion a punched hole in a card creates e.g. an adult wishing to carry their card on a lanyard may punch a hole not knowing that this is a security process.
At Check-In, the Ground Reservation staff must ensure that documentation confirming age is presented and accurate. The appropriate coded card must then be issued to the person. This system must also be properly implemented when a passenger joins down-line e.g. not in the main embarkation port. The Pursers will be responsible for ensuring this process is conducted properly.
Onboard revenue systems must be keyed to reflect the any levels of age coding that a company uses. This requires the system to be coded electronically. The system must be designed so as not provide a sale if the card presented is not legally entitled to be used for a certain purchase. This should be applicable in all bars, room service and gift shops.
The identification and age should also be verified. The simplest solution is to link the bar swipe of the card to a photographic display from the Electronic Access Control System to assist the bar staff to confirm that the card presented is that of the authorized holder. If this is not the case, the purchase shall not proceed, the Bar Supervisor called to the scene and the parent or guardian of the person notified immediately.
The system should be designed in such a way as it does not provide the ability to review all photographs on the system, does not permit print outs or copies of passenger or crew photographs but is linked only to the swiped bar code on the person’s onboard revenue card e.g. if a card is not swiped then the database is not accessible. The swiped action will only display that one linked photograph and no others. The photograph will only be displayed for 15 seconds and then will be blanked. This is to ensure that the system is not abused by any person intent in “trawling” the system against company policy and laws of the Port and Flag State.
A hand held version of the unit should be developed for use on private island facilities, where hard checks are normally used for the purchase of alcohol or soft drinks.This hand held unit will also be provided to the Room Service staff.
Room service staff must be provided with the same verification tools and aids that all other alcohol service areas are allocated. They must also undergo the same training as bar tenders and servers.
The dining room bar service areas will be provided with fitted unit access. They will also be required to undergo the same training.
Both the fixed unit and handheld units would display an opening screen reminding the user, bar tender or server, room service personnel and dining room staff of the appropriate law and company policy. The user would be provided with a unique identification and password and this would be recorded on the system for later review if necessary.
In those areas serving alcohol, and perhaps attractive to minors e.g. the Adult Disco, there must be a firm and effective access control in place. This may be fulfilled by general crewmembers but they must be fully trained, supervised by security personnel and given specific instructions and policies concerning access to the area.
They must also be provided with the hand-held swipe identification unit to verify a person’s age.
These types of areas must display the age restrictions relevant to the location e.g. if the area sells alcohol then it is not a Disco but a Disco Bar and all relevant laws and company policy apply.
A spot check audit will be conducted every day of the system. This check will be conducted by the security staff and reported through the Staff Captain to the Captain. The spot check will be documented, and retained on record. As will any shortcomings or violations. All shortcomings and violations will be investigated fully.
Additionally, random checks of the bars by supervisors will be conducted to ensure compliance with laws and company policy; these random checks will also include on-shore private island facilities.
All bars must be under the view of CCTV surveillance. The activity at the bar must be recorded at all times. The system should be able to cover the bar serving areas.
A Risk Assessment (RA) should also be conducted of the Adult Disco to ensure that minors may not enter by using emergency exits etc to by-pass security checks. This RA will be conducted by the Security Officer, Safety Officer and the Manager responsible for the area. Shortcomings must be addressed.
The RA must be documented and kept on file. The Captain will be provided with a copy of the RA, recommendations and a separate report, if necessary, detailing the measures to address any shortcomings.
While onboard the vessel, on a company arranged tour or within a private island facility, parents and guardians will not have the authority to override the law or company policy. A parent or guardian will not be permitted under any circumstance to bring a minor into the Adult Disco or Casino Bar.
Any parent or guardian adamant about this requirement will be reminded of the law and company policy; this might eventually lead to the parent or guardian and the child being disembarked from the vessel.
This also applies to the provision of alcohol to a minor.
There should be a company policy with regards to complimentary alcohol e.g. the same laws apply as for purchased alcohol and this includes the provision of alcohol to minors.
Alcohol should not be considered as a complimentary restitution for bad service but another service should be offered e.g. free tour, chocolates, flowers, fruit basket etc and not a possible intoxicant.
The cruise line companies must properly police any and all functions that provide complimentary alcohol to the passengers or crew. This policing should ensure that minors are not able to by-pass the verification process by simply entering and obtaining complimentary alcohol.
It must be stressed that “good housekeeping” is properly practiced during these types of events and all bars in general, in order to prevent a minor from drinking from discarded glasses containing alcohol from the tables of other people.
The cruise line company’s policies must address intoxication by adults and should ensure that a person who is intoxicated is not permitted to purchase or be provided by another person alcohol; and that any intoxicated person is handled in such a manner to ensure their continued well-being.
This should include ensuring that the person is properly supervised and that the supervision is not conducted by another person under the influence of alcohol or any narcotic. This is particularly important if the person is accommodated in a balcony cabin.
The company’s crew training must include reference to, and understanding of, Blood Alcohol Content ratio and the effects of alcohol on the judgment of an individual.
It should also consider the medical dangers of intoxication, the increased
hazards to a vessel from an intoxicated person and the difficulty of handling
such a person during a safety incident or emergency.
The crew training must also include CPR, the “Recovery Position” and AED training.
Each bar onboard must be fitted with a highly visible CPR mask for use in emergencies. All bar staff must be trained in CPR.
The cruise line company’s policy should detail the restrictions concerning the bringing of alcohol onboard by passengers; either parent, guardian or minor.
There should be secondary screening of the property of any minor in an out-port when returning onboard and found in possession of alcohol. The age must be quickly verified, the parent or guardian notified and the alcohol taken into safe custody until return to the disembarkation port. The alcohol must not be passed to the parent or guardian when discovered nor returned on the last night but passed by signature to the parent or guardian on the last morning.
The secondary screening must be conducted by support personnel and not ship’s security staff. The primary screening will always be conducted by ship’s security personnel but providing other personnel to support the secondary screening will ensure that the security personnel are focused on the requirements of theISPS, MTSA (if applicable) and Ship Security Plan.
For US itineraries the parent or guardian will be reminded of the CBP legal requirements concerning alcohol.
The cruise line company’s policy must also address alcohol provided to participants of company provided excursions.
Risk Assessments must be conducted when a tour operator is first considered or offers a new tour. A periodic review must also be considered conducted.
This Risk Assessment must be documented and retained on file.
If “free” alcohol is provided then no minor is permitted on the tour, unless the tour is able to provide beyond any doubt that a minor may NOT obtain alcohol either knowingly or unknowingly (e.g. the tour must be to the same standards of enforcement as onboard the vessel).
These types of tours must also be accompanied by a ship’s supervisor who is not permitted to participate or drink alcohol.
This person must have radio communications with the vessel (either personal radio or using the tour operator’s equipment).
Any medical or alcohol related incident will be notified immediately to the vessel, so that any medical response can be prepared in advance.
Within private island facilities, extreme sport type services, e.g. wave runners, paragliding etc should require that the supervisor determines that the person participating is not intoxicated or has drunk sufficient to impair the person’s judgment while in control of potentially hazardous equipment e.g. fast moving wave runner not only poses a hazard to the driver but other persons in the water.
The cruise line company’s contract must also require that all guides and supervisors of tours and in particular, those with increased hazard e.g. climbing, diving etc must comply with the company’s alcohol policies with regards to a person on duty. The ship’s tour escort will be expected to monitor this situation and take action if any of the responsible persons appears intoxicated.
The cruise line company’s policy will not permit any alcohol related “party games” either onboard or onshore within a private island facility.If they want drink racing games use cups of soda etc.
Party games which encourage abuse of alcohol consumption within an excursion should be strongly discouraged. Cruise line documentation must mention if any tour provides alcohol, free or at a charge. (In the same manner, that they have small logos displaying any mobility restrictions on a specific tour).
The cruise line company’s policy must detail the response to a person returning onboard intoxicated and this should consider the verification of the person’s condition by a member of the ship’s medical staff. (This is particularly important if the person is traveling alone or all occupants of the same cabin appear to be under the influence of alcohol and in particular if the person or person(s) occupy a balcony cabin).
The medical staff of the vessel should ensure that the person assuming responsibility for the intoxicated person is properly briefed concerning the affects of alcohol, the Recovery Position, dehydration and the process for obtaining further medical assistance including the ship’s emergency contact processes e.g. 911.
Cruise line reservation systems are able to determine the age groupings sailing on a relevant voyage, support for the onboard security organization should be increased when the number of youngsters in risk age groups increases and this should include during seasonal peaks e.g. spring break.
This manpower must be properly trained, supervised and managed. They should have the authority to enforce the company’s policies with regards to intoxication and also minors involved in alcohol or narcotics related incidents.
For college graduation groups, events etc, the cruiseline must determine the number of adult chaperones needed to manage the group and this must be reflected in the booking. Chaperones must be properly supported and expected to behave in a supervisory role and ensure the well-being of their group members.
The cruise line will be expected to step in when this is not the case and be expected to implement their policies with regards to person, persons or groups creating an unhealthy vacation environment.
Most cruise line companies apply a policy of removing alcohol from passengers and returning the same on the last night of the cruise; this should be expanded to the crew and detailed in the company’s policies. This policy must be enforced properly, given that the majority of crewmembers on a vessel are members of a safety organization.
The cruise line company’s policy concerning crew alcohol consumption must be properly and correctly enforced.
Crew bars must be correctly managed and supervised.
A verification system must be in place to ensure that those crewmembers in a safety sensitive duty position do not violate the policy, contravene the law and place people in potential risk during a response to a ship’s emergency. This is critically important in the Bridge Navigation, Engine Control Room, Medical Facility and Fire Response organizations, but likely also includes Survival Craft crew, Personnel assisting a Passenger during an emergency, communications etc
Company sponsored events for crewmembers must be in line with those for passengers and should not violate the company’s own policies with regards to alcohol consumption.
Corporate initiated external and internal safety audits would be expected to review and inspect a vessel’s application of the company’s policies. Deficiencies must be reported, documented and addressed.
Additional Note:
The hand held age verification units discussed would also have its uses amongst the security personnel on patrol – verifying a person’s identity during an incident and, additionally, could be used on shore on those tender stations where normally a visual check of a boarding card is conducted only and the photographic check is conducted only. In these circumstances, the shore security personnel would be able to verify a person is authorized to board and increasing the ship’s security integrity.
