View From the Bridge - ROSS A KLEIN

Rick Sasso of MSC CruisesROSS A KLEIN, PhD

Ross A. Klein is an internationally recognized authority on the cruise ship industry. The Memorial University of Newfoundland professor of social work has published four books on the industry, commissioned to write four reports for the Canadian Centre for Policy Alternatives, two reports for Bluewater Network/Friends of the Earth, and has more than a dozen articles and book chapters in academic and non-academic venues. (more about Ross Klein here...)

In this View from the Bridge article, Ross Klein shares his view about the environment and the cruise industry.


By Ross A Klein

A serious concern for many are the environmental practices of the cruise industry and cruise tourism's impact on oceans and air quality. The industry markets itself as a responsible steward of the marine environment, often asking why it would pollute when its livelihood depends on keeping the oceans pristine. The question is effective in deflecting attention from an environmental record – the North American industry has been fined more than US$50 million over the past decade in the U.S. alone.

The industry continues to be cited for violations. In 2008, Alaska cited 35 violations of state water quality standards by Holland America Line, Norwegian Cruise Line, Regent Seven Seas Cruises, and Princess Cruises (see Juneau Empire, 2008a; Juneau Empire 2008b). In addition, Alaska cited cruise ships for 10 violations of air quality standards in 2008 (Golden, 2009). And there were other violations. On July 4, 2008 the Associated Press reported Royal Caribbean broke Alaska state law in discharging about 20,000 gallons of wastewater into Chatham Strait in Southeast Alaska more than three weeks before (ADN, 2008). And on September 14, 2008, the Juneau Empire reported the company violated the state’s air quality standards twice in 2007 (Golden, 2008).

Sadly, that which is illegal in the U.S. may not be prohibited elsewhere, and even when it is regulations are rarely enforced. The problem is that the marine environment is by some accounts under siege. Increasingly common are news stories of dying coral reefs, of dead zones in coastal oceans – more than 95,000 square miles (Diaz and Rosenberg, 2008), and of forms of sea life becoming extinct or seriously threatened. At the same time, the cruise industry continues to grow with little sign of slowing. While boasting profits of multi-billions of dollars and paying virtually no corporate income taxes, cruise lines appear to place increased profit above environmental protection. And they have been adept at avoiding legislation and regulations (see Klein, 2009).

The Cruise Ship Pollution Problem

A cruise ship is not the most environmentally friendly form of transportation.  On average, a cruise ship discharges three times more carbon emissions than aircraft, trains, and passenger ferries:

Carnival, which comprises 11 cruise lines, said in its annual environmental report that its ships, on average, release 712 kg of CO2 per kilometer … This means that 401g of CO2 is emitted per passenger per kilometer, even when the boat is entirely full.  This is 36 times greater than the carbon footprint of a Eurostar passenger and more than three times that of someone traveling on a standard Boeing 747 or a passenger ferry” (Starmer-Smith, 2008).

But the problem is greater than just CO2.  A moderate-sized cruise ship on a one week voyage with 2,200 passengers and 800 crewmembers is estimated to generate up to 210,000 gallons of human sewage (this would fill approximately six large swimming pools), one million gallons (the equivalent of 30 swimming pools) of gray water (water from sinks, baths, showers, laundry, and galleys), and eight tons of garbage (the weight of a school bus) (Copeland, 2008:2).

The cruise industry frequently claims that its pollution is only a small part of the problem given the proportionately larger number of other ocean-going vessels and that these vessels, too, produce waste.  While this may be true for waste streams such as oily bilge water and emissions from burning fuel, it is not the case with other pollution.  With its large number of passengers and crew, wastes such as sewage, gray water, solid waste, and air emissions from incinerators are substantially greater on cruise ships than on other ships – a Congressional Research Service report estimates that 24 percent of the solid waste generated by vessels worldwide (by weight) comes from cruise ships (Copeland 2008:5). In addition, because cruise ship operations tend to concentrate in the same geographic locations and along the same sea routes, their cumulative impact on local areas can be significant.  Add to this the potential for, and reality of, accidental discharges and the environmental impacts of cruise ships are a serious concern.

Cruise Ship Waste Streams Identified

Cruise Ship Water Pollution
Black water, otherwise known as human sewage, is the waste from cruise ship toilets and medical facilities.  A cruise ship produces more than eight gallons of sewage per day per person (EPA, 2008:2-1). The cumulative amount per day for a ship such as Royal Caribbean’s Freedom of the Seas is as much as 45,000 gallons; over 300,000 gallons on a one week cruise.  These wastes contain harmful bacteria, pathogens, disease, viruses, intestinal parasites and harmful nutrients.  If not adequately treated they can cause bacterial and viral contamination of fisheries and shellfish beds.  In addition, nutrients in sewage, such as nitrogen and phosphorous, promote algal growth.  Algae consume oxygen in the water that can be detrimental or lethal to fish and other aquatic life (EPA, 2008:2-8 – 11).

Sewage Treatment - Marine Sanitation Devices. Sewage from a cruise ship traditionally has been treated by a type II marine sanitation device (MSD). Type II MSDs are the most common type of wastewater treatment systems on cruise ships and consist of flow-through devices that break up and chemically or biologically disinfect waste before discharge.  Except in the U.S. where discharge of effluent from an MSD is permitted within three miles of the shoreline, under theInternational Convention for the Prevention of Pollution from Ships (MARPOL), discharge from an MSD must occur beyond four miles of the coast.  Despite MARPOL’s regulations, cruise ship discharges are not monitored so there is no basis on which to know for certain where treated sewage is being released.

Type II MSDs are supposed to produce effluent containing no more than 200 fecal coliform for 100 milliliters and no more 150 milligrams per liter of suspended solids. Whether MSDs achieve that standard was called into question in 2000 when the state of Alaska found that 79 of 80 samples from cruise ships were out of compliance with the standard.  According to the Juneau port commander for the Coast Guard, the results were so extreme that it might be necessary to consider possible design flaws and capacity issues with the Coast Guard-approved treatment systems (McAllister, 2000). According to a 2008 report from the U.S. EPA, the problems identified in 2000 with MSDs continue today (EPA, 2008).

Sewage Treatment - Advanced Wastewater Treatment Systems (AWTS).  The cruise industry in recent years has adopted the use of AWTS (an advanced form of type II Marine Sanitation Device) on many ships – most often ships visiting Alaska’s Inside Passage where such systems are required for continuous discharge in state waters.  A ship with an AWTS avoids the need to travel outside Alaska state waters to discharge treated sewage.  Installation of AWTS for ships visiting other waters with less stringent or no regulation has been at a much slower pace.  For example, Carnival Corporation (which includes Carnival Cruise Lines, Holland America Lines, and Princess Cruises) had AWTS installed on slightly more than one third of its fleet at the end of 2007.  But Carnival Cruise Lines, which sends only one ship to Alaska per season, has installed AWTS in only one of its twenty-two ships. The corporation’s spokesperson says they try to make sure AWTS are included on ships that go to Alaska and to other sensitive areas.

AWTS are a vast improvement over MSDs — yielding what the industry refers to as drinking-water quality effluent.  However this terminology must be treated with skepticism.  Such water cannot be recycled for onboard human consumption nor can it be used in the laundry because sheets and towels apparently turn gray. Both the EPA and Alaska have found that even the best systems still had difficulty with a number of constituents.  A key problem is the AWTS do not adequately address nutrient loading, which means they pose similar problems as MSDs with regard to nitrogen and phosphorous.  In addition, tests in Alaska have shown levels of copper, nickel, zinc, and ammonia that are higher than the state’s water quality standards (Alaska DEC, 2004:29). The EPA also found AWTS sometimes exceed permitted concentrations of chlorine and tetrachlorethylene.  As a result, 12 of 20 (60%) ships permitted to discharge in Alaska waters violated discharge limits in 2008, logging 45 violations involving 7 pollutants. These include ammonia, biological oxygen demand, chlorine, copper, fecal coliform, pH, and zinc (Golden, 2008).

Royal Caribbean stated in 2003 that, “two of the three prototype systems on our ships today have proven unsatisfactory and we will replace them with even newer prototypes” (Fain, 2003). Moreover, given that these systems are not regularly tested, except by Alaska, and that they are prone to breakdown and require constant maintenance and care, there is a need to be cautious with regard to where the effluent from an AWTS can be released.  The need for caution is further supported by a 2007 study by the Washington State Division of Environmental Health that found, “AWTS can effectively remove bacteria but may not eliminate viruses that cause illnesses” (Washington State Department of Health, 2007). The report recommends no discharges should occur within 0.5 nautical miles of bivariate shellfish beds that are recreationally harvested or commercially approved for harvest, and that cruise ships should withhold discharge when a system upset occurs.

Sewage Sludge. Most type II MSDs and AWTS filter solids from sewage as part of treatment.  This yields on average 4,000 gallons of sewage sludge per day (National Marine Sanctuaries, 2008: 43); cumulatively, it adds up quickly.  It is estimated that 4.2 million gallons of sewage sludge are produced every year by ships as they pass through Washington State waters on their way to Alaska (King County Wastewater Treatment Area, 2007) – this is small compared to what cruise ships generate outside Washington state waters.  In some cases (about one in sixteen ships with an AWTS), sewage sludge is dewatered and then incinerated.  In other cases sludge is dumped at sea. These sludges have a high oxygen demand and are detrimental to sea life.  Sewage sludge poses the same problem as sewage, but in a more concentrated form.  

A report issued in August 2003 by the California Environmental Protection Agency and the California state Water Resources Control Board said “it found ‘particularly troubling’ the discharging of sludge 12 miles out to sea” (Weiss, 2003; Cruise Environmental Task Force, 2003). This concern is in stark contrast to regulations elsewhere that define sewage sludge as treated sewage and permit its discharge as according to those criteria.  

One option is to require sewage sludge to be dewatered and incinerated onboard, however incineration creates an air quality problem and the ash must be disposed of somewhere.  Dumping the ash overboard raises new problems.  Another option is to require sewage sludge to be held onboard and offloaded for treatment in port.  Washington State has in recent years explored the commercial use and value of sewage sludge as a fertilizer, but no clear plans have yet been made (Port of Seattle, 2008). Clearly, a workable solution to the huge volume of sludge being dumped into the oceans – 28,000 gallons per week on an average-sized cruise ship – must be identified and implemented.

Gray Water.  Gray water is wastewater from sinks, showers, galleys, laundry, and cleaning activities aboard a ship.  It is the largest source of liquid waste from a cruise ship: as much as 90 gallons per day per person; over half a million gallons per day for a ship such as Freedom of the Seas. Like sewage, gray water can contain a variety of pollutants. These include fecal coliform bacteria, detergents, oil and grease, metals, organics petroleum hydrocarbons, nutrients, food waste and medical and dental waste (Copeland, 2008). The greatest threat posed by gray water is from nutrients and other oxygen-demanding materials. The cruise industry characterizes gray water as innocuous, at worst. A 2008 report from the Congressional Research Service disagrees. It states:

Sampling done by EPA and the state of Alaska found that untreated gray water from cruise ships can contain pollutants at variable strengths and that it can contain levels of fecal coliform bacteria several times greater than is typically found in untreated domestic wastewater. Gray water has potential to cause adverse environmental effects because of concentrations of nutrients and other oxygen-demanding materials, in particular:” (Copeland, 2008:4)

As recently as the 1980s ships were designed with pipes that directly discharged gray water overboard no matter where the ship was. Today gray water is more commonly collected in a holding tank and discharged, through a screen that filters out plastics, when a ship is one mile from the shore. Some vessels with AWTS mix gray water with sewage and they are treated together. This isn’t always possible. Gray water lacks sufficient nutrients for a bioreactor system to properly function so ships using this design release their gray water with limited or no treatment.

Solid Waste. A cruise ship produces a large volume of non-hazardous solid waste. This includes huge volumes of plastic, paper, wood, cardboard, food waste, cans, glass, and the variety of other wastes disposed of by passengers. It was estimated in the 1990s that each passenger accounted for 3.5 kilograms of solid waste per day (Herz and Davis, 2002). With better attention to waste reduction this volume in recent years has been cut nearly in half. But the amount is still significant, more than eight tons in a week from a moderate sized cruise ship. Twenty-four percent of the solid waste produced by vessels worldwide comes from cruise ships (Copeland, 2008). Glass and aluminum are increasingly held onboard and landed ashore for recycling when the itinerary includes a port with reception facilities.

Food and other waste not easily incinerated is ground or macerated and discharged into the sea. These “… food wastes can contribute to increases in biological oxygen demand, chemical oxygen demand, and total organic carbon; diminish water and sediment quality; adversely effect marine biota; increase turbidity; and elevate nutrient levels” (EPA, 2008:5-11). They may be detrimental to fish digestion and health and cause nutrient pollution (Polglaze, 2003). An additional problem with discharging food waste at sea is the inadvertent discharge of plastics. Under Annex V of MARPOL, throwing plastic into the ocean is strictly prohibited everywhere. Plastic poses an immediate risk to sea life that might ingest or get caught in it. It poses a longer term risk as it degrades over time, breaking down into smaller and smaller pieces, but retaining its original molecular composition. The result is a great amount of fine plastic sand that resembles food to many creatures. Unfortunately, the plastic cannot be digested, so sea birds or fish can eventually starve to death with a stomach full of plastic (Reid, 2007).

Solid waste and some plastics are incinerated on board, with the incinerator ash being dumped into the ocean. Incinerator ash and air emissions can contain furans and dioxins, both found to be carcinogenic,  as well as heavy metal and other toxic residues. For this reason Annex V of MARPOL dictates that ash should not be discharged into the sea (EPA, 2008:5-12). At the very least, incinerator ash should be tested before each overboard discharge. This would include analysis and accounting of the contaminants typically found in cruise ship incinerator ash to determine whether it should be categorized as solid waste or hazardous waste (EPA, 2008:5-15).

Under MARPOL no garbage can be discharged within three miles of shore. Between three and twelve miles garbage can be discharged if ground-up and capable of passing through a one-inch screen. If not ground-up and capable of passing through a screen, most food waste and other garbage can be discharged at sea when a ship is more than twelve miles from shore.

Although cruise ships have reduced their volume of solid waste, the total amount is still significant. Royal Caribbean’s stated commitment in 2003 to not dump any trash overboard is admirable and should set a standard for all cruise ships operating on the world’s oceans. If it is achievable by Royal Caribbean, then there is no reason why it is not practical for all cruise lines. This should be incorporated in legislation or international conventions in order to ensure cruise ships can be held accountable for unnecessarily dumping solid waste in the ocean.

Hazardous Waste. A ship produces a wide range of hazardous waste. These include photo processing chemicals, dry cleaning waste, used paint, solvents, heavy metals, expired chemicals and pharmaceuticals, waste from the print shop, hydrocarbons and chlorinated hydrocarbons, used fluorescent and mercury vapor light bulbs, and batteries (U.S. Bureau of Transportation, 2002; EPA, 2008:6-2 – 3). Although the volume produced by a ship may be relatively small (less than 1,000 liters in a typical week), the toxicity of these wastes makes them a serious concern. Hazardous wastes must be carefully managed in order to avoid their contamination of other waste streams (e.g., gray water, solid waste, bilge water, etc).

Oily Bilge Water. A typical large cruise ship will generate an average of eight metric tons of oily bilge water for each twenty-four hours of operation (National Research Council, 1995); according to Royal Caribbean’s 1998 Environmental Report its ships produce an average 25,000 gallons of oily bilge water on a one week voyage. This water collects in the bottom of a vessel’s hull from condensation, water lubricated shaft seals, propulsion system cooling and other engine room sources. It contains fuel, oil, wastewater from engines and other machinery, and may also include solid wastes such as rags, metal shavings, paint, glass, and cleaning agents.

The risks posed to fish and marine organisms by oil and other elements in bilge water are great. In even minute concentrations oil can kill fish or have numerous sub-lethal effects such as changes in heart and respiratory rates, enlarged livers, reduced growth, fin erosion, and various biochemical and cellular changes (Copeland, 2008). Research also finds that by-products from the biological breakdown of petroleum products can harm fish and wildlife and pose threats to human health if these fish and wildlife are ingested.

Oily bilge water is normally passed through a fifteen parts per million (ppm) oily water separator for discharge within twelve miles of the coast; to 100 ppm (Copeland, 2008). for discharge beyond twelve miles from the U.S. shoreline. The oil extracted by the separator can be reused, incinerated, and/or offloaded in port (Copeland, 2008:5 – 6). Vessels are required to document the disposal of oil, oily bilge water or oily residues in an Oil Record Book (Copeland, 2008:14). To address the deleterious effect of oil to marine life, even in minute quantities, the discharge of oily bilge water should be prohibited in sensitive areas and in coastal zones.

Ballast Water. Cruise ships like other ocean-going vessels use a tremendous amount of ballast water to stabilize the vessel during transport. This water is often taken on in one location after a ship discharges wastewater or unloads cargo and then discharged at the next port of call. “[Ballast water] … typically contains a variety of biological materials, including plants, animals, viruses and bacteria ... These materials include non-native, nuisance, exotic species that can cause extensive ecological and economic damage [and] … pose public health and environmental risks as well as significant economic cost to industries such as water and power utilities, commercial and recreational fisheries, agriculture and tourism.” (Copeland, 2008:6) The problem is not limited to cruise ships – it is a problem posed by all ships traversing the world’s oceans

Cruise Ship Air Pollution

There are two sources of air emissions from cruise ships: incinerators and engines. Each presents its own set of issues.

Incinerators. Cruise ships incinerate and burn a variety of wastes, including hazardous wastes, oil, oily sludge, sewage sludge, medical and bio-hazardous waste, outdated pharmaceuticals, and other solid wastes such as plastics, paper, metal, glass, and food. A cruise ship may burn 1 to 2.5 tons per day of oily sludge in these incinerators and boilers (California Cruise Ship Environmental Task Force, 2003). The emissions from onboard incineration and its ash can include furans and dioxins, both found to be carcinogenic, as well as nitrogen oxide, sulfur oxide, carbon monoxide, carbon dioxide, particulate matter, hydrogen chloride, toxic and heavy metals such as lead, cadmium and mercury, and hydrocarbons (Bluewater Network, 2000).

In contrast to incinerator use on land, which is likely to be strictly monitored and regulated, incinerators at sea operate with few limits.  MARPOL Annex VI bans incineration of certain particularly harmful substances, including contaminated packaging materials and polychlorinated biphenyls (PCBs). There are no international standards limiting emissions from ship incineration.

The State of California has established that air emissions from incineration, generated between 27 and 100 miles off the coast, could negatively impact the air quality of the state (California Cruise Ship Environmental Task Force, 2003). The state initially introduced legislation in 2003 to prohibit ships from using onboard waste incinerators while within 20 miles of the coast, but subsequently passed legislation applicable only to waters over which the state had jurisdiction. The final California law prohibits incinerator use when a ship is within three miles of the coast.

Clear parameters are needed for operational requirements for onboard incinerators, much like on land. In addition, it is wise to do as California has done and ban the use of incinerators within a specific distance from the coast. Any such law must take into account the potential for onshore winds and ocean currents to move incinerator pollutants on-shore.

Engine Emissions. Air emissions from ship engines are an obvious source of pollution because many ships burn bottom-of-the-barrel bunker fuel – typically what remains of the crude oil after gasoline and the distillate fuel oils are extracted through distillation. An estimated 60,000 died worldwide in 2002 as a result of under-regulated shipping air emissions and that number is estimated to grow by 40 percent by 2012 due to increases in global shipping traffic (Corbett et al, 2007). According to the U.S. EPA, oceangoing ships each year emit 870,000 tons of nitrogen oxide, a key contributor to smog. Conventionally a cruise ship’s environmental impact is likened to the impact of 12,000 automobiles (Oceana, 2003). A study published in 2007 raises an even greater alarm. It found that bunker fuel on average has almost 2,000 times the sulfur content of highway diesel fuel used by buses, trucks, and cars and that one ship can make as much smog-producing pollution as 350,000 cars (Waymer, 2007). This figure can vary widely depending on the fuel being burned. A number of ships began using gas turbine engines in the late 1990s and early 2000s, well before the spike in fuel costs in 2007. These gas turbines are considerably better than conventional cruise ship engines in terms of sulfur and nitrous oxide emissions.

Current international standards set maximum sulfur content for ocean going vessel fuel at 4.5 percent, making it easy for cruise lines to say they meet or exceed international regulations since bunker fuel averages 3 percent sulfur content. New international standards will require a reduction of ship fuel sulfur content to 3.5 percent in 2012 and 0.5 percent in 2020 or 2025. In contrast, lower sulfur fuels such as on road diesel currently have sulfur contents as low as 0.0015 percent. Use of lower sulfur fuel reduces particulate matter 58 percent, sulfur 99.6 percent, and oxides of nitrogen 11 percent (Klein, 2003:52). Cruise lines have been resistant to adopting use of fuels below 3 percent because of their higher cost.

Another way in which air emissions can be curtailed is by imposing reduced speed limits as cruise ships approach ports. In February 2009, the Port of San Diego moved forward with a vessel speed reduction program (Port of San Diego, 2009). Cruise and cargo ships will be asked to voluntarily reduce their speed when entering and leaving San Diego Bay in an effort to reduce air pollution. The voluntary speed limit will be 15 knots for cruise ships when traveling in an area that extends 20 nautical miles out to sea from Point Loma; cargo ships are expected to reduce speed to 12 knots. According to port officials, studies have shown a significant reduction in air emissions from ship engines when speeds are reduced – particularly significant reductions in emissions of oxides of nitrogen, oxides of sulfur, diesel particulate matter and carbon dioxide (California Environmental Protection Agency, 2009). Similar programs have been enacted by the ports of Los Angeles and Long Beach, which report the program saved more than 100 tons of nitrogen oxide from going into the air in the first three months of implementation (Port of Los Angeles, 2005).

Another way to grapple with the problem of air emissions from engines is cold ironing, the option for ships to turn off all engines while in port and to plug into shore side power. Cold-ironing was first introduced in 2001 in a partnership between the port of Juneau and Princess Cruises and is slowly propagating to other locations, including the ports of Vancouver, Los Angeles, Long Beach, and Seattle. The west coast of the U.S. is setting an example for the rest of the country and the practice of cold ironing should be encouraged, if not required, along all coasts of the U.S.

While the industry argues that it meets or exceeds MARPOL limits, it must be recognized that these regulations are minimal and fall far short of those already in place in California where ships will be required to use marine gas oil, or marine diesel oil with a sulfur content of no more than 0.5 percent by weight in all diesel engines within 24 nautical miles of the coast beginning in July of this year (sulfur content of marine gas oil drops to 0.1 percent sulfur in 2012). According to the California Air Resources Board, the use of low sulfur fuel in auxiliary engines used in port could save 3,600 lives in coastal communities over the first six years through reduced respiratory illnesses and heart disease, including a potential 80% drop in cancer risk associated with ship pollutants (Roosevelt, 2008:B1). The results are even more impressive if auxiliary engines are shut down and shore side power is used instead.

Believe What We Say, Not What We Do

Despite its environmental record, the cruise industry presents itself as environmentally concerned, responsible, and reformed after all the pollution incidents in the 1990s and early 2000s. They attempt to disarm critics with statements such as, “We visit some of the most pristine areas of the world and our income depends on them staying that way, so why would we pollute?” It is a compelling argument, but as already seen is at variance with continued behavior.

Monterey Bay (2002). In April 2002, representatives from environmental organizations, the City of Monterey, the State of California and the Monterey Bay National Marine Sanctuary met with cruise lines planning to visit Monterey and told them that if they could not refrain from soiling waters of the bay, they should stay away. Crystal Cruises was among the four cruise lines that travel into Monterey Bay and it sent a letter to the city.

Tom Greene, director of safety, environment and training for Crystal Cruises, which plan[ned] to dispatch its Crystal Harmony to Monterey on Oct. 9, said company officials had promised to withhold all liquid and solid waste water while in Monterey Bay. Even though a company policy forbids such dumping, Mr. Greene said the company wanted to reassure local officials in writing that it would abide by their demands." (Madigan, 2002)

The company’s vice president, Joseph Valenti, signed the letter to the California Regional Water Quality Control Board, stating: “Crystal Harmony will observe a no-discharge policy in the Monterey Bay National Marine Sanctuary … This policy will apply to all wastewater, ballast water, water discharged through the oily water separator, and all forms of solid waste” (Madigan, 2002). Valenti reiterated the company’s commitment at a public lecture given by this author at the Monterey Institute for International Studies on January 14, 2003. He complained both publicly and privately that he had been denied time to present the cruise line’s point of view at the lecture. However he made statements during the lecture asserting that Crystal Cruises was an exemplary company in the industry given its high environmental standards.

In late-February 2003 it was learned, through the California State Water Resources Control Board’s review of ship’s logs, that the Crystal Harmony had in fact discharged 34,078 gallons of gray water, 264 gallons of treated black water, and 2,118 gallons of processed bilge water into Monterey Bay. When asked why they hadn’t reported the discharge when it occurred, Valenti, defended the silence by saying the company had only broken its promise; it hadn’t violated any laws (Laidman, 2003). ICCL President, Michael Crye, also dismissed the violation telling a news reporter the ship’s discharge occurred 14 miles from the coast so it wasn’t illegal (Fletcher, 2003).

The people of Monterey expressed their extreme displeasure with these discharges and on March 18, 2003, the Monterey City Council voted to bar all Crystal Cruises ships from entering the port of Monterey for 15 years and barred the Crystal Harmony forever (Madigan, 2003).

Carnival Corporation (2003-2004). Despite paying an $18 million fine as part of its plea agreement in 2002, Carnival was back in federal court within a year. It had been summoned by the court in July 2003 after a probation officer reported the company failed to develop, implement and enforce the terms of an environmental compliance program stemming from the 2002 plea agreement. Holland America employees reportedly submitted twelve audits that contained false, misleading and inaccurate information Dupont, 2003; Tobin, 2003). Carnival Corporation replied to the court that three environmental compliance employees had been fired for the reports but it did not admit violating its probation. In a settlement signed August 25, 2003, Carnival agreed to hire four additional auditors and to provide additional training for staff (Perez, 2003).

Carnival Corporation was back in court in July 2004. Its Holland America Line’s former vice president for environmental compliance pleaded guilty to certifying environmental compliance audits that were never performed (Klein, 2007).

Royal Caribbean (2003-2008). Royal Caribbean has also contradicted word and deed. The CEO of the corporation issued a form letter on September 24, 2003 responding to letters he received as part of a social action campaign pursued by Oceana. The letter clearly states that the company discharges its black water (wastes from toilets) and its gray water “only when we are 12 or more miles from the shore and moving at least six knots” (Fain, 2003). The letter proudly promotes Royal Caribbean’s policies and procedures for exceeding Coast Guard requirements and as stricter than U.S. law. It’s an impressive claim, but is contradicted with a report in December 2003 that the company had 12 times violated Hawaii’s MOU 12 times that prohibits discharges within four miles of the coast (Yamanouchi, 2003).

More recently, since coming off probation in 2004, Royal Caribbean has reportedly returned to discharging untreated effluent beyond three nautical miles from shore and at variance with its public commitment to only discharge beyond 12 miles. The company reportedly has also changed the required qualifications of environmental officers and has reduced their onboard status. This was obviously the case with a 2006 discharge of 500,000 gallons of wastewater in Puget Sound (see above) and its discharge of 20,000 gallons of wastewater into Chatham Strait in Southeast Alaska on June 10, 2008.

Cruise Industry Responds

Several weeks after the July 1999 plea agreement between the Department of Justice and Royal Caribbean, the International Council of Cruise Lines (ICCL) made a commitment on July 27 to standards for waste management. The ICCL assured that “…member lines have strengthened their own environmental policies and procedures, and closely monitor onboard activities to ensure these standards are maintained. The internal procedures are designed to meet existing and comprehensive federal, state, and international standards designed to prevent discharges from all commercial vessels” (ICCL, 1999). While the commitment and mandatory standards set protocols for performance, there are no criteria for verification and enforcement, nor are there regulatory targets. Furthermore, no member cruise line has ever been publicly sanctioned or had its membership in ICCL withdrawn for environmental violations.

The ICCL restated its environmental commitment two years later in June 2001 with “New Mandatory Environmental Standards for Cruise Ships.” The standards were announced while the Alaska State Senate was in special session considering legislation that would authorize monitoring of cruise ship emissions and enforce environmental standards, and following two new violations in Alaska waters in May 2001 – NCL’s Norwegian Sky discharged black water for 20 to 30 minutes while in the Alexander Archipelago, leaving a waste stream of up to three-quarters of a mile; Holland America Line’s Westerdam accidentally discharged 100 gallons or more gray wastewater while docked in Juneau. The new standards, announced June 11, 2001, responded to the public outcry against the types of pollution deposited in Alaska’s waters.

The industry’s record suggests it responds most effectively to legislation, as seen by the effectiveness of Alaska’s approach that includes direct monitoring and enforcement. It also responds to public pressure, but the nature of the response is to promote its commitment to environmental protection and responsibility – words that are not consistently seen in behavior. Take for example the ICCL’s statements between July 1999 when Royal Caribbean was fined $18 million and June 2001 when the Alaska legislature was about to approve the Alaska Cruise Ship Initiative. On July 27, 1999, an ICCL press release said: “These incidents have served as an important wake-up call, causing our industry to redouble its efforts to improve its environmental performance.” On October 4, 1999, an ICCL press release said: “The International Council of Cruise Lines (ICCL) today released a statement that outlines the industry's plans to enhance and strengthen environmental standards for the cruise industry in the area of waste disposal and onboard waste management.” On April 28, 2000, ICCL had a letter to the editor published in the St. Petersburg Time – it said: “Our member cruise lines are committed to protecting and preserving the environment. The industry will continue to work diligently with lawmakers, regulators and stakeholders to ensure that our joint efforts continue to reflect that commitment.” And on June 10, 2001, the ICCL president, Michael Crye, was quoted by the Associated Press as saying, “Regrettably, there have been violations of environmental laws involving cruise lines in the past few years. These incidents served as a wake-up call” (Klein, 2005:144). But cruise line environmental violations continue to this day.


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Klein, Ross A. 2009. Cruising without a Bruising: Cruise Tourism and the Maritimes, Halifax:Canadian Centre for Policy Alternatives.

Klein, Ross A. 2008. Paradise Lost at Sea, Halifax: Fernwood.

Klein, Ross A. 2007. “The Politics of Environmental Activism: A Case Study of the Cruise Industry and the Environmental Movement.” Sociological Research Online 12, 2 (March).

Klein, Ross A. 2005. Cruise Ship Squeeze: The New Pirates of the Seven Seas, Gabriola Island, BC:New Society.

Klein, Ross A. 2003. Charting A Course: The Cruise Industry, The Government of Canada, and Purposeful Development, Halifax: Canadian Centre for Policy Alternatives.

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Juneau Empire. 2008b. “More Cruise Ships Cited for Wastewater,” Juneau Empire, October 2.

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Madigan, Nick. 2002. “After Promise of Purity, a Cruise Ship Calls on Monterey,” New York Times, September 19.

McAllister, Bill. 2000. “A Big Violation on Wastewater: Some Ship Readings 100,000 Times Allowed Amount,” The Juneau Empire, August 27,

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Yamanouchi, Kelly. 2003. "Cruise Lines Admit Pollution Violations," Honolulu Advertiser, December 12.


Ross A. Klein is an internationally recognized authority on the cruise ship industry. The Memorial University of Newfoundland professor of social work has published four books on the industry, commissioned to write four reports for the Canadian Centre for Policy Alternatives, two reports for Bluewater Network/Friends of the Earth, and has more than a dozen articles and book chapters in academic and non-academic venues. (complete biography)

He maintains Cruise Junkie dot Com and the International Centre for Cruise Research; his work is equally academic and applied. He has given invited lectures at international conferences, universities, and to community organizations in the UK, across Canada and the US, across the Caribbean, in Mexico, Australia, and New Zealand. In addition, Klein is often quoted in media around the world, is frequently interviewed on television and radio, and has been/is an expert witness in a range of lawsuits against the cruise industry. He has given invited testimony to the San Francisco Board of Supervisors, Hawai’i County Council, US House of Representatives and US Senate.

Ross received his B.S. from Arizona State University, MSW from University of Maryland, and M.A. and PhD from Syracuse University. His books include: Death by Chocolate: What You Must Know Before Taking a Cruise – 2001, Cruise Ship Blues: The Underside of the Cruise Industry – 2002, Cruise Ship Squeeze: The New Pirates of the Seven Seas – 2005, Paradise Lost at Sea: Rethinking Cruise Vacations – 2008.


• Naomi Kabak
Senior Vice President
Group IST

• Guy A Young
President & CEO of Uniworld Boutique River Cruise Collection

• Larry Pimentel
President & CEO of Azamara Club Cruises

• Cdr Mark Gaouette
Maritime Security Consultant
Department of Homeland Security

• Rick Sasso
President and CEO
MSC Cruises

• Diane Moore
Windstar Cruises

• Paul Strachan
Pandaw River Cruises

• James Rodriguez
Senior Vice President, Marketing
Oceania Cruises

• Colin Stone
Managing Director
Swan Hellenic

• Mike Deegan
Managing Director
Hebridean Island Cruises

• Derek Banks
European Waterways Ltd

• Ken Carver
International Cruise Victims Association (ICV)

• Terry Dale
President and CEO
Cruise Lines International Association (CLIA)

• Lawrence Dessler
Executive Director
Niche Cruise Marketing Alliance (NCMA)

• Ross A Klein

• Bob Levinstein
Cruise Compete

• Alan Lewis
Grand Circle Corporation & Grand Circle Cruise Lines

• Albert Peter
Chief Executive Officer
Silversea Cruises

• Dietmar R Wertanzl
President and Chief Executive Officer
Cruise West