Welcome To Brazil: Understanding ANVISA Food Safety Requirements

Image of a Brazilian woman with a flag of Brazil, with the words Welcome To Brazil Understanding ANVISA Food Safety Requirements

With its combination of breathtaking scenery, tropical rainforests, vibrant cultural experiences, and picturesque coastlines, Brazil is popular destination for cruise ships. In recent years, the cruise market in Brazil has experienced significant growth, attracting both domestic and international travelers. According to CLIA Brazil (Associação Brasileira de Cruzeiros Marítimos)—part of the global Cruise Lines International Association, the world’s largest cruise industry trade organization—from October 2023 to May 2024, the cruise sector is anticipated to contribute approximately R$3.9 billion (US$780 million) to the nation’s economy.

The Brazilian National Health Surveillance Agency (Agência Nacional de Vigilância Sanitária, ANVISA)—an autarchy linked to the Brazilian Ministry of Health—coordinates the public health controls at ports and borders to ensure compliance with both Brazilian legislation and international health regulations. The Brazilian Sanitary Guide for Cruise Ships (Guia Sanitário Para Navios de Cruzeiro) is a comprehensive manual outlining the sanitation requirements international cruise vessels operating in Brazilian waters must adhere to.

While there is a general resemblance to the CDC’s Vessel Sanitation Program (VSP) guidelines—the cruise industry’s de facto standards for cruise ship public health—distinct variations exist that cruise operators and ship management companies must be aware of.

ANVISA Food Receiving Requirements

Section 1.3 of the Brazilian Sanitary Guide addresses the loading of food items onto a vessel. The term ‘food’ encompasses all forms of edible substances intended for human consumption, including ice and beverages, regardless of whether raw, cooked, or otherwise processed.

Maintaining food-handling areas—where food is stored, processed, prepared, or served—in a clean and hygienic condition is a fundamental principle of food safety management. Neglecting to do so increases the risk of cross-contamination and pest infestations. The regulations set forth by ANVISA, however, go one step further by stipulating that food receiving areas must be sanitized immediately prior to loading:

“The food receiving area must be periodically cleaned and whenever necessary. Sanitization processes (cleaning and disinfecting) must take place immediately before food entry. Disinfectant manufacturer’s instructions, including concentration and contact time, must be strictly followed.”

Brazilian Sanitary Guide for Cruise Ships (2019)

For fruits and vegetables, ANVISA recommends they are sanitized (using chemicals or another efficient system) before being transferred to food storage facilities on board. Where this is not feasible, fruits and vegetables must be sanitized before they enter food preparation areas: any location where food is processed, cooked, or prepared for service.

In comparison, the corresponding standard from the VSP 2018 Operations Manual (7.3.3.2.4 Wash Fruits/Vegetables) instructs crew to ensure all raw fruits and vegetables are “thoroughly rinsed in water to remove soil and other contaminants before being cut, combined with other ingredients, cooked, served, or offered for human consumption”.

The Brazilian sanitary guidelines are quite specific regarding documentation requirements for food supplies delivered to a vessel. The condition and quality of food must be checked upon receipt, with the following basic information recorded:

  • Date of delivery
  • Vendor name
  • License plate of the delivery vehicle
  • Product name
  • Quantity (e.g., weight or volume)
  • Batch number
  • Expiration date
  • Confirmation if approved or rejected
  • A description of actions taken in cases of defects
  • The signature of the crew member responsible

In the case of perishable foods—those that spoil, decay, or become unsafe to consume if not maintained under proper temperature control—documentation must also capture the temperature at which the goods were received, as well as the temperature inside the transport vehicle’s refrigerated storage compartment. Records must be maintained on board throughout the vessel’s entire Brazilian cruise season.

ANVISA Food Storage Requirements

Most food stored on board must have some form of designation on its packaging—a date, a code, or a number—that can be used to confirm the product’s expiration date. Verification by means of technical or commercial documents is permitted. Terms such as “use by,” “best before,” or other comparable expressions, for the purposes of the manual, designate the same.

Food items without expiration dates “must be kept segregated and unavailable while the ship remains in Brazilian territorial sea.” When food is removed from its original packaging, it must be appropriately stored and labelled with the following information (as applicable):

  • Product name
  • Manufacturer’s name
  • Batch or lot number
  • Expiration date and shelf life after opening

Measures must be implemented in storage areas for the precise administration of food disposal dates, using systems such as “First In First Out” (FIFO). Control steps must be “formally described” (formalmente descrito) and can be achieved through a variety of methodologies including color coding, bar code readings, or spreadsheets. Where logs are used, they must contain information that identifies the product, date of manufacture and expiry, and the date of entry and exit from the storage area on board.

ANVISA Food Preparation Requirements

Section 1.5.3 of the Brazilian Sanitary Guide addresses food preparation. It is important to note three specific variations that stand out when compared to VSP standards.

The first divergence in requirements concerns the thawing of perishable foods, or potentially hazardous food (PHF) as referred to within the VSP guidelines. The VSP 2018 Operations Manual offers three principal methods (7.3.5.1.3 Thawing) to defrost potentially hazardous food:

  • Under refrigeration that maintains the food temperature at 5°C (41°F) or less
  • As part of a cooking process in a microwave oven
  • When submerged under running water at a water temperature of 21°C (70°F) or below

ANVISA regulations do not permit thawing frozen food under cold running water. Apart from the unsafe practice of defrosting food at room temperature, using running water is one of the least safe methods for thawing perishable food. This is because food temperatures can rise into the ‘Temperature Danger Zone’: a critical concept in food safety referring to a temperature range between 5°C to 60°C (41°F to 140°F). Within this range, bacteria can grow rapidly, increasing the risk of foodborne illnesses.

The second notable deviation pertains to the preparation of ready-to-eat (RTE) food: food that can be consumed in its current state without the need for additional washing, cooking, or preparation. According to the VSP 2018 Operations Manual:

“Refrigerated, ready-to-eat, potentially hazardous food, prepared on a vessel and held refrigerated for more than 24 hours must be clearly marked at the time of preparation to indicate the date or day by which the FOOD must be consumed (7 calendar days or fewer from the day the FOOD is prepared). The day of preparation is counted as day 1.”

VSP 2018 Operations Manual

In comparison, ANVISA guidelines take a more conservative approach, advising that RTE food can be kept under refrigeration for a maximum of five days before it must be consumed or discarded. Cruise ships often prepare food ahead of time but considering internal food quality standards—the degree to which food meets consumer expectations—not many dishes will be made a full week before they are needed.

The third significant difference regards the storage and transportation of refrigerated perishable foods:

“Storage and transport of refrigerated food must occur under temperature conditions that do not compromise their quality and safety. The temperature required in this situation is below 5 °C (41 °F) and must be monitored and logged throughout all of the storage and transport steps.”

Brazilian Sanitary Guide for Cruise Ships (2019)

While ensuring a holding temperature of 5°C (41°F) or less is generally comparable across both guidelines, ANVISA documentation requirements surpass those of the VSP, which do not mandate maintaining temperature records for the storage and transportation of food.

Other notable food safety variations between the two set of guidelines include the ANVISA requirement that cutlery in self-service restaurants (buffets) must be wrapped in clean napkins, or placed into disposable wrappers, to prevent the cross-contamination of utensils.

Are There Other Differences Between ANVISA and VSP Standards?

The Brazilian Sanitary Guide and VSP Operations Manual are both divided in chapters and subsections that comprehensively address numerous operational aspects crucial in safeguarding public health aboard cruise vessels. The chapters encompass a range of topics such as communicable disease surveillance, outbreak management, food safety, potable water, recreational water facilities, pest management, and housekeeping services.

As public health requirements in both manuals are principally based on scientific research, the control measures for preventing the emergence and spread of infectious diseases are similar. Nonetheless, regulation deviations do exist across most of the topics covered. Broadly speaking, when variances occur, the Brazilian Sanitary Guide usually adopts a more prescriptive and cautious approach when compared with the VSP manual.

Both VSP and ANVISA conduct sanitary inspections on cruise ships to verify adherence to their respective standards. In Brazil, any health violations identified must be rectified immediately as the vessel will typically undergo a follow-up inspection upon arrival at the next Brazilian port. In contrast to VSP, ANVISA does not issue an inspection grade or score: cruise lines simply must ensure any infractions are promptly addressed.

Conversely, in the U.S., cruise ships are afforded an extended timeframe to resolve issues cited by VSP, unless the vessel fails its inspection, or the violations pose an imminent risk to public health. VSP does not verify that the deficiencies raised have been corrected until the cruise ship’s next inspection, typically scheduled 5-6 months later. Additionally, failing a VSP inspection rarely results in consequences for the cruise line involved other than reputational damage; the issuance of a no-sail recommendation or order is extremely rare.

Under Brazilian law, however, ANVISA has the authority to impose civil, administrative, and criminal penalties for health violations. Within its guidelines, there is a clear warning:

“Non-compliance with the requirements established by Brazilian Health Legislation is a health violation, pursuant to Law No. 6.437 of August 20, 1977, also subject to civil, administrative and criminal penalties that are deemed appropriate.”

Brazilian Sanitary Guide for Cruise Ships (2019)

To avoid legal or financial consequences as a result of non-compliance, it is crucial when sailing in Brazilian waters that cruise line executives, ship management companies, and on board staff recognize there may be differences between their public health Standard Operating Procedures (SOPs) and the ANVISA requirements. Often, such marginal variations can be overlooked, but as the popular idiom alludes, “The devil is in the details.”