The Brazilian author Paulo Coelho once said, “Be brave. Take risks. Nothing can substitute experience.” However, as the cruise season in Brazil approaches, gambling on compliance with the region’s specific public health requirements might not be the best option for cruise operators aiming to avoid legal or financial repercussions.
The latest Brazilian Sanitary Guide for Cruise Ships (Guia Sanitário Para Navios de Cruzeiro nº 65/2023 – versão 4) outlines the hygiene and sanitation regulations that international cruise ships must adhere to when sailing in Brazilian waters. While these regulations share similarities with the CDC’s Vessel Sanitation Program (VSP) guidelines, the unique variations of the Agência Nacional de Vigilância Sanitária (ANVISA) necessitate close attention.
In our previous article, “Welcome to Brazil: Understanding ANVISA Food Safety Requirements,” we explored the key differences in food safety regulations. This time, we turn our focus to the distinct requirements for potable water and recreational water facilities, ensuring that your fleet is well-prepared for a smooth and compliant cruise season in Brazil.
ANVISA Potable Water Bunkering Requirements
ANVISA requirements for bunkering potable water are quite similar to those in the VSP 2018 Operations Manual. However, there is one key difference to note.
Both manuals mandate that vessels must request a copy of the latest microbiological report from each port before bunkering to verify that the water meets safe drinking water standards. According to the VSP guidelines, this report must include, at a minimum, an analysis for Escherichia coli (E. coli). In contrast, Section 4.2.1 Abastecimento e produção (Supply and production) of the ANVISA regulations requires the report to include an analysis of both thermotolerant coliforms (E. coli is a thermotolerant coliform) and total coliforms.
Where a report is not available, water samples can be collected and analyzed by the ship. Therefore, ensuring your vessels have a suitable test kit and an adequate supply of associated equipment, such as IDEXX Colisure™, is important.
ANVISA Potable Water Storage Requirements
If your Standard Operating Procedures (SOPs) comply with the current VSP Operations Manual requirements for potable water tanks, you should be well-prepared for sailing in Brazil, with one notable exception.
According to Section 5.3.4.1.2 Inspection of the VSP Ops Manual, “POTABLE WATER TANKS must be inspected, cleaned, and disinfected at least every 2 years.” However, ANVISA’s requirements are stricter, mandating a minimum timeframe of 1 year:
“Os reservatórios de água potável devem ser inspecionados, limpos e desinfetados durante as docagens, sejam secas ou molhadas, ou anualmente. Os registros das atividades de manutenção, limpeza e desinfecção dos tanques e sistema de distribuição de água potável devem ser mantidos a bordo da embarcação por 12 meses, estando disponíveis à autoridade sanitária sempre que solicitado.”
“Drinking water reservoirs must be inspected, cleaned, and disinfected during dry or wet docks, or annually. Records of maintenance, cleaning, and disinfection activities of the tanks and drinking water distribution system must be kept on board the vessel for 12 months and be made available to the health authority whenever requested.”
Brazilian Sanitary Guide for Cruise Ships (version 4, 5 December 2023)
The shorter timeframe specified by ANVISA is likely due in part to Brazil’s tropical climate, where higher temperatures can accelerate the growth of harmful microorganisms in water systems.
For cleaning and disinfecting the tanks, the Brazilian Sanitary Guide for Cruise Ships refers to the VSP Operations Manual, specifying that the standards in Section 5.3.5 Potable Water Tank Disinfection Methods must be followed.
ANVISA Potable Water Quality Requirements
Section 4.2.3 Qualidade e segurança sanitária da água potável (Drinking Water Quality and Safety) of the Brazilian Sanitary Guide for Cruise Ships has a few variations compared to the VSP Operations Manual standards:
- Turbidity: ANVISA regulations recommend that the turbidity in the vessel’s potable water system be a maximum of 5 NTU (Nephelometric Turbidity Unit). NTU is a standard unit for measuring the cloudiness or haziness of a liquid, caused by numerous tiny particles that are usually invisible to the naked eye. Elevated turbidity levels can reduce water transparency and signal the presence of pollutants, pathogens, and other contaminants, rendering the water unsafe for human consumption. Although the Sanitary Guide does not specify the frequency for measuring turbidity, it would be prudent to ensure your vessels have a means to do so, such as a turbidity meter (also known as a turbidity sensor or nephelometer).
- Halogen Residual: VSP standards for the free residual halogen (chlorine) level in the vessel’s potable water distribution system require a minimum of ≥0.2 mg/L (ppm) and a maximum of ≤5.0 mg/L (ppm). In contrast, ANVISA sets a stricter maximum of ≤2.0 mg/L (ppm). While this difference is unlikely to cause operational issues—since most vessels maintain chlorine levels below 1.0 ppm to avoid a noticeable chlorine taste and smell—it is important to be aware of the discrepancy between the two guidelines.
- Halogen Monitoring: VSP cruise ship inspections include a review of the halogen analyzer-chart recorder charts from the “far point”—a distant point in the vessel’s potable water distribution system that represents the entire distribution system—to ensure compliance with the operational limits mentioned above. In contrast, ANVISA requires daily monitoring of the residual halogen at several different points in the distribution system: “O monitoramento do residual de halogênio (cloro ou bromo) deve ser realizado diariamente em diversos pontos de oferta.” This is an important distinction. While the Brazilian Sanitary Guide does not specify the exact number of points to be monitored, it clearly implies more extensive monitoring than just the far point. Additionally, it is recommended to conduct supplementary manual sampling to identify and correct any potential failures in electronic monitoring.
- Microbiological Monitoring: Similar to the variations in bunkering mentioned earlier, ANVISA requires that monthly potable water samples (at least four) taken from different points in the distribution system be analyzed for the presence of both E. coli (thermotolerant coliforms) and total coliforms. VSP only requires analysis for the presence of E. coli.
- Halogen Products: The Brazilian Sanitary Guide mandates that the packaging of products used for the disinfection and treatment of potable water must include the following minimum information: identification of the active ingredient, concentration, batch number (if applicable), expiration date, and the manufacturer’s name. Additionally, the vessel must maintain a technical data sheet (either printed or electronic) for each product.
ANVISA Recreational Water Facility Requirements
The Brazilian Sanitary Guide for Cruise Ships, in Section 4.3 Águas recreacionais (ARC), outlines the requirements for the operation and management of recreational water facilities (RWFs) on board. While these requirements are generally similar to the VSP standards, there are two notable exceptions.
ANVISA permits a higher maximum free residual chlorine limit of 7.0 ppm in pools, compared to the VSP Operations Manual’s maximum of 5.0 ppm. Additionally, while VSP standards allow a pH level between 7.0 and 7.8, ANVISA has stricter requirements:
“O pH da água de piscina abastecida com água potável deve estar entre 7.2 e 7.8, caso o halogênio utilizado seja o cloro e entre 7.2 e 8.0, caso o halogênio seja bromo ou outro desinfetante.”
“The pH of pools filled with potable water should be between 7.2 and 7.8 if the halogen used is chlorine, and between 7.2 and 8.0 if the halogen used is bromine or another disinfectant.”
Brazilian Sanitary Guide for Cruise Ships (version 4, 5 December 2023)
The Devil’s in the Details
Since its original publication in 2009, ANVISA has revised the Sanitary Guide for Cruise Ships several times (the current assigned version number does not reflect the actual number of updates). The guide is organized into several sections that comprehensively cover operational public health requirements on board, including disease surveillance and reporting, food safety, potable water, recreational water facilities, pest management, waste management, and the cleaning of cabins and public areas.
Understanding the specific requirements detailed within the Sanitary Guide can save your fleet and company from numerous complications, including potential financial penalties. Unlike VSP inspections in the U.S., ANVISA’s sanitation inspections do not allow for extended timeframes to address issues, nor is there an option to contest findings. In Brazil, cruise ship public health inspections are straightforward: upon completion, the vessel will receive a report detailing any deficiencies and will be advised to resolve them before arriving at the next Brazilian port, where a follow-up inspection will typically be conducted.
It is crucial that crew members who accompany ANVISA’s inspectors have full knowledge of the processes and controls of the areas and services inspected, as information provided by these crew members will be considered official by the Brazilian authorities.
Navigating international regulations can be challenging, but preparation and knowledge are your best allies. By ensuring your procedures reflect local requirements and your crew is well-versed in them, you can navigate the challenges of compliance with confidence and ease, providing a safe and enjoyable experience for your passengers while avoiding potential pitfalls.