Brazil - Ship Sanitation Control Certificates

Club correspondents Representacoes Proinde (Rio) Ltda. Rio de Janeiro, have advised that fines are being imposed in certain ports in Rio de Janeiro State if vessels are unable to produce evidence that insect and rodent infestation have been subject to control procedures within the previous six months. Unlike most other countries, holding a Ship Sanitation Control Exemption Certificate is not considered to be sufficient. Fines are not governed by a set tariff and are typically in the region of US$ 10,000.

Earlier this year the Brazilian National Sanitation Surveillance Agency (ANVISA) started to enforce Article 80 of Resolution RDC No. 72 in Itaguai, Rio de Janeiro, Arraial do Cabo and several minor ports. Article 80 states, in part, that “Every six months, all ships must be subject to control procedures of rodent extermination and insects which must be substantiated by records in the ship’s log book or certificates”. ANVISA deems this requirement to apply regardless of whether or not there is any insect or rodent infestation on board.

Since ANVISA requires evidence confirming that such control procedures have been exercised, the presence of a Ship Sanitation Control Exemption Certificate will not suffice. To avoid being fined, vessels need to be in possession of a valid Ship Sanitation Control Certificate issued by a responsible company detailing the insect and rodent control measures undertaken. The cost of obtaining a Ship Sanitation Control Certificate in Rio de Janeiro is approximately US$ 2,000 to US$ 3,000.

It is understood that ANVISA intends to enforce Article 80 in larger ports such as Recife, Manaus and Ponta da Madeira in the near future.

If a vessel is due to call at a Brazilian port and is not in possesion of a Ship Sanitation Control Certificate, arrangements should be made to obtain one at a previous port or on arrival so that the required measures can be undertaken and a certifcate issued. Vessels lacking a Ship Sanitation Control Certificate or which have not arranged for one to be issued on arrival may experience delays with inward health clearance and the granting of free pratique, and may be fined by ANVISA thereafter.

Although it may be possible for vessels arriving with a Ship Sanitation Control Exemption Certificate to challenge a fine if there is no evidence of insect or rodent infestation on board, the ship will almost certainly be delayed and legal costs may be high.

Members requiring further guidance should contact the Loss Prevention department.