Introduction: Correct Documentation Prevents Nonconformities
The use of chemical preservatives in meatpacking plants is governed by a number of regulations from ANVISA (Brazil's National Health Surveillance Agency), MAPA (Brazil's Ministry of Agriculture, Livestock and Food Supply) and state health surveillance agencies. Documentation nonconformities are one of the main causes of:
- Citations and fines (missing SDS, test reports, records)
- Held batches (incomplete or outdated documentation)
- SIF suspension (SIF: Brazil's Federal Inspection Service for animal products)
- Product recalls (use of non-certified preservatives or levels above the limits)
This technical guide sets out a complete compliance roadmap for the use of preservatives in meatpacking plants, covering:
- Applicable legislation (ANVISA, MAPA, GMP)
- Mandatory supplier documentation
- Required internal controls
- Audit checklist
- Traceability procedures
1. Applicable Legislation: Regulations Governing Preservatives
1.1 ANVISA: National Health Surveillance Agency
RDC No. 272/2005 (RDC: ANVISA Collegiate Board Resolution), Technical Regulation for Vegetable Products, Fruit Products and Edible Mushrooms:
- Defines permitted additives, including preservatives
- Sets maximum use limits
Resolution RDC No. 276/2005, Technical Regulation for Spices, Seasonings and Sauces:
- Applies to processed products containing preservatives
Ordinance No. 1004/1998, Technical Regulation: Assignment of Additive Functions, Additives and their Maximum Limits:
- Lists permitted additives by food category
- Defines technological functions (preservative, acidulant, etc.)
1.2 MAPA: Ministry of Agriculture, Livestock and Food Supply
Normative Instruction No. 51/2006:
- Sets limits for nitrite and nitrate in meat products
- Sodium nitrite: maximum 150 mg/kg
- Sodium nitrate: maximum 300 mg/kg
- Residual nitrite in the finished product: maximum 150 ppm
Decree No. 9,013/2017 (RIISPOA, Brazil's Regulation for Industrial and Sanitary Inspection of Animal Products):
- Requires GMP (Good Manufacturing Practices)
- Establishes traceability procedures
- Defines the duties of the responsible technical officer
1.3 Good Manufacturing Practice (GMP) Standards
Ordinance CVS-5/2013 (São Paulo state) and equivalent state regulations:
- Control of incoming inputs
- Proper storage of chemical products
- Batch identification and traceability
- Food handler training
1.4 ISO 22000 / HACCP (Hazard Analysis and Critical Control Points)
Although not mandatory, they are strongly recommended for meatpacking plants that export or supply large retail chains:
- Identification of chemical hazards (preservative overdosing)
- Establishment of CCPs (Critical Control Points)
- Continuous dosage monitoring
2. Mandatory Documentation from the Preservative Supplier
2.1 SDS: Safety Data Sheet (ABNT NBR 14725)
ABNT NBR 14725 is the Brazilian standard for hazard communication and safety data sheets. The SDS is mandatory for all chemical products, including food grade preservatives.
Essential SDS sections:
- Product and company identification
- Hazard identification (GHS classification)
- Composition and information on ingredients (purity, CAS)
- First aid measures
- Firefighting measures
- Accidental release measures
- Handling and storage (temperature, incompatibilities)
- Exposure controls and personal protection (PPE)
- Physical and chemical properties (solubility, pH, density)
- Stability and reactivity (decomposition products)
- Toxicological information (LD50, acute and chronic effects)
- Ecological information
- Disposal considerations
- Transport information (UN number, hazard class)
- Regulatory information (ANVISA, MAPA)
- Other information (revision, validity)
Attention: The SDS must be updated every 5 years or whenever there is a regulatory change.
2.2 Test Report (Quality Certificate)
The document that proves the purity and conformity of the purchased batch.
Mandatory information:
- Product identification (chemical name, purity grade)
- Batch number
- Manufacturing and expiry dates
- Analysis results:
- Purity (% active ingredient)
- Moisture
- Heavy metals (Pb, As, Hg), if applicable
- Microbiological contaminants (for food grade)
- Signature of the manufacturer's responsible technical officer
- CNPJ (Brazilian corporate taxpayer ID) of the laboratory (if external)
Frequency: Request a test report with every purchase/batch.
2.3 Food Grade Certification
A manufacturer's declaration that the product meets specifications for food contact.
Information it must include:
- Compliance with ANVISA/MAPA regulations
- Absence of contaminants above established limits
- Reference to international codes (if applicable): FCC (Food Chemicals Codex), USP
Attention: Industrial products (not food grade) cannot be used in food, even if they are chemically identical. The difference lies in the control of purity and contaminants.
2.4 Invoice with a Complete Description
The nota fiscal (Brazilian tax invoice) must contain:
- Full product name (e.g. "Sodium Nitrite Food Grade")
- Batch number
- Quantity (kg)
- Expiry date
- Supplier's CNPJ
- Intended use (e.g. "for food use")
Traceability: Link the invoice to the batch received (label in the storeroom).
3. Mandatory Internal Controls in the Meatpacking Plant
3.1 Receiving and Inspection of Inputs
Procedure:
- Check packaging integrity (no tears, moisture or contamination)
- Check labeling:
- Product name
- Batch number
- Expiry date
- Hazard symbol (if applicable)
- Check documentation:
- Invoice with the correct description
- Batch test report
- Up-to-date SDS (check the revision date)
- Record receipt in a spreadsheet or system:
- Date received
- Supplier
- Batch
- Quantity
- Expiry date
- Person responsible for receiving
Acceptance/rejection criteria:
- ✅ Accept: Complete documentation + intact packaging + product within its shelf life
- ❌ Reject: Missing test report, outdated SDS, damaged packaging, expired product or product close to expiry (< 6 months)
3.2 Preservative Storage
GMP requirements:
- Dedicated area for chemical products (separate from ready-to-eat food)
- Adequate ventilation (prevent gas buildup)
- Controlled temperature (room temperature, 15-25°C)
- Protection from moisture (shelving, never directly on the floor)
- Clear identification (labels with name, batch, expiry date, hazard symbol)
- Access control (authorized and trained personnel only)
- Incompatibilities: Do not store near strong acids (risk of reaction with nitrites)
Stock records:
Keep a spreadsheet or system with:
- Date of entry
- Product
- Batch
- Quantity (kg)
- Expiry date
- Location in the storeroom
- Movements (issues to production)
3.3 Dosing and Use in Production
Standard operating procedure (SOP):
- Finished product specification sheet with the preservative dosage (mg/kg or %)
- Dosage calculation per production batch (meat mass x % preservative)
- Weighing on a calibrated scale (minimum accuracy ±0.1 g for small quantities)
- Double check (operator and supervisor verify the dosage before adding it)
- Record on the production order:
- Date
- Product manufactured
- Production batch
- Preservative used (name, batch)
- Quantity added (g or kg)
- Person responsible for dosing
Required equipment:
- Calibrated electronic scale (valid calibration certificate)
- PPE: gloves, mask (handling nitrite generates dust)
- Dedicated utensils (scoops, labeled containers)
3.4 Full Traceability: From Supplier to Finished Product
Principle: It must be possible to trace which preservative batch was used in each finished product batch.
Traceability flow:
- Receiving: Nitrite batch X (invoice 123) goes into stock
- Use: Batch X is used to produce bacon batch Y (production order 456)
- Finished product: Bacon batch Y contains nitrite from batch X
Benefits:
- In the event of a recall, quickly trace which products were affected
- In audits, demonstrate strict control of inputs
- In nonconformities, identify the root cause (a defective preservative batch?)
Tools:
- Excel spreadsheets (small operations)
- ERP systems with a traceability module (medium and large plants)
4. Checklist for ANVISA/SIF Audits
4.1 Supplier Documentation (Checkpoints)
| **Item** | **Compliant?** | **Notes** |
|---|---|---|
| Up-to-date SDS (< 5 years) | ☐ Yes ☐ No | Check the revision date |
| SDS in Portuguese (ABNT NBR 14725) | ☐ Yes ☐ No | Do not accept an SDS in a foreign language |
| Batch test report | ☐ Yes ☐ No | Must match the batch in stock |
| Food grade certification | ☐ Yes ☐ No | Declaration of ANVISA/MAPA compliance |
| Invoice with a complete description | ☐ Yes ☐ No | Name, batch, expiry date, food use |
4.2 Storage (Checkpoints)
| **Item** | **Compliant?** | **Notes** |
|---|---|---|
| Dedicated area for chemicals | ☐ Yes ☐ No | Separate from ready-to-eat food |
| Adequate ventilation | ☐ Yes ☐ No | Windows, exhaust fans |
| Products identified (name, batch, expiry date) | ☐ Yes ☐ No | Legible labels |
| Products within shelf life | ☐ Yes ☐ No | Discard expired products |
| Intact packaging (no moisture, tears) | ☐ Yes ☐ No | Damaged products must be quarantined |
| Restricted access control | ☐ Yes ☐ No | Locked door, authorized access only |
| Incompatibilities respected | ☐ Yes ☐ No | Nitrites kept away from acids |
4.3 Usage Control (Checkpoints)
| **Item** | **Compliant?** | **Notes** |
|---|---|---|
| Specification sheet with defined dosage | ☐ Yes ☐ No | For every product manufactured |
| Calibrated scale (valid certificate) | ☐ Yes ☐ No | Calibration at least once a year |
| Dosage recorded on the production order | ☐ Yes ☐ No | Preservative batch + quantity used |
| Double check of dosage | ☐ Yes ☐ No | Operator + supervisor sign |
| Appropriate PPE (gloves, mask) | ☐ Yes ☐ No | Available and in use |
4.4 Traceability (Checkpoints)
| **Item** | **Compliant?** | **Notes** |
|---|---|---|
| Stock control spreadsheet/system | ☐ Yes ☐ No | Batch receipts and issues |
| Preservative batch linked to finished product batch | ☐ Yes ☐ No | Full traceability |
| Successful traceability test | ☐ Yes ☐ No | Auditor picks a batch and checks the trace |
4.5 Employee Training (Checkpoints)
| **Item** | **Compliant?** | **Notes** |
|---|---|---|
| GMP training (signed record) | ☐ Yes ☐ No | Annually or on hiring |
| Specific training on nitrite handling | ☐ Yes ☐ No | Hazards, PPE, correct dosage |
| Qualified responsible technical officer (RT) | ☐ Yes ☐ No | Registered with a professional council (CRMV, CRQ, etc.) |
5. Traceability Procedures: Practical Examples
5.1 Example 1: Tracing a Bacon Batch
Situation: A customer reports a problem with bacon batch 2025-001.
Procedure:
- Identify the production order for batch 2025-001
- Check the production order:
- Preservative used: Sodium Nitrite FG, batch 2024-1123 (supplier Boreto & Cardoso®)
- Quantity used: 1.2 kg for 800 kg of meat
- Date: Jan 10, 2025
- Check the test report for batch 2024-1123:
- Purity: 99.6% ✓ (compliant)
- Expiry: 12/2026 ✓ (compliant)
- Conclusion: The preservative is compliant. Investigate other variables (pH, curing time, temperature).
Tracing time: < 5 minutes (organized system).
5.2 Example 2: Preventive Recall
Situation: The supplier reports that nitrite batch 2024-1130 was contaminated with moisture (potential loss of effectiveness).
Procedure:
- Check the stock spreadsheet: Batch 2024-1130 received on Jan 5, 2025, used from Jan 6 to Jan 8, 2025
- List the products made with batch 2024-1130:
- Ham batch 2025-005 (Jan 6)
- Bacon batch 2025-008 (Jan 7)
- Sausage batch 2025-011 (Jan 8)
- Action: Withdraw batches 2025-005, 2025-008 and 2025-011 from the market (preventive recall)
- Notify the authorities: Inform SIF/ANVISA of the preventive measure
Effective traceability prevented:
- Distribution of potentially nonconforming products
- Citations for failing to act preventively
- Damage to the brand's image
6. The Most Common Nonconformities and How to Avoid Them
6.1 Nonconformity: No Up-to-Date SDS
Risk: Citation, fine (from R$ 2,000 to R$ 1,500,000 depending on severity).
How to avoid it:
- Request the SDS with the first purchase
- Check the revision date (< 5 years)
- Request an updated SDS every 5 years or after a regulatory change
- Keep the SDS in an accessible place (paper + digital)
6.2 Nonconformity: Use of a Non-Food Grade Product
Risk: Heavy metal contamination, recall, SIF suspension.
How to avoid it:
- Require food grade certification from the supplier
- Check the invoice: it must state "food use" or equivalent
- Do not accept products labeled "industrial use" or "technical use"
6.3 Nonconformity: Dosage Above the Legal Limit
Risk: Nonconforming product, recall, fine, liability of the RT.
How to avoid it:
- Clear specification sheet with the dosage (mg/kg)
- Calibrated scale (valid certificate)
- Double check before adding the preservative
- Periodic analysis of residual nitrite in the finished product (colorimetric kit or laboratory)
6.4 Nonconformity: Lack of Traceability
Risk: Inability to run a targeted recall, citation during an audit.
How to avoid it:
- Stock control spreadsheet/system with batches
- Link the preservative batch to the production order
- Test traceability periodically (mock recall)
6.5 Nonconformity: Improper Storage
Risk: Product degradation (loss of effectiveness), cross-contamination.
How to avoid it:
- Dedicated area for chemicals
- Temperature/humidity control
- Clear product identification
- Monthly inspection of packaging integrity
7. Team Training: Mandatory Content
7.1 Initial Training (On Hiring)
Duration: 4 hours
Content:
- Introduction to GMP (Good Manufacturing Practices)
- ANVISA/MAPA legislation on preservatives
- Identification of chemical products (labels, SDS)
- Health risks (nitrite toxicity, PPE)
- Correct storage
- Dosing procedure (scale, calculation, record keeping)
- First aid in case of exposure
Assessment: Practical dosing test + written assessment.
7.2 Annual Refresher Training
Duration: 2 hours
Content:
- Regulatory updates (ANVISA/MAPA changes)
- Review of internal procedures
- Review of the year's nonconformities (real cases)
- Traceability reinforcement
Record: Spreadsheet with name, date, employee signature and instructor signature.
7.3 Responsible Technical Officer (RT)
Required qualifications:
- Degree: Veterinary Medicine, Food Engineering, Chemistry or related fields
- Registration with a professional council (CRMV, CRQ, etc.)
- Experience in the food industry (recommended)
Responsibilities:
- Approve specification sheets with preservative dosages
- Supervise quality control
- Sign internal reports
- Answer to the regulatory authorities
8. Support Tools: Spreadsheets and Checklists
8.1 Preservative Stock Control Spreadsheet
| **Date Received** | **Product** | **Batch** | **Quantity (kg)** | **Expiry** | **Supplier** | **Invoice** | **Test Report?** |
|---|---|---|---|---|---|---|---|
| Jan 10, 2025 | Sodium Nitrite FG | 2024-1123 | 25 | 12/2026 | Boreto & Cardoso® | 12345 | Yes |
| Jan 12, 2025 | Sodium Benzoate | 2024-0998 | 25 | 06/2027 | Boreto & Cardoso® | 12356 | Yes |
8.2 Production Order with Traceability
| **Product Batch** | **Date** | **Finished Product** | **Kg of Meat** | **Preservative Used** | **Preservative Batch** | **Quantity (g)** | **Responsible** |
|---|---|---|---|---|---|---|---|
| 2025-001 | Jan 10, 2025 | Bacon | 800 | Sodium Nitrite FG | 2024-1123 | 1,200 | João Silva |
| 2025-002 | Jan 11, 2025 | Ham | 500 | Sodium Nitrite FG | 2024-1123 | 600 | Maria Santos |
8.3 Incoming Inputs Checklist
| **Item** | **OK?** | **Notes** |
|---|---|---|
| Intact packaging (no tears/moisture) | ☐ | |
| Label with name, batch, expiry date | ☐ | |
| Invoice matches the product received | ☐ | |
| Batch test report | ☐ | |
| Up-to-date SDS | ☐ | |
| Product within shelf life (> 6 months) | ☐ | |
| Food grade certification | ☐ |
Decision: ☐ Accept ☐ Reject
Responsible: ****__**** Date: __/__/__
9. Frequently Asked Questions (FAQ)
9.1 How long is an SDS valid? Do I need to request a new one?
The SDS must be updated every 5 years or whenever there is a regulatory change (new hazard classifications, revised limits). Ask your supplier for an updated SDS if the one you have is more than 5 years old.
9.2 Can I use a preservative without a test report?
Not recommended. The test report proves that that specific batch meets the specifications. Without it, you have no guarantee of purity and may end up using an off-spec product (risk of nonconformity).
9.3 How do I demonstrate traceability during an audit?
The auditor will pick a random finished product batch. You must present:
- The production order for that batch (showing which preservative batch was used)
- The purchase invoice for the preservative batch
- The test report for the preservative batch
If you can present these in < 10 minutes, your traceability is effective.
9.4 Do I need to calibrate the scale every year?
Yes. Annual calibration is a GMP requirement. Use an accredited company (RBC, the Brazilian Calibration Network). Keep a valid calibration certificate attached to the scale.
9.5 Who should sign the production order?
- The operator who weighed and added the preservative
- The supervisor who checked the dosage
- The Responsible Technical Officer (RT) may sign weekly, reviewing a batch of orders
9.6 How should expired preservatives be disposed of?
Never dispose of them in ordinary trash or the sewer. Expired preservatives must be:
- Identified (label "EXPIRED: DO NOT USE")
- Separated from active stock
- Returned to the supplier (if there is an agreement)
- Disposed of by a company specialized in chemical waste (with a certificate of disposal)
9.7 Can I buy preservatives from a supplier without a CNPJ?
No. The supplier must be a registered company with a CNPJ, able to issue an invoice with a complete description. Purchases without an invoice make traceability impossible and may result in a citation.
10. Boreto & Cardoso®: Your Compliance Partner
10.1 Complete Documentation Guaranteed
When you buy preservatives from Boreto & Cardoso®, you receive:
✅ Up-to-date SDS (ABNT NBR 14725) in Portuguese ✅ Test report for each batch with purity and contaminant results ✅ Food grade certification (declaration of ANVISA/MAPA compliance) ✅ Detailed invoice with name, batch and expiry date
10.2 Certified Suppliers
With 53 years of experience supplying chemical inputs to the food industry, Boreto & Cardoso® distributes food grade preservatives from certified suppliers. Each product comes with its certificate of analysis. We also provide the Safety Data Sheet (SDS) and other documents required for legal and quality compliance.
10.3 Logistics and Quality
- On-time deliveries
- Intact, labeled packaging
- ISO 9001 certification
Conclusion: Compliance Is Risk Prevention
Maintaining regulatory compliance in the use of preservatives is a legal obligation and also a risk management strategy:
- Avoids fines and citations (savings)
- Prevents recalls (brand protection)
- Ensures product quality (customer satisfaction)
- Makes certification easier (ISO, HACCP, BRC)
- Shows professionalism (successful audits)
Investment in compliance:
- Time: 2 to 4 hours/month (document control)
- Cost: Low (spreadsheets, in-house training)
- Return: High (prevention of costly nonconformities)
For questions or to request technical documentation, please contact our team.
📞 Contact Information
Boreto & Cardoso®, Chemical Inputs Distributor
📱 Phone: +55 11 3931-1722 +55 11 2366-6260
📧 Email: boreto@boreto.com.br
📍 Address: Rua Alagoas, 30 | Recanto Silvestre Santana de Parnaíba - SP | CEP 06530-245
🌐 Website: www.boreto.com.br
🏆 Certification: ISO 9001, Quality Management
Boreto & Cardoso®: 53 years of experience supplying food grade preservatives with complete documentation for ANVISA/MAPA compliance.
Note to the Reader
This article is based on established technical knowledge of health legislation, food grade preservatives and the regulations that apply to the food industry. The information presented is for informational and educational purposes and is intended for professionals in the field.
The procedures mentioned should be implemented by a qualified technical professional (food technologist, chemist, food engineer, veterinarian or similar), taking into account the specifics of each production process and the applicable regulatory requirements.
Boreto & Cardoso® is a distributor of chemical inputs and supplies products accompanied by a certificate of analysis and SDS. We do not offer consulting services, formulation development or qualified technical support for industrial processes.