CAT/OP/BRA/2 politically not feasible, how this is tested, at what stage, by whom, and details of if and why Brazil could consider it necessary to limit cooperation with the NPM for any reason. 30. Since receiving Brazil’s Reply, and learning of the passage of the draft NPM legislation through the Chamber of Deputies, the SPT has received some indications that the right of access to places of detention by the NPM may no longer be automatic, and understands that it may be contingent on prior communication. The SPT requests that Brazil clarifies the NPM’s rights of access provided for in the draft legislation. The SPT further recommends that, in the interests of the greatest possible effectiveness of the NPM, the authorities reconsider this position, and consider as an alternative, making the NPM’s access to all places of detention automatic whether a visit is announced or unannounced. 31. The NPM should comply in particular with Articles 17, 18, 19 and 20 OPCAT, and with the Paris Principles. The SPT requests a copy of the most recent draft legislation for its comments, and requests to be kept informed of its progress as the draft Bill is adopted. B. Regional mechanisms 32. The SPT commends the establishment of local preventive mechanisms in some Brazilian States. The SPT regards this as a very important and progressive step that can go a long way towards combating torture and ill-treatment, and also serve as a model to be replicated in other neighbouring states. Brazil has nevertheless not answered the SPT’s recommendation at paragraph 20 of its report, and requests to know whether, and if so, what steps have been taken to implement this recommendation, and to ensure functional independence and sufficient resources for such mechanisms, as this would greatly strengthen protection. C. Other preventive policies and framework 33. The SPT welcomes details of mechanisms and policies designed to prevent and combat torture and ill-treatment, which are additional to the NPM and its regional counterparts. The SPT highlights in particular, Brazil’s ‘Master Plan’ (Reply, paras. 152) and the Section V of its Reply. The SPT includes its comments, recommendations and requests on these measures below. VI. Torture and ill-treatment 34. During its visit, the SPT encountered repeated, consistent and credible accounts of torture and ill-treatment committed by the civil and military police against both adults and juveniles (see Report paras. 79-86), by prison guards, both in prisons and during transportation in vehicles of the Special Operations Services, (Report paras. 126–129), in pre-trial detention facilities for juveniles (Report, para. 143), and in institutions for children and adolescents (Report, paras 144-150). It is abundantly evident that, in spite of progress observed in a number of areas, torture and other ill-treatment continue to be widespread practices in Brazil, across a whole spectrum of institutions. It is clear also that torture and other ill-treatment are perpetrated by a number of different state authorities. 35. The SPT is deeply concerned that of all of its direct recommendations relating to torture and ill-treatment in the visit Report, Brazil has responded to none of these recommendations directly, but rather restated the pre-existing legal framework and policy. 8