CAT/OP/BRA/3 8. Foreign nationals 73. In prisons in the State of Rio de Janeiro, the Subcommittee observed that foreign detainees were not given consistent access to interpretation services and had limited access to counsel and health care. 74. The Subcommittee recommends that the State party ensure that foreign detainees have access to interpretation services and are able to consult with counsel and health-care personnel as needed. V. Implementation of the Optional Protocol: National System to Prevent and Combat Torture 75. In accordance with its article 17, Brazil should have established or designated a national preventive mechanism at the latest one year after its ratification of the Optional Protocol in 2007. Since the ratification, the State has conducted internal reviews and public consultations on an appropriate model for such a mechanism. The national preventive mechanism bill was presented to the Subcommittee during its first visit to Brazil in 2011. In its first visit report the Subcommittee had recommended that the State party introduce the necessary changes to guarantee an open, transparent and inclusive process, in particular of civil society, for the selection and appointment of the members of the mechanism. The Subcommittee had further recommended that provision be made for gender balance and ethnic and minority representation in the membership of the mechanism. The Subcommittee commends the changes introduced to the draft law following its first visit, which allowed for improving the level of transparency of the new bodies created by the federal law. The Subcommittee nevertheless emphasizes the importance of gender balance in the composition of the membership of the national preventive mechanism. A. Institutional framework for the prevention of torture at federal level 76. The Subcommittee welcomes the adoption of federal law 12.847 of 2 August 2013 establishing the National System to Prevent and Combat Torture, 11 and federal decree 8.154 of 16 December 2013 regulating the functioning of the National System to Prevent and Combat Torture, the composition and functioning of the National Committee to Prevent and Combat Torture and the National Mechanism to Prevent and Combat Torture. 12 77. The Subcommittee observes with great interest the composite structure created by the State, which demonstrates that the prevention of and combat against torture is seen and acknowledged as a systemic task that depends on a multiplicity of institutions and State organs. 78. The Subcommittee acknowledges the complexity of the federal State and took note that the National System to Prevent and Combat Torture is comprised of a variety of institutions and bodies, including the National Committee to Prevent and Combat Torture, the National Mechanism to Prevent and Combat Torture, the National Penitentiary Department, the National Council on Criminal and Prison Policies, and local committees to prevent and combat torture at state level. 13 The role of the National System is to integrate all these bodies and institutions and to hold an annual meeting.14 11 12 13 14 16 See www.planalto.gov.br/ccivil_03/_Ato2011-2014/2013/Lei/L12847.htm. See www.planalto.gov.br/ccivil_03/_Ato2011-2014/2013/Decreto/D8154.htm. Article 2 of federal law 12.847. Article 4 of decree 8.154.