HACCP and Video Monitoring: How Cameras Help You Pass Audits

Is НАССР the same as HACCP?

Yes. Ukrainian legislation writes HACCP (Hazard Analysis and Critical Control Points) in Cyrillic as НАССР, and in everyday speech people more often say ХАССП. Article 1 of the Law of Ukraine «Про основні принципи та вимоги до безпечності та якості харчових продуктів» (Law of Ukraine “On Basic Principles and Requirements for Food Safety and Quality”) defines HACCP as a system that identifies, evaluates and controls hazards significant for food safety.

What does the law require?

Article 21 of Law No. 771/97-VR obliges food business operators to develop, implement and apply permanent procedures based on HACCP principles. Primary production is exempt. Part 3 names seven principles:

1. identifying hazards;
2. determining critical control points;
3. establishing critical limits;
4. monitoring at critical control points;
5. corrective actions when a point goes out of control;
6. validation and verification;
7. documents and records that prove the measures are applied.

Three more provisions of Article 21 matter for video monitoring. Under the simplified approach, Part 4 allows visual monitoring to be recorded only in cases of nonconformity, with a description of corrections and corrective actions. Part 6 requires HACCP documents and records to be kept for at least three months after the product's shelf life ends. Part 7 states directly that certification of HACCP procedures is not mandatory. A plant goes through IFS, BRCGS or FSSC 22000 audits at its buyers' request.

Article 48 of the law covers staff hygiene. Only people with no medical contraindications who have completed hygiene training, confirmed by records, may handle food, and the training is repeated periodically.

What are prerequisite programs, and where does staff fit in?

Prerequisite programs (PRP) are the basic hygiene conditions without which a HACCP plan does not work. Order No. 590 of the Ministry of Agrarian Policy and Food, dated October 1, 2012, lists 13 mandatory programs in clause 2.4. Staff health and hygiene is sixth on the list (subclause 2.4.6) and is detailed in clause 2.10.

Clause 2.10.5 requires rules of conduct for staff in production. They cover entering and leaving premises, moving between zones, wearing personal items and jewelry, what to do with cuts, eating, handwashing, smoking, toilet visits, and storing and using personal clothing and workwear. Clause 2.10.6 extends these rules to visitors and contractors.

Here is how these requirements map to what video monitoring records every day, on every shift.

Order No. 590 requirement	What video monitoring records
2.10.5, handwashing	Hand sanitizing at the hygiene station, two people passing on one cycle
2.10.3, workwear	Hair cap, face mask, beard net, gloves in the zone
2.10.5, entering and leaving, use of workwear	Leaving the zone in workwear
2.10.5, eating, personal items	Phone, food and belongings on lockers and workstations
2.4.2 and 2.4.7, protecting products from contamination	Crates of product directly on the floor, containers piling up on tables
2.4.8, pest control	Open dock doors and washroom doors
2.10.2 and 2.10.4, medical checks and health status	Remain with the medical service and the work clearance procedure

What do IFS, BRCGS and FSSC 22000 auditors ask about staff?

The IFS Food, BRCGS Food Safety and FSSC 22000 certification schemes each have dedicated sections on staff hygiene. Below is what can be verified from public documents.

Standard	Staff section	What matters for video monitoring
IFS Food, version 8	3.2 (personnel hygiene, protective clothing)	3.2.2 is marked KO No. 3: all employees, contractors and visitors must understand and follow the hygiene rules. 3.2.3 requires monitoring of compliance at a risk-based frequency, but at least once every three months. 3.2.4 requires a program to check the effectiveness of hand hygiene
BRCGS Food Safety, Issue 9	Section 7: 7.1 training, 7.2 personal hygiene, 7.3 medical screening, 7.4 protective clothing	Requirement 7.1 on training is a fundamental requirement. Audits against Issue 9 have run since February 1, 2023; BRCGS has held a consultation on the next issue
FSSC 22000	Version 6 relies on ISO/TS 22002-1:2009, section 13 (personnel hygiene and employee facilities)	Version 7, published in May 2026, moves to ISO 22002-1:2025 together with ISO 22002-100:2025, where personnel hygiene is in section 14. Audits against version 6 are allowed until April 30, 2027

The IFS guideline for auditors contains a remark that is useful for preparation. In the IFS view, walkthroughs that record only deviations do not prove that hygiene requirements are met. The auditor wants to see how workers are checked during work, who does the checking, evidence of the checks and a list of the violations found. For KO No. 3, the auditor also observes people on the production floor.

The Codex Alimentarius (General Principles of Food Hygiene CXC 1-1969, 2020 revision) describes the same requirements at the international level: health status, personal cleanliness, staff behavior and rules for visitors.

How does a log of decisions with frames become evidence?

For an auditor, the evidence is the record, and the camera supplies the frame for it. In our system every event is a card with a frame, rule, camera and time. A responsible person at the plant decides “violation” or “no violation”, and confirmed violations go to the log. Such a log meets the seventh HACCP principle (records) and supports the fifth (corrective actions).

Sample log entry (made-up data, for format illustration only):

Field	Value
Time and camera	06:42, hygiene station, entrance to the deboning area
Rule	Entry without hand sanitizing
Frame	Link to the evidence frame
Decision	Violation, confirmed by the head of HACCP at 07:05
Correction	Worker sent back to the hygiene station
Corrective action	Repeat briefing for the shift, entry in the training log

To answer the IFS remark about walkthroughs that see only deviations, the log has to show compliance too: how many people passed the hygiene station during the shift and how many of them committed a violation. The violation rate by day and shift then becomes a monitoring indicator under clause 3.2.3, and repeat violations in one area show where corrective action is needed.

• Tie the card retention period to the requirement of Part 6 of Article 21 of Law No. 771/97-VR.
• Build the auditor report for a period: number of events, decisions, corrective actions, a sample of frames.
• Restrict access to frames by role, because frames showing people are personal data.

How do you show an auditor that the system can be trusted?

An auditor may ask whether the system misses violations. Before video monitoring becomes part of daily work, you get a report built on your own plant's events: how many cards your people confirmed and over what period. We state every number with the number of events and the period, for example “X of N cards confirmed, September 1–30”. Without that, the number proves nothing.

HACCP principle 6 (verification) works here in the usual way: once per period, the process engineer reviews a random sample of video and compares it with the log.

What can a camera not replace?

• Medical checks, clearance for work and health monitoring (clauses 2.10.2 and 2.10.4 of Order No. 590).
• Staff training and its records (Article 48 of the law, BRCGS 7.1).
• Hand swabs and lab checks of hand hygiene effectiveness (IFS 3.2.4).
• The pre-shift check of staff that a supervisor or process engineer does under your procedures.
• Certainty where there is none. If a situation on the frame cannot be judged with confidence, the system marks it as such instead of guessing.
• The decision. The camera prepares the card, and the person responsible for the HACCP system draws the conclusion.

Where to start a few months before the audit?

1. List the rules of conduct from the HACCP plan and prerequisite programs whose violations are visible on video.
2. Work out with us which of these zones your existing cameras already cover.
3. Set up video monitoring in line with the personal data law: purpose, internal policy, staff acknowledgment.
4. Start monitoring and get the first report on your own events: number of cards, how many were confirmed, over what period.
5. Bring the confirmed rules into daily work; we refine the rest for your site.
6. Prepare a report for the period and a log verification procedure for the auditor.

Sources

1. Law of Ukraine «Про основні принципи та вимоги до безпечності та якості харчових продуктів» (“On Basic Principles and Requirements for Food Safety and Quality”) of December 23, 1997, No. 771/97-VR (Art. 1, 21, 48)
2. Order of the Ministry of Agrarian Policy and Food of October 1, 2012, No. 590 «Про затвердження Вимог щодо розробки, впровадження та застосування постійно діючих процедур, заснованих на принципах НАССР» (“On Approval of the Requirements for the Development, Implementation and Application of Permanent Procedures Based on HACCP Principles”)
3. IFS, Guideline for the IFS Food Audit Checklist, version 8
4. IFS Food, standard page
5. BRCGS, Global Standard Food Safety (Issue 9)
6. BRCGS, public consultation on the next issue of the standard
7. FSSC, FSSC 22000 Version 7: Key Changes Explained
8. ISO 22002-1:2025, Prerequisite programmes on food safety, Part 1: Food manufacturing
9. ISO/TS 22002-1:2009 (previous edition)
10. FAO/WHO Codex Alimentarius, General Principles of Food Hygiene CXC 1-1969