Annual Mock Recalls

Aligned with SQF Code Edition 10 – System Element 2.9.3

Requirement Overview

SQF Code Edition 10, System Element 2.9.3, requires:

“Records of recalls, including mock recalls, shall be maintained and tested at least annually to ensure the effectiveness of the recall and withdrawal system.”

An annual mock recall confirms your team’s ability to execute product withdrawals, traceability, and customer communication quickly and effectively—essential for audit readiness and food safety protection.

Disclaimer: Food Safety Systems is not affiliated with or endorsed by the Safe Quality Food Institute (SQFI). This article is intended for educational and compliance guidance only. For official SQFI documentation, visit www.sqfi.com.

Key Compliance Objectives

✓ Test and evaluate the recall and withdrawal process
✓ Validate the accuracy of traceability records
✓ Train staff to respond effectively during recalls
✓ Maintain documentation of each test and corrective actions

Step-by-Step Compliance Implementation

1. Establish a Recall Team and Define Roles

Key Team Members:

• Recall Coordinator
• QA or Traceability Officer
• Communications Lead
• Regulatory Liaison

Evidence to Maintain:

• Documented team assignments with contact information
• Job descriptions outlining authority and responsibilities during recalls

2. Prepare a Realistic Mock Recall Scenario

Scenario Criteria:

• Use a randomly selected product or batch
• Base the scenario on a realistic threat (e.g., foreign material, undeclared allergen, mislabeling)
• Simulate traceability and communication actions

Evidence to Maintain:

• Scenario development notes
• Mock recall scenario approval with signatures
• Assigned timeline and objectives

3. Execute the Mock Recall

Test Activities Include:

• Initiate internal alert and team notification
• Activate product traceability and retrieve distribution logs
• Simulate external communication to mock customers
• Track time and response at each stage

Evidence to Maintain:

• Time logs and activity tracking sheets
• Product traceability documentation
• Mock “customer” communication records

4. Evaluate Performance and Identify Gaps

Assessment Metrics:

• Time to trace and retrieve 100% of affected product
• Accuracy and completeness of distribution data
• Staff understanding of recall procedures
• Clarity and effectiveness of communication

Evidence to Maintain:

• Completed evaluation or scorecard
• Summary of identified weaknesses
• Assigned corrective actions

5. Document and Review the Test

Documentation Requirements:

• Full test report including all steps and findings
• Corrective/preventive actions
• Update recall SOPs based on lessons learned

Evidence to Maintain:

• Signed mock recall report with conclusions
• Updated recall SOP and training records
• Corrective action plan with completion tracking

Common Audit Findings & Recommended Fixes

Audit Finding Recommended Action

No mock recall conducted annually Schedule and log annual mock recall with team

Scenario lacks realism Use product-specific, risk-based recall scenarios

Incomplete documentation Maintain recall test logs, reports, and CAPAs

No improvements post-test Review outcomes and update procedures accordingly

Audit Finding	Recommended Action
No mock recall conducted annually	Schedule and log annual mock recall with team
Scenario lacks realism	Use product-specific, risk-based recall scenarios
Incomplete documentation	Maintain recall test logs, reports, and CAPAs
No improvements post-test	Review outcomes and update procedures accordingly

Auditor Verification Checklist

During an audit, expect the following:

• Review of the mock recall report and approval signature
• Verification of traceability testing accuracy
• Evidence of communication with mock stakeholders
• Records of corrective/preventive actions and plan updates

Implementation Roadmap

Build Your Program

✓ Assign a trained recall team
✓ Develop your recall plan and SOPs

Train and Validate

✓ Simulate realistic recall events
✓ Train QA, warehouse, and logistics teams

Operate and Monitor

✓ Conduct mock recalls annually
✓ Maintain logs, communications, and response metrics

Improve Continuously

✓ Document findings and improvements
✓ Update recall protocols after every test or real incident

Why This Matters?