Annual Mock Recalls
Aligned with SQF Code Edition 9 – System Element 2.9.3
Requirement Overview
SQF Code Edition 9, 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
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✓ 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
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Key Team Members:
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• Recall Coordinator
• QA or Traceability Officer
• Communications Lead
• Regulatory Liaison
Evidence to Maintain:
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• Documented team assignments with contact information
• Job descriptions outlining authority and responsibilities during recalls
- • Recall Coordinator • QA or Traceability Officer • Communications Lead • Regulatory Liaison
- • Documented team assignments with contact information • Job descriptions outlining authority and responsibilities during recalls
2. Prepare a Realistic Mock Recall Scenario
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Scenario Criteria:
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• 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:
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• Scenario development notes
• Mock recall scenario approval with signatures
• Assigned timeline and objectives
- • 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
- • Scenario development notes • Mock recall scenario approval with signatures • Assigned timeline and objectives
3. Execute the Mock Recall
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Test Activities Include:
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• 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:
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• Time logs and activity tracking sheets
• Product traceability documentation
• Mock “customer” communication records
- • 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
- • Time logs and activity tracking sheets • Product traceability documentation • Mock “customer” communication records
4. Evaluate Performance and Identify Gaps
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Assessment Metrics:
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• 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::
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• Completed evaluation or scorecard
• Summary of identified weaknesses
• Assigned corrective actions
- • 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
- • Completed evaluation or scorecard • Summary of identified weaknesses • Assigned corrective actions
5. Document and Review the Test
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Documentation Requirements:
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• Full test report including all steps and findings
• Corrective/preventive actions
• Update recall SOPs based on lessons learned
Evidence to Maintain::
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• Signed mock recall report with conclusions
• Updated recall SOP and training records
• Corrective action plan with completion tracking
- • Full test report including all steps and findings • Corrective/preventive actions • Update recall SOPs based on lessons learned
- • 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 |