Mock recall (recall drill) checklist template

How to use this template

1. Pick a real lot of a finished product and write at the top the facility, the product, the lot code and the date and time the drill starts.
2. For each action, write the person your written plan assigns and the section of the procedure that was followed (21 CFR 117.139(b)).
3. Record when each step starts and ends and what you found (for example, how many direct consignees you could notify and whether information was missing).
4. At the end, write the changes the plan needs and who will make them; the blank rows are for steps specific to your plan.

What the rule says

• The written recall plan must include procedures that describe the steps to be taken, and assign responsibility for taking those steps, to perform these actions as appropriate to the facility: (1) directly notify the direct consignees of the food being recalled, including how to return or dispose of the affected food; (2) notify the public about any hazard presented by the food when appropriate to protect public health; (3) conduct effectiveness checks to verify that the recall is carried out; and (4) appropriately dispose of recalled food, for example through reprocessing, reworking, diverting to a use that does not present a safety concern, or destroying the food (21 CFR 117.139(b)).
• The recall plan is one of the rule's preventive controls (21 CFR 117.135(c)(5)).
• The text of 21 CFR 117.139 requires a written plan; it does not mention drills. Practicing it is a way to check the plan works before you need it.
• If your facility is SQF certified (a voluntary certification many buyers ask for, not a law), the SQF Food Manufacturing Code, Edition 9, requires the withdrawal and recall system to be reviewed, tested and verified as effective at least once a year. The test must cover incoming materials (traced at least one step back) and finished product (at least one step forward), and use products from different shifts. Records of the tests must be kept (clauses 2.6.3.2 and 2.6.3.3).
• Edition 10 of the SQF Food Manufacturing Code keeps the annual test and adds that it must include all components of the recall program (clause 2.6.3.2). Check with your certification body which edition applies to your next audit.
• Part 117 records are kept for at least 2 years after the date they were prepared (21 CFR 117.315(a)(1)).