Recall and Mock-Recall Readiness

A run-through to work before an audit or your annual recall test — recall plan current, contacts verified, both-direction trace tested, effectiveness measured — tick each item only when you can put your hand on the record that proves it.

Work this list before a certification audit, or as the yearly self-review of the recall program every GFSI-benchmarked scheme expects you to test. Read each item against your own records and tick it only when you can put your hand on the one that proves it; the ones you cannot tick are your prep list. This checklist backs up the lesson on running a mock recall step by step, which walks the drill these items verify.

Confirm your edition, and know what has no clock

These items are written against the SQF Food Safety Code: Food Manufacturing, Edition 9 — the edition audits run on through 2026 — so confirm which edition your audit is booked against on the SQFI code library before you lean on a clause number below. Hold onto one thing: the SQF code sets no time limit on a trace. The "trace 100% in 2 to 4 hours" bar operators repeat is a customer and industry expectation, not an SQF clause. And not every item reaches every operation — the FSMA 204 item applies only to foods on FDA's Food Traceability List. Verified July 2026.

Do this in your operation

A written recall and withdrawal plan exists, and it separates a recall from a withdrawal. Confirm you keep a documented plan that names who initiates, manages, and investigates the event, and that it distinguishes a recall — product that already reached your customers — from a withdrawal of product still under your control. SQF clause 2.6.3.1 requires those responsibilities and methods in writing, including where you turn for legal and regulatory advice. Record: the current plan.
The plan names every party it must notify, and how. Confirm the plan carries a communication plan covering site personnel, customers, consumers, and the appropriate regulatory authority — and, for an SQF site, lists SQFI and your certification body as essential organizations to notify for a food safety incident of a public nature or a product recall for any reason (clause 2.6.3.1). If you are subject to FDA's preventive-controls rule for a food with a hazard requiring a control, 21 CFR 117.139 also requires the plan to spell out notifying your direct consignees, notifying the public when it takes that to protect health, running effectiveness checks, and disposing of the recalled food. Record: the notification section, current.
The plan was reviewed within the last 12 months and reflects your operation today. Confirm the plan was reviewed inside the last year and matches your current process, products, and people — SQF folds that review into the annual recall-system test in clause 2.6.3.2. A plan that names a supervisor who left or a customer you dropped is not current. Record: the dated review.
The internal recall team is named, still employed, and reachable after hours. Confirm every person named to initiate, manage, and investigate a recall still works there, each role is filled, and you have a way to reach each one outside business hours — a recall does not wait for Monday. Record: the team roster with current contact details.
Your direct-customer contact list is current, and you have proven you can reach them. Confirm you can reach every direct account the product ships to — the consignee, not the shelf the shopper bought from — and spot-check that the phone numbers and emails still land. This is the list a real recall runs on and the one that rots fastest. Record: the verified consignee contact list.
External contacts are current and the reporting clocks that bind you are known. Confirm the plan holds current contacts for your certification body, SQFI, the appropriate regulatory authority, and your legal and insurance advisors. Know the deadlines that apply: for an SQF site, SQFI and the certification body must be notified in writing within 24 hours of a food safety event that requires public notification (clause 2.6.3.4). Record: the external contact list and the notification deadlines you owe.
You have run a mock recall in the last 12 months — a drill, not a paper review. Confirm the recall system was tested inside the last year, as SQF clause 2.6.3.2 requires: reviewed, tested, and verified as effective, not merely read over. Record: the dated mock-recall test.
The drill used a demanding lot, not the easiest one on the rack. Confirm the test lot came from a bulk or shared material used across several products and shipped to a wide range of customers, and that over time you exercise lots from different shifts — SQF clause 2.6.3.2 asks for exactly this. A one-off batch that went to a single account proves almost nothing. Record: which lot you tested and why it stresses the system.
The backward trace reached the direct supplier of every input, with receipt dates. Confirm the drill traced the finished lot at least one step back — to the manufacturing supplier of every raw material, ingredient, and packaging input — and that the receipt date of each input was on record (SQF clause 2.6.2.1). Record: the backward trace and the receiving records behind it.
The forward trace reached every direct customer, including anything reworked. Confirm the drill traced at least one step forward to every direct customer the lot reached, following each finished lot the inputs touched, and that traceability held where product was reworked into a later batch (SQF clause 2.6.2.1). Record: the forward trace and the shipping records behind it.
If you handle a Food Traceability List food, the same drill proved your records come out in 24 hours. If any food you make, or any ingredient you use, is on FDA's Food Traceability List, the records behind this trace fall under FSMA 204 and must be producible within 24 hours of an FDA request — assembled, for most operations, into a single electronic sortable spreadsheet (21 CFR 1.1455). The rule's compliance date is July 20, 2028, pushed 30 months from the original January 20, 2026; confirm the live date on FDA's Food Traceability Rule page rather than one you remember. Time your drill against that 24-hour clock. Verified July 2026. Record: how long the assembled records actually took to pull.
The trace reconciled — you accounted for the whole lot, not just produced a customer list. Confirm the drill closed the numbers: everything you produced or received under the lot code equals everything shipped, still on hand, consumed into other batches, and documented as loss. A clean customer list with a pallet unaccounted for is a failed trace wearing a passing face. The SQF code names no formula for this, but clause 2.6.3.2 requires the system be verified as effective, and reconciling the quantity is how you show it. Record: the reconciliation, with any gap explained.
The test is documented with start and finish times, the percentage accounted for, and every gap. Confirm you wrote down when the drill started and finished, the share of the lot you accounted for, and each point where the trace stalled or a record was missing — SQF clause 2.6.3.3 requires records of recall tests and the root-cause work behind any failure. An honest write-up of the scramble is worth more than a tidy one that hides it. Record: the mock-recall report.
Every gap has a corrective action, and the ones from last time are closed. Confirm each finding from the drill carries a corrective and preventive action with an owner and a due date, and that the findings from your last test are closed — not still open going into the audit (SQF clause 2.6.3.3). The gaps you fix on an ordinary week are the ones that will not surprise you during a real recall. Record: the corrective-action records, closed.

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