How long should a mock recall take?

There is no single number, but most auditors want to see a trace finished within two to four hours. Time your drill and work to shorten the slowest step.

How often should we run one?

Run a mock recall on a set schedule - many small plants do it once or twice a year - and after any major change to suppliers, customers, or records.

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recall

How do I run a mock recall with a 3-person team?

A mock recall tests whether a small team can trace one lot forward to customers and back to its inputs within the window an auditor expects. Pick a finished lot, pull the production and shipping records, list every customer who received it, and time how long the trace takes. The gaps you find are the point of the exercise.

Reviewed by Steven Moussawer, PCQI , Sep 08, 2026

Pick one lot and trace it both ways

Choose a finished lot you shipped in the last few months. Working from the lot code, pull the batch record to find the ingredient lots that went into it, then pull the shipping records to find every customer who received it. The backward trace answers "what was in this," the forward trace answers "where did it go." A 3-person team can split the two directions and meet in the middle.

Time it and write down the gaps

The exercise is only useful if you time it and record what slowed you down - a missing lot code, a handwritten log, a customer you could not reach. 21 CFR 117.139 expects a written recall plan, and FSMA 204 raises the bar on traceability records for listed foods. Run the drill on a schedule, fix the slowest step each time, and keep the dated results so the improvement is visible to you and to an auditor.

Frequently Asked Questions

Sources & Citations

21 CFR 117.139 - Recall plan §117.139
21 CFR 7.40 - Recall policy §7.40
FSMA 204 - Additional traceability records for certain foods §Part 1 Subpart S

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