Summary
In short
- Choose a batch with rework, blending, partial shipment or repacking in it. Clean batches test the easy path and every real recall involves the complicated one.
- Mass balance is what distinguishes a complete trace from a mostly complete one. Without reconciliation, you have found product rather than accounted for it.
- Test the communication. Whether contact details work, whether people answer out of hours, and whether the person reached has authority to act are all part of a recall and none are tested by a trace.
- Impose a time limit and record the actual elapsed time, including the parts spent waiting for someone to become available.
- Record the problems found, not just the result. An exercise producing no problems has either an exceptional system or an undemanding design, and the second is more common.
- Vary the design between exercises: different batch complexity, different starting point, different time of day. Repeating the same test demonstrates the same thing.
What it is
What it is
What is a mock recall?
A rehearsal of the traceability and communication elements of a recall, tracing a selected batch backward to its inputs and forward to its customers, reconciling quantities, and testing whether the people who would need to be contacted can be.
What does mass balance establish?
Whether the trace is complete. Reconciling what was produced against what was shipped, held, sampled, given away, scrapped and reworked either accounts for everything or reveals a quantity that went somewhere nobody has recorded. An unreconciled trace has located most of the product and cannot say it has located all of it.
When to use it
When to use it, and when not to
This records one exercise. The recall plan it tests sits separately.
Use it for
- Scheduled traceability and recall exercises at the frequency the scheme requires
- Testing after a change to products, customers, markets, distribution or systems
- Exercising the communication chain including out-of-hours contacts
- Verifying that a new or modified traceability system performs under time pressure
- Following a real event, to test that the corrective actions took effect
Not for
- The recall plan, which sets out roles, authority and the decision process
- The real recall record, which documents an actual event
- Traceability system configuration and design
- The complaint or deviation that would trigger a real recall
- Supplier traceability exercises, which test the tier above rather than your own records
Standards
What it is built against
Traceability exercises are required by the schemes and support the statutory recall obligations.
| Clause | Requirement | Where it lands |
|---|---|---|
| SQF Edition 9 cl.2.6 | Product trace, withdrawal and recall, tested at a defined frequency with records | Header |
| BRCGS Issue 9 cl.3.9 | Traceability system tested at least annually, covering forward and backward trace and mass balance | Mass balance |
| BRCGS Issue 9 cl.3.11 | Product withdrawal and recall procedures tested at least annually | Communication test |
| 21 CFR 117.139 | Written recall plan including notification, public warning, effectiveness checks and disposition | Communication test |
| 21 CFR 1 Subpart S | Additional traceability records for foods on the Food Traceability List | Backward trace |
| EU Reg 178/2002 art.18 | One step back and one step forward traceability throughout the food chain | Forward trace |
| ISO 22000 cl.8.3 | Traceability system enabling identification of incoming materials and distribution of finished product | Header |
| 9 CFR 418 | Recall procedures and notification for meat and poultry establishments | Result |
What it does not cover
- The recall plan, setting out roles, decision authority and the process this exercises.
- The real recall record, documenting an actual event.
- Traceability system design and configuration.
- The complaint or deviation that would trigger a real decision.
- Supplier traceability exercises, testing the tier above rather than your own records.
Filling it in
Filling it in well
Choose a hard batch, reconcile the quantities, contact people for real, and record what went wrong.
Rework included, partial shipments, a blended intermediate, repacked product, or material that crossed a shift or a site. These are where lineage breaks, and they are the conditions a real recall will present. A batch chosen because its records are tidy has selected for the answer.
Quantity produced against quantity shipped, held, sampled, scrapped, reworked and given to customers as samples. Mass balance is the step that reveals product nobody has accounted for, and it is the step most often skipped because locating the majority feels like completing the exercise.
Call the numbers. Test whether they connect, whether anyone answers outside working hours, and whether the person reached knows what to do. A contact list is not a communication capability, and lists decay faster than any other part of a recall arrangement.
The value of the exercise is in what went wrong: a record that took forty minutes to find, a customer contact who had left, a quantity that would not reconcile, a system that needed someone on leave to operate it. An exercise report saying the trace completed within target has recorded a time and no learning.
Audit findings
Common audit findings
Mock recall findings concentrate on exercise design.
| Finding | Clause | What fixes it |
|---|---|---|
| Batch selected from a clean run with no rework or partial shipment. | BRCGS 3.9 | Choose complexity; clean batches test the path a real event will not take. |
| Mass balance not performed. | BRCGS 3.9 | Reconciliation is what distinguishes a complete trace from a partial one. |
| Communication tested against a list rather than by contacting people. | 21 CFR 117.139 | Call the numbers; lists decay faster than procedures. |
| Exercise always conducted during working hours. | SQF 2.6 | Real events start out of hours; test at least once when key people are unavailable. |
| Problems encountered not recorded because the target was met. | SQF 2.6 | The problems are the output; the elapsed time is context. |
| Same exercise design repeated each cycle. | BRCGS 3.11 | Vary batch complexity, starting point and timing; repetition demonstrates the same thing. |
| Exercise depends on one person who knows the system. | ISO 22000 cl.8.3 | Run it without them; single-person dependency is itself the finding. |
| Forward trace stops at the direct customer. | EU Reg 178/2002 art.18 | One step forward is the minimum; onward distribution capability should be understood. |
| Products on the Food Traceability List without the additional records. | 21 CFR 1 Subpart S | Check whether products are listed; requirements are additional and specific. |
| Findings not fed back into the recall plan or the traceability system. | SQF 2.6 | An exercise that changes nothing is a rehearsal rather than a test. |
Worked case
Case in point: four hours, and the wrong four hours
A site ran mock recalls twice yearly against a four-hour target and met it every time. The exercises began at ten in the morning with a batch code provided by the quality manager, and concluded when the trace reconciled.
An exercise run deliberately at seven on a Friday evening, using a batch that had been partially reworked, took considerably longer. The rework record was a book kept by the shift leader and reconciled weekly. Two customer contacts were people who had left. The despatch system required a login held by someone on leave.
None of those problems were new. They had existed throughout the two years of successful exercises, which had been designed in a way that never encountered any of them.
Definitions
Definitions and key terms
- Backward trace
- Identifying the inputs to a batch: materials, lots, suppliers and the processing history.
- Forward trace
- Identifying where a batch went: customers, quantities, dates and onward distribution.
- Mass balance
- Reconciliation of quantities produced against shipped, held, sampled, scrapped and reworked, which tests completeness.
- One up one back
- The minimum traceability requirement: the immediate supplier and the immediate customer.
- Communication test
- Actually contacting the people a recall would require, rather than confirming a list exists.
- Exercise design
- The choices about batch, timing and scope, which frequently determine the result more than the system does.
- Food Traceability List
- The FDA list of foods subject to additional traceability record requirements.
- Single-person dependency
- Where the exercise can only be completed by one individual, which is a finding in its own right.
FAQ
Frequently asked questions
Why should the exercise be designed to fail?+
Because an exercise that cannot fail confirms what you already believed. Choosing a difficult batch, an inconvenient time and real contact attempts locates the failure points while nothing is at stake, which is the entire purpose. An exercise designed to produce a pass reliably produces one and teaches nothing.
What makes a batch difficult?+
Rework, blending, partial shipments, repacking, or material that crossed a shift or a site boundary. These are where lineage breaks and where records are least likely to be complete. They are also what a real event will involve, because the batches that generate problems are rarely the tidy ones.
Why does mass balance matter?+
Because it is the difference between locating product and accounting for it. Reconciling produced against shipped, held, sampled, scrapped and reworked either closes or reveals a quantity nobody can place. A trace that found ninety percent of a batch and stopped has not established where the remainder went.
Should we actually call people?+
Yes. Contact lists decay faster than any other part of a recall arrangement, and the discovery that a key number reaches someone who left two years ago reliably happens during a real event. Testing whether numbers connect, whether anyone answers out of hours, and whether the person reached can act is part of the exercise.
What should the record contain?+
The problems. Elapsed time is useful context and it is not the output. A record showing that a rework entry took forty minutes to locate, that two contacts were unreachable, and that the despatch report needed a login held by one person is worth considerably more than one showing the target was met.
The agents
What the agents do with it
The exercise tests the trace and the contacts. What fails is a design that selected for the answer.
Selects batches by complexity rather than convenience, records problems alongside elapsed time, and varies the design between exercises.
Performs the forward trace across shipments and partial consignments, and produces the mass balance reconciliation.
Tracks which conditions have been exercised and which have not, so repetition of the same design becomes visible.
Verifies contact details as part of each exercise and flags where notification obligations differ by market.
This template lives in KnowQuality — quality and food safety. HACCP, nonconformance, traceability, laboratory and customer complaints.
Sources
Sources
- SQF Edition 9 clause 2.6, product trace, withdrawal and recall
- BRCGS Food Safety Issue 9 clauses 3.9 and 3.11, traceability and recall testing
- 21 CFR 117.139, recall plan, FDA
- 21 CFR Part 1 Subpart S, additional traceability records, FDA
- Regulation (EC) 178/2002 article 18, traceability (EU)