A recall usually reaches a distributor as a call or an email: a supplier has pulled a lot, or a customer has a problem. What happens next depends on whether your records can answer two questions quickly. Where did this lot come from, and who got it? A mock drill asks those questions on an ordinary day, when getting the answer wrong costs nothing.
Why run one
A mock drill is a practice, not a legal requirement. But two FDA rules make it worth doing.
- The Food Traceability Rule (FSMA 204). Once it is enforced on July 20, 2028, you must give the FDA the required records for covered foods within 24 hours of a request, and during an outbreak or recall the FDA can ask for them as an electronic sortable spreadsheet (FDA).
- The preventive controls rule. If your facility has a food safety plan and a food has a hazard that needs a preventive control, you need a written recall plan that covers notifying your direct customers, notifying the public when appropriate, checking that the recall worked, and disposing of the food (21 CFR 117.139). A drill is how you find out whether that plan works.
Why four hours
Four hours is a target we suggest, not a regulatory number. It sits well inside the FDA's 24-hour window, and it is short enough that rebuilding records by hand from paper will show. Use a different limit if you like, but set it before you start, and keep it the same from one drill to the next so you can compare.
Before the day
- Choose a drill lead and a scribe. The lead runs the scenario and must not help. The scribe writes down every step, every question asked and the time each answer arrived.
- Pick the lot. Choose a lot of a covered food received a few months ago, so it has had time to ship to many customers. Do not pick one you already know is easy.
- Write the scenario. For example: "Supplier X has recalled lot ABC123 of romaine, received in the spring. Produce the trace and the customer list." Use the supplier's lot code, not your internal number, because a real notice will.
- Decide what stays simulated. Draft customer notices but do not send them. Mark every drill document "DRILL".
Running the drill: five tasks
- Find the lot. Go from the supplier's lot code to your own records. If your system stores the supplier's traceability lot code in a searchable field, this takes moments. If it sits in a notes field, the drill has already found its first issue.
- Trace back. Pull the receiving record: supplier, date, quantity, purchase order, bill of lading and where the lot code was assigned.
- Account for every unit. Received should equal shipped, plus on hand, plus returned, plus written off or used in repacks. If the numbers do not balance, find out why before you go on. An unexplained gap means some cases may have gone to customers you cannot name.
- Trace forward. List every customer and delivery location that received any of the lot, with quantities, dates and invoice numbers. Include anything repacked from it, and the customers who received the repacked product.
- Act. Put the remaining stock on hold so it cannot be picked. Draft the customer notices with what to do with the product. Assemble the record package the FDA would ask for, including a key to your internal codes, and a spreadsheet of the receiving and shipping records for that item over the relevant dates.
How to score it
| Question | What a pass looks like |
|---|---|
| Did we get from the supplier's lot code to our records without help? | One search, by whoever was on shift |
| Did the units balance? | Every case accounted for, with no guesses |
| Did the customer list include repacks and returns? | Yes, with quantities and dates |
| Could the record package come from the system? | Yes, without hand-built spreadsheets |
| Were customer contacts current? | A working contact, including after hours, for every account on the list |
| Was on-hand stock blocked from picking? | Yes, before the drill ended |
| Could someone else have done it? | No single person whose absence stops the drill |
| How long did it take? | Within your target, recorded per task |
Common places a drill breaks
- The supplier's lot code was typed into a free-text note, so the search is slow or misses entries.
- Pickers recorded quantities but not lots, so the customer list is a guess based on dates.
- Repacked product has no link back to the lot it came from.
- Returned cases went back to stock without their lot.
- Customer contact details are out of date, or exist only in a rep's phone.
- Only one person knows how to pull the report, and they are on vacation.
- Records are split across systems that do not share a lot number.
The debrief
Hold it the same week. For every break, write down what happened, the fix, an owner and a date. Update your written recall plan and, if you handle covered foods, your traceability plan. Then run the drill again in a year, or sooner after a system change, a new warehouse or new staff in receiving.
Vary the scenario each time. Start one drill from a customer complaint and trace back from the invoice. Start another from an FDA-style request for every shipment of one item between two dates. Pick a lot that was repacked. Each version tests a different path through your records.
For the full list of what to have in place before July 2028, see the FSMA 204 readiness checklist, and for quick answers on the rule, the FSMA 204 FAQ and our FSMA 204 guide.
How APFoodz handles it
In APFoodz, each lot's events are recorded as the work happens, so tasks 2 to 4 are a lookup rather than a search through paper, and lots, expiry and quarantine live in the same system. See FSMA 204 traceability and recalls.