How to Conduct a Food & Beverage Mock Recall Planning Procedures

A food mock recall is a necessary process for any business in the food and beverage space to understand. Both the Food and Drug Administration (FDA) and Centers for Disease Control (CDC) are heavily focused on disease and viral infections being spread through food. In this article, we will discuss how to conduct a food and beverage mock recall planning procedures.

Conducting food and beverage mock recalls ensures your business’s recall management procedures can withstand anything. This requires a solid understanding of what’s involved, including consumer notification, regulatory reporting, and more. It is important that every step of the mock recall planning procedure process can be tested, managed and scaled to accommodate the mock recall.

This proactive approach is similar to conducting mock safety drills and provide a training ground for your team to understand the process without putting lives on the line or disrupting your business. Here’s how to get started.

Why Perform a Food & Beverage Mock Recall?

In 2022, The FDA published its final guidance outlining steps companies should take to develop recall policies and procedures that include training, planning, and record-keeping to help significantly reduce the time a recalled product remains on the market. These mock recall planning procedures test your recall readiness.

The FDA guidance describes an array of best practices for creating, testing, and executing a recall plan. Testing a recall plan means developing recall procedures and planning as if you were actually conducting a real product recall. Because of the FDA’s heightened expectations, along with the greater risk and complexity involved in today’s recalls, training – including regular mock recall exercises – has become an essential part of the recall planning preparation process.

It is imperative that your organization plan, train and test for a product recall by developing and testing mock recall procedures that involves every department in your company.  This includes re-evaluating, and testing your mock recall procedures at least twice a year to make sure it is up to date.

What the Preventative Controls rule of the Food Safety Modernization Act specifies is that there’s a written recall plan in place for any facility that requires preventative control. This is as far as the law goes, but your business can’t depend on an untested process. Just like you go through numerous iterations of testing and quality control before releasing a new product to the public, you need to stress test your written recall plan.

Verify that everything works correctly – your entire supply chain needs to be notified of any issues related to your recall. You need full transparency and traceability of your product’s journey so that you can effectively execute on the plan when necessary. It’s also important that all of your partners both upstream and downstream are notified as well.

Even if your facility remains incident free indefinitely, you may still one day need to deal with the challenges of assisting one of your partners in the process. Familiarizing staff on the proper processes and maintaining regular assessments ensures everyone’s skills are sharp and ready to perform when the time comes.

Elements of a Successful Mock Recall

Whether it’s a mock recall or real one, food and beverage companies need accountability to properly execute on the plan. There are four main elements to build your mock food and beverage recall plan around:

  1. Building a Recall Team

The recall team is the dedicated team that handles all aspects of the recall. Each member coordinates different pieces and has a perspective unique to their skillset. They take on accountability and act as key points of contact while conducting the recall process.

Recall teams require a recall coordinator to oversee and manage the process. This is a project management role that involves herding cats, so to speak, so choose a strong leader. You’ll also need someone to handle external communications (i.e. media), legal counsel, and customer service representatives to speak with consumers.

  1. Establishing a Recall Plan

You recall team will also develop and refine the recall plan. This should account for all aspects of business continuity while also including:

  • Stakeholder notification
  • Quantifiable operational effectiveness
  • Proper product disposal
  • Regulatory requirements
  • Your plan should provide detailed processes and steps that can be followed and trained to the rest of the team, so everyone is on the same page. This keeps the business running while the recall is performed.
  1. Conducting a Mock Recall

Once you recall a product, it needs to be traced. This means you should already have a traceability system in place during normal operations. Since you’re in control of the mock recall, you can choose the timing that’s convenient. Wait too long, however, and your simulation will be too late.

Follow every step and properly document what worked and what didn’t, so that all the potential obstacles are already overcome when it’s time to perform in real life.

  1. Assessing Vulnerabilities and Effectiveness

Food and beverage recalls require intense reporting. Even if you do it right, you can drop the ball on reporting requirements and cause further issues. It’s important to continue mock recall drills until you get it right the first time. Be honest about your assessment of the performance, because real customers and regulators will be less forgiving.

Mock recalls also help you find vulnerabilities in your supply chain. When COVID-19 lockdowns hit, companies of every industry were stress tested in ways never before imagined. Cross contamination with food wasn’t the biggest concern, but there are still major problems that can create a crisis in our supply chains.

About Mock Recalls

MockRecalls is a mock recall planning, training and consulting program to test your recall readiness. We are purely focused on protecting your product investment by working with you to create a new recall plan or analyze your current recall plan and then put it through a mock recall or recall simulation test to insure you are prepared for a possible product recall. We use our on-demand SaaS based recall management platform that eliminates common mistakes manually conducting recalls, by automating the most tedious steps of a product recall. It is a simple to use platform that just focuses on handling product recalls quickly and efficiently. Through our mock recall training using our dedicated recall platform, companies can improve the recall process, increase response rates, and document and communicate with all stakeholders.

Our program can analyze your company’s readiness in many of the typical elements of the recall process including:

  • Initiation, investigation, and communication process
  • Recall working team and decision team composition and dynamics
  • Team roles and responsibilities
  • Process flow and lot traceability
  • And retrieval capability and effectiveness checks

Our recall simulation program is conducted as an escalating model using real product facts and potential issues, with multiple inputs such as consumer complaints, social media, FDA/USDA/local health department and law enforcement. Conducting a recall simulation will also allow the recall team and all involved personnel to become familiar with their responsibilities throughout the recall procedure. This gives them time to effectively communicate any concerns about the plan while the company isn’t dealing with the pressure of an actual recall.

Looking to test your product recall readiness across your organization? MockRecalls will help create and/or test your recall program. Click here to learn more or call us!

Learn more about each department’s role during a product recall