A mock recall in under four hours

At a glance

• A mock recall proves two things: that you can find where a lot came from and where it went, and that your team knows what to do when it matters.

• Food law expects every food business to know who supplied it and which businesses it supplied: one step back and one step forward.

• BRCGS Food Safety Issue 9 expects a trace test at least once a year, with the quantities added up, and says a full trace should be achievable within four hours.

• Pick the lot without warning. A test people can prepare for doesn’t test much.

• The quantities have to add up. If 500 kg came in, you should be able to say where 500 kg went.

This guide is for the quality lead at a small food, drink or supplement site. It explains how to run a trace test and a mock recall, what to time, and what to do with the result. We’ll add a free mock recall worksheet to the site soon.

1. Two tests in one

• The trace test checks your records: can you follow a lot through the site?

• The recall test checks your people and your plan: who decides, who phones whom, and how fast.

You can run them together. Start with the trace, then act out the first hour of a recall using what the trace found.

2. Before you start

You need:

• a written recall plan naming the team, what each person does, and who covers when they’re away

• an up-to-date contact list, including out-of-hours numbers: your team, suppliers, customers, your certification body, your local authority and the testing lab

• someone to run the clock and write down times

Don’t tell the team which lot or which day.

3. Run the trace

Do it in both directions over the year: one test starting from a finished product, one starting from a raw material or a packaging item.

Starting from a finished product lot (backwards and forwards):

1. Find the batch record. Note the time.

2. List every ingredient and packaging lot that went into it, with supplier and delivery.

3. List every customer and delivery that received the lot, with quantities and dates.

4. Find what’s left in your own stock.

5. Pull the checks that go with the batch: process checks, cleaning and changeover before it, label check, release.

Starting from a raw material lot (forwards):

1. Find the delivery and how much arrived.

2. List every batch that used it, and how much each used.

3. For each of those batches, list where it went.

4. Find what’s left in stores, and any written off as waste.

Don’t forget rework, part-used bags, and printed packaging. They are where traces usually break.

4. Make the quantities add up

For the starting lot, fill in one line:

Amount received or made = amount used or dispatched + amount in stock + waste and samples

Small differences happen. Decide in advance what counts as acceptable for that material, and investigate anything outside it. A trace that finds every document but can’t account for 40 kg hasn’t passed.

5. Act out the first hour

With the trace in hand, gather the recall team and work through it as if it were real:

• Decide. Is this a withdrawal or a recall? A withdrawal takes product back before it reaches consumers. A recall is needed when it has already reached them.

• Who do you tell? Customers who received it, your local authority, the Food Standards Agency (or Food Standards Scotland), and your certification body. Check the numbers on your contact list work, without alarming anyone: say clearly it’s a test, or just confirm the number is current.

• What do you say? Draft the notice to customers: product, lot codes, the problem, what to do with it.

• What happens to the product? How it comes back, where it’s held, who decides its fate.

Write down the time each step was reached.

6. Score it honestly

Record:

• time to complete the trace in each direction

• whether the quantities added up

• every point where you had to hunt, guess or ask someone who “just knows”

• contact details that were wrong or missing

• anything in the plan that didn’t match what people actually did

Each of those is a finding. Give it an owner and a date, then run the test again once it’s fixed.

7. If it’s ever real

Under BRCGS Food Safety Issue 9, a certificated site must tell its certification body within three working days of a significant food safety incident, recall or safety-related withdrawal, and follow up with the full details within 21 calendar days. If you have reason to believe food you supplied is unsafe, the law requires you to tell your local authority and the Food Standards Agency (Food Standards Scotland in Scotland). Both agencies have incident teams and online report forms.

Checklist

• Recall plan with named team, deputies and roles

• Contact list checked in the last few months, with out-of-hours numbers

• One test from a finished product and one from a material each year, at least

• Lot chosen without warning

• Times recorded for each stage

• Quantities reconciled, with an agreed tolerance

• Findings turned into actions, and a retest

Common mistakes

• Choosing an easy lot. Pick one with rework, several customers or a shared ingredient.

• Tracing documents but not quantities.

• Forgetting packaging and labels.

• Only ever testing in one direction.

• A contact list nobody has rung in two years.

• Calling it a pass and filing it, with the slow steps left as they were.

Where this sits in the standards

BRCGS Food Safety Issue 9 covers traceability in 3.9, which it treats as a fundamental requirement, and incidents, withdrawal and recall in 3.11. Other standards ask for the same job in their own words and may set different timings.

Sources (checked 10 November 2026)

• BRCGS Global Standard Food Safety, Issue 9 (our own reading; no text reproduced). The standard itself is available from BRCGS: brcgs.com

• GOV.UK, Food traceability for businesses (one step back, one step forward; records to keep): https://www.gov.uk/government/publications/food-traceability-for-businesses/food-traceability-for-businesses

• Food Standards Agency, Food incidents, product withdrawals and recalls (guidance and templates): https://www.food.gov.uk/business-guidance/food-incidents-product-recalls-and-withdrawals

• Food Standards Scotland, Food and feed incidents (withdraw before the consumer, recall after; notify the local authority): https://www.foodstandards.gov.scot/business-guidance/running-a-food-business/food-and-feed-incidents

• FSA and FSS, Quick reference guide: food traceability, withdrawals and recalls (incident team contacts): https://www.food.gov.uk/sites/default/files/media/document/Quick-reference-guide-Food-traceability-withdrawals-and-recalls.pdf

• GOV.UK, Report a food safety incident for local authorities and businesses (England, Wales and Northern Ireland; updated 5 August 2026): https://www.gov.uk/government/publications/report-a-food-problem/report-a-food-safety-incident

The test method, scoring and lists are general guidance based on common practice.

QAaval helps quality teams keep these records on the shop floor.