Standard Operating Procedure for Conducting Mock Recalls of Injectable Products
| Department | Sterile Injectable Manufacturing |
|---|---|
| SOP No. | SOP/SIM/090/2025 |
| Supersedes | SOP/SIM/090/2022 |
| Page No. | Page 1 of 14 |
| Issue Date | 18/06/2025 |
| Effective Date | 20/06/2025 |
| Review Date | 18/06/2026 |
1. Purpose
To define the procedure for conducting periodic mock recall exercises of sterile injectable products to evaluate the effectiveness of the recall system and improve traceability and responsiveness during actual recall events.
2. Scope
This SOP is applicable to all marketed sterile
injectable products manufactured at the facility and covers the planning, execution, documentation, and evaluation of mock recall exercises.
3. Responsibilities
- QA Manager: Overall in-charge of the mock recall process and reporting outcomes.
- Recall Coordinator: Plans and executes the mock recall with cross-functional team support.
- Stores Department: Provides distribution and inventory data as required.
- Documentation Team: Maintains records and evaluates performance metrics.
4. Accountability
The Head of Quality is accountable for ensuring compliance with the mock recall procedure and reporting findings to senior management.
5. Procedure
5.1 Planning
- QA shall plan one mock recall every year as part of the quality system review.
- Select a product batch randomly from the list of released injectable products.
- Prepare a Mock Recall Plan (Annexure-1) detailing objective, product details, team members, and recall strategy.
5.2 Execution
- Initiate recall from dispatch records and simulate tracing the product down to distributor level.
- Verify accuracy and completeness of:
- Batch Manufacturing Record (BMR)
- Batch Packing Record (BPR)
- Distribution records
- Document time taken to trace and locate all shipped quantities.
- Complete the Mock Recall Execution Log (Annexure-2).
5.3 Evaluation
- QA shall analyze gaps in documentation, traceability, and communication.
- Summarize outcomes in a Mock Recall Evaluation Report (Annexure-3).
- Share findings with Quality Head and senior management for review and training enhancement.
5.4 Closure
- Prepare a Corrective and Preventive Action (CAPA) plan based on observations (Annexure-4).
- Update the Mock Recall Register (Annexure-5).
- Review this SOP annually based on outcomes.
6. Abbreviations
- SOP: Standard Operating Procedure
- QA: Quality Assurance
- BMR: Batch Manufacturing Record
- BPR: Batch Packing Record
- CAPA: Corrective and Preventive Action
7. Documents
- Mock Recall Plan – Annexure-1
- Execution Log – Annexure-2
- Evaluation Report – Annexure-3
- CAPA Plan – Annexure-4
- Mock Recall Register – Annexure-5
8. References
- WHO TRS 996 Annex 3 – Good Manufacturing Practices
- 21 CFR Part 7 – Recall Procedures
- ICH Q10 – Pharmaceutical Quality System
9. SOP Version
Version: 2.0
10. Approval Section
| Prepared By | Checked By | Approved By | |
|---|---|---|---|
| Signature | |||
| Date | |||
| Name | |||
| Designation | Manufacturing Executive | QA Executive | Head QA |
| Department | Production | Quality Assurance | Quality Assurance |
11. Annexures
Annexure-1: Mock Recall Plan
| Product | Batch No. | Recall Date | Team Lead |
|---|---|---|---|
| Injexol 250mg | BN25023 | 01/05/2025 | Sunita Reddy |
Annexure-2: Execution Log
| Time Started | Distributor Traced | Quantity Found | Time Completed |
|---|---|---|---|
| 09:00 AM | PharmaLink Distributors | 500 vials | 12:30 PM |
Annexure-3: Evaluation Report
| Observation | Impact | Recommendation |
|---|---|---|
| Delay in distributor contact | Moderate | Improve contact list accuracy |
Annexure-4: CAPA Plan
| Action | Responsible | Due Date | Status |
|---|---|---|---|
| Update recall SOP contact info | QA Manager | 10/05/2025 | Completed |
Annexure-5: Mock Recall Register
| Date | Batch | Product | Status | Remarks |
|---|---|---|---|---|
| 01/05/2025 | BN25023 | Injexol 250mg | Completed | Effective |
Revision History
| Revision Date | Revision No. | Details | Reason | Approved By |
|---|---|---|---|---|
| 10/04/2022 | 1.0 | Initial Version | New SOP | QA Head |
| 18/06/2025 | 2.0 | Annexures revised, contact protocols added | Annual Review | QA Head |