SOP Guide for Pharma

Sterile Injectable Manufacturing: SOP for Conducting Mock Recalls of Injectable Products – V 2.0

Sterile Injectable Manufacturing: SOP for Conducting Mock Recalls of Injectable Products – V 2.0

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

  1. QA shall plan one mock recall every year as part of the quality system review.
  2. Select a product batch randomly from the list of released injectable products.
  3. Prepare a Mock Recall Plan (Annexure-1) detailing objective, product details, team members, and recall strategy.

5.2 Execution

  1. Initiate recall from dispatch records and simulate tracing the product down to distributor level.
  2. Verify accuracy and completeness of:
    • Batch Manufacturing Record (BMR)
    • Batch Packing Record (BPR)
    • Distribution records
  3. Document time taken to trace and locate all shipped quantities.
  4. Complete the Mock Recall Execution Log (Annexure-2).

5.3 Evaluation

  1. QA shall analyze gaps in documentation, traceability, and communication.
  2. Summarize outcomes in a Mock Recall Evaluation Report (Annexure-3).
  3. Share findings with Quality Head and senior management for review and training enhancement.

5.4 Closure

  1. Prepare a Corrective and Preventive Action (CAPA) plan based on observations (Annexure-4).
  2. Update the Mock Recall Register (Annexure-5).
  3. 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

  1. Mock Recall Plan – Annexure-1
  2. Execution Log – Annexure-2
  3. Evaluation Report – Annexure-3
  4. CAPA Plan – Annexure-4
  5. 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
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