Pharmaceutical Product Recall Readiness Checklist

Pharmaceutical recall readiness is a regulatory requirement and patient safety obligation. This readiness checklist verifies that distribution traceability, notification procedures, and effectiveness check programs meet FDA 21 CFR 7 recall requirements.

  • Industry: Pharmaceutical & Life Sciences
  • Frequency: Annual Readiness Review / Per Recall Event
  • Estimated Time: 30-45 minutes
  • Role: QA Director / Regulatory Affairs Director
  • Total Items: 31
  • Compliance: FDA 21 CFR Part 7 - Enforcement Policy: Recalls, FDA Regulatory Procedures Manual Chapter 7 - Recall Procedures, FDA Guidance for Industry - Product Recalls Including Removals and Corrections, EU GMP Chapter 8.5 - Product Recalls

Distribution Records and Traceability

Verify distribution traceability capability.

  • Complete lot-level distribution records accessible for all marketed lots?
  • Customer database current with current contact information for all accounts?
  • Ability to generate consignee list by lot number within 2 hours?
  • Quantity shipped by lot trackable from distribution records?
  • Downstream tracing capability to retail or patient level where required?

Health Hazard Evaluation

Verify HHE capability.

  • Medical officer or qualified clinician available to lead HHE?
  • HHE template and procedure in place for rapid health hazard assessment?
  • Recall class determination procedure documented per FDA Class I/II/III criteria?
  • Risk assessment methodology for determining recall depth documented?
  • Access to medical, toxicological, and regulatory expertise for HHE support?

FDA Notification and Communication

Verify FDA notification procedures.

  • FDA District Office contact and reporting procedures documented?
  • Field Alert Report (FAR) procedure for 3-day initial notification ready?
  • Recall strategy template prepared per 21 CFR 7.42?
  • Press release template prepared for Class I/II public recalls?
  • Media spokesperson and communications protocol designated?

Customer and Downstream Notification

Verify customer notification capability.

  • Recall notification letter template prepared per FDA format requirements?
  • Ability to notify all direct accounts within 24 hours for Class I?
  • Return/destruction instructions and authorization numbers process documented?
  • Process for directing customers to notify their own downstream customers?
  • Recall hotline or contact point established for customer inquiries?

Effectiveness Checks

Verify effectiveness check procedures.

  • Effectiveness check procedure documented per FDA recall check requirements?
  • Effectiveness check depth (Level A-D) selection criteria documented?
  • Process for following up with non-responding accounts documented?
  • Recall status reporting schedule to FDA (typically every 2 weeks) documented?
  • Recall termination criteria and FDA termination letter process documented?

Mock Recall and Training

Verify recall preparedness training.

  • Annual mock recall exercise conducted within past year?
  • Mock recall completing distribution traceability within 2-hour target?
  • Recall team members trained on recall procedures?
  • Recall team member list current with alternates for all key roles?
  • Lessons from mock recalls or actual recalls incorporated into procedures?
  • Annual recall readiness report completed?

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Why Use This Pharmaceutical Product Recall Readiness Checklist?

This pharmaceutical product recall readiness checklist helps pharmaceutical & life sciences teams maintain compliance and operational excellence. Designed for qa director / regulatory affairs director professionals, this checklist covers 31 critical inspection points across 6 sections. Recommended frequency: annual readiness review / per recall event.

Ensures compliance with FDA 21 CFR Part 7 - Enforcement Policy: Recalls, FDA Regulatory Procedures Manual Chapter 7 - Recall Procedures, FDA Guidance for Industry - Product Recalls Including Removals and Corrections, EU GMP Chapter 8.5 - Product Recalls. Regulatory-aligned for audit readiness and inspection documentation.

Frequently Asked Questions

What does the Pharmaceutical Product Recall Readiness Checklist cover?

This checklist covers 31 inspection items across 6 sections: Distribution Records and Traceability, Health Hazard Evaluation, FDA Notification and Communication, Customer and Downstream Notification, Effectiveness Checks, Mock Recall and Training. It is designed for pharmaceutical & life sciences operations and compliance.

How often should this checklist be completed?

This checklist should be completed annual readiness review / per recall event. Each completion takes approximately 30-45 minutes.

Who should use this Pharmaceutical Product Recall Readiness Checklist?

This checklist is designed for QA Director / Regulatory Affairs Director professionals in the pharmaceutical & life sciences industry. It can be used for self-assessments, team audits, and regulatory compliance documentation.

Can I download this checklist as a PDF?

Yes, this checklist is available as a free PDF download. You can also use it digitally in the POPProbe mobile app for real-time data capture, photo documentation, and automatic reporting.

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