Pharmaceutical Product Recall Readiness Checklist

Pharmaceutical product recalls protect public health when a product is defective or potentially harmful. This readiness checklist ensures recall capabilities meet FDA 21 CFR Part 7 requirements and can be rapidly mobilized when needed.

  • Industry: Pharmaceutical & Life Sciences
  • Frequency: Annual
  • Estimated Time: 30-45 minutes
  • Role: Regulatory Affairs Manager / Quality Director
  • Total Items: 31
  • Compliance: FDA 21 CFR Part 7 - Enforcement Policy (Recalls), FDA 21 CFR 314.81 - NDA Post-Marketing Reports (Field Alerts), EU Regulation No. 726/2004 - Post-Authorization Safety Measures, ICH E2D Post-Approval Safety Data Management

Recall SOPs and Procedures

Verify recall procedures are current and tested.

  • Written recall and market withdrawal SOP current and approved?
  • Recall classification criteria (Class I, II, III) documented with decision framework?
  • 24/7 emergency contact list for recall team maintained and current?
  • Field Alert Report (FAR) SOP including 3-day reporting timeline?
  • Press release, consignee notification, and FDA letter templates prepared?

Product Traceability and Distribution Records

Verify traceability and distribution record availability.

  • Distribution records maintained enabling lot-level traceability to consignees?
  • Current consignee database with contact information maintained?
  • Distribution records accessible within 24 hours for any lot?
  • DSCSA track-and-trace system implemented for prescription drug traceability?
  • International distribution records available for exported products?

Mock Recall Exercises

Review mock recall performance.

  • Annual mock recall exercise completed?
  • Mock recall timed with trace-back to 100% lot accountability within required time?
  • Mock recall tested realistic scenario including regulatory notification process?
  • Mock recall lessons learned documented with improvements implemented?
  • 3-calendar-day Field Alert Report timeline achievable per mock exercise?

FDA and Regulatory Notification

Verify notification procedures.

  • FDA district office and recall coordination contacts current?
  • Field Alert Report (FAR) requirements understood - 3-day initial, 15-day written?
  • Recall strategy template (depth, public warning, effectiveness check) prepared?
  • Legal review process for press releases and public communications established?
  • International regulatory notification procedures for ex-US markets?

Recall Effectiveness Checks

Verify effectiveness check procedures.

  • Recall effectiveness check SOP defining methodology and success criteria?
  • Status report schedule for recall progress to FDA defined?
  • Returned product tracking and reconciliation process defined?
  • Recalled product destruction documentation and FDA notification process?
  • Recall closure criteria and FDA closeout request process defined?

Documentation and Readiness

Verify recall documentation readiness.

  • Recall readiness file organized with all required documentation?
  • Product liability insurance current and covering recall costs?
  • Regulatory legal counsel identified and engaged?
  • Crisis communications plan for media and customer inquiries?
  • Any prior recalls analyzed for systemic issues to prevent recurrence?
  • Annual recall readiness assessment report prepared?

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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 regulatory affairs manager / quality director professionals, this checklist covers 31 critical inspection points across 6 sections. Recommended frequency: annual.

Ensures compliance with FDA 21 CFR Part 7 - Enforcement Policy (Recalls), FDA 21 CFR 314.81 - NDA Post-Marketing Reports (Field Alerts), EU Regulation No. 726/2004 - Post-Authorization Safety Measures, ICH E2D Post-Approval Safety Data Management. 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: Recall SOPs and Procedures, Product Traceability and Distribution Records, Mock Recall Exercises, FDA and Regulatory Notification, Recall Effectiveness Checks, Documentation and Readiness. It is designed for pharmaceutical & life sciences operations and compliance.

How often should this checklist be completed?

This checklist should be completed annual. Each completion takes approximately 30-45 minutes.

Who should use this Pharmaceutical Product Recall Readiness Checklist?

This checklist is designed for Regulatory Affairs Manager / Quality 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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