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What specific requirements apply to staff training records for a pharmaceutical licence application? How long must they be retained?

A complete explanation of the regulatory basis, Drew Tang’s recommendations and risk alerts. The original material dates from 2025; read it alongside the latest official requirements.

Original guide, 2025 edition: These FAQs are provided for topic-based reference and have not all been individually checked against current rules. Please confirm fees, personnel, renewal, changes and product requirements against the professional in-depth guide for the relevant licence type and the official requirements in force at the time.

Drug Office, Department of Health Chinese Medicines Board

Q139 · Category C: Eligibility and Personnel Requirements (Q101-Q150)
Training record management is an important part of a pharmaceutical quality management system, and regulators have clear requirements in this area. First, all staff involved in licensed activities must receive initial and ongoing training appropriate to their duties. Second, detailed records must be kept of every training activity. Training records should generally include the date, topic, outline of content, trainer’s name and qualifications, and the signatures of participating staff. For key training in Good Manufacturing Practice (GMP) or Good Distribution Practice (GDP), it is also advisable to keep records of post-training assessments or evaluations. All such training records must be properly retained. As a general recommendation, retain records for at least 5 years or, where specific product expiry requirements apply, for the longer period.

📘 Regulatory basis

Both the Code of Practice for the Guidance of Licensed Wholesale Dealers in Western Medicines and the GMP guidelines for proprietary Chinese medicines expressly require, in their sections on “Personnel” and “Documentation”, that licence holders train their staff and retain relevant records for inspection by the regulatory authorities at any time.

📗 Drew Tang's recommendations

We recommend that clients maintain a separate training file for each employee, systematically recording all training received since joining the company. An annual training plan should also be established and strictly followed. We will provide a full set of training record templates, including attendance sheets, training content summaries and assessment papers, to help clients manage compliance with ease.

📕 Risk notice

Training records are one of the items routinely checked during on-site inspections by the Drug Office. If a company cannot provide adequate, systematic training records, inspectors may conclude that staff competence cannot be assured. This is a major deficiency in the Quality Management System and may result in an unsuccessful inspection or a requirement to complete corrective actions within a specified period.

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