Q147 · Does a company need to appoint a deputy or…

Q147 · Category C: Eligibility and Personnel Requirements (Q101-Q150)

There is no legal requirement to formally appoint a “deputy” or “stand-in” RP or pharmacist for a licence application or day-to-day operations. The statutory requirement is that a qualified, approved key person must be available at all times. However, from the perspective of sound operations and risk management, having an effective succession or temporary cover plan is highly advisable and professional. Large wholesalers or manufacturers commonly appoint a deputy or senior manager who has the potential qualifications to become an RP and is familiar with all relevant duties, so that they can take over promptly if the RP is on leave or leaves unexpectedly. A pharmacy cannot have two pharmacists-in-charge of sale at the same time, but it can establish contacts with locum pharmacists so that temporary cover can be arranged to maintain lawful operations if the pharmacist-in-charge is ill or on leave.

📘 Regulatory basis

The core regulatory requirement is “continuous availability”, not “appointing a designated deputy”. However, guidance such as the Code of Practice forholders of licences issued under the Pharmacy and Poisons Ordinance encourages licence holders to establish a sound Quality Management System, of which continuity of personnel management is one part.

📗 Drew Tang's recommendations

RGYS may assist with clarifying roles, evidence of qualifications and responsibility arrangements within the written scope; the suitability, appointment and actual presence at work of candidates remain subject to verification by the applicant and legally qualified personnel, and no provision or certification of personnel is promised. A potential backup RP can be involved in all relevant compliance meetings and training to ensure that he or she stays up to date. For pharmacies, a reliable contact list of locum pharmacists should be established. This demonstrates the company's management maturity and commitment to business continuity.

📕 Risk notice

The greatest risk of having no contingency plan is that, if a key person suddenly leaves or becomes unable to perform their duties, the company will immediately fall into a non-compliant state. Finding and appointing a new qualified person takes time. During this gap, the company may be forced to suspend all licensed activities, resulting in substantial business losses and customer attrition.

Plan Your Hong Kong Pharmaceutical Licensing Project with Drew Tang

Business Manager Tang Shangyong (Drew Tang) will review your products, operating model, licence type and preparation requirements with you one-to-one. The precise service scope is confirmed in writing; pharmaceutical duties are carried out by legally qualified personnel, and approvals are determined by the competent authorities.

Does a company need to appoint a deputy or alternate for the Responsible Person (RP) or registered pharmacist?

Plan Your Hong Kong Pharmaceutical Licensing Project with Drew Tang