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For storing controlled medicines (dangerous drugs), what additional security and record-keeping measures are required beyond a locked poison cupboard?

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

Q165 · Category D: Premises and Storage Requirements (Q151-Q200)
Storage of drugs controlled under the Dangerous Drugs Ordinance (Cap. 134) (for example, certain potent analgesics) is subject to stricter security and record-keeping requirements than ordinary poisons. First, the storage facility must be a fixed, robust safe or vault; an ordinary locked cabinet is not sufficient. The safe must be secured to the building structure so that it cannot easily be removed as a whole. Second, access to and handling of these drugs must be very strictly controlled, usually through a dual-person, dual-lock or similar system, under which two authorised persons must be present for each operation. Third, and most importantly, a dedicated Dangerous Drugs Register must be maintained. Every receipt and issue must be recorded promptly and accurately, including the date, source or destination, quantity and signatures of the persons handling the transaction. The register must follow the prescribed statutory format and must not be altered.

📘 Regulatory basis

The Dangerous Drugs Ordinance (Cap. 134) and its regulations contain highly detailed and mandatory requirements for the storage, custody and recording of dangerous drugs. Any breach is a criminal offence. The Ordinance expressly requires licensed wholesalers to keep a dangerous drugs register and record all transactions in the prescribed form.

📗 Drew Tang's recommendations

We recommend that clients have two people check and sign every entry in the dangerous drugs register to minimise clerical errors. The register should be kept as securely as cash. Stock should also be physically counted and reconciled against the register balance regularly (for example, monthly), with the results recorded. Any discrepancy must be investigated and reported immediately.

📕 Risk notice

The management of dangerous drugs is a top regulatory priority, and any lapse can have extremely serious consequences. Late or inaccurate register entries, or unauthorised alterations, may be regarded as offences. Any unaccounted loss of medicines may trigger a criminal investigation. The licence holder and person-in-charge will bear personal legal responsibility.

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