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What happens if inspectors identify some minor defects during an on-site inspection?

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

Q225 · Category E: Application Process and Approval Procedures (Q201-Q250)
If a pharmacist inspector identifies “minor defects” during an on-site inspection, this will not usually lead to your application being refused outright. Minor defects are small issues that do not directly affect medicine safety or quality and can be corrected promptly. Examples include failing to update a cleaning record for one area, a minor formatting error in a non-core SOP, or an unclear label on a shelf. In such cases, the inspector will usually point out the issues orally at the end of the inspection or in a subsequent inspection report. You must complete the corrective actions within the specified period (for example, one to two weeks) and respond to the Department of Health in writing with evidence that the actions have been completed, such as photographs or updated documents. Provided that you complete the corrective actions promptly and effectively, these minor defects will generally not affect the PPB’s positive assessment of your application.

📘 Regulatory basis

When conducting assessments, regulatory authorities generally classify deficiencies according to a risk-based approach (for example, as critical, major or minor). The way minor deficiencies are handled reflects a proportionate and flexible approach to regulation, aimed at helping applicants improve their systems rather than simply penalising them.

📗 Drew Tang's recommendations

We take a “zero-tolerance” approach to “minor deficiencies”. Through our rigorous pre-inspection process, we aim to eliminate all visible deficiencies, whether major or minor, before the official inspection. If an unexpected minor issue does arise during the inspection, we will respond immediately, guide you to complete corrective action within 24 hours and prepare the response documents, demonstrating to the inspector your efficient execution and proactive compliance approach, and turning a minor issue into a positive.

📕 Risk notice

The risk lies in disregarding “minor deficiencies”. If you ignore issues raised by inspectors, delay corrective action or take only superficial measures, those minor deficiencies may be escalated into major concerns about “non-cooperation” or “lack of commitment to compliance”. This could fundamentally change the inspector’s view of you and may result in a negative report to the PPB.

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