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HONG KONG DRUG LICENSING

How do I establish an effective Document Control system?

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

Q327 · Category G: Quality management and compliance systems (Q301–Q350)
A document control system is a procedure that ensures the lifecycle of all QMS documents (such as the quality manual, SOPs and forms)—from creation, review, approval, distribution and revision through to obsolescence—is controlled. An effective document control system should ensure that: 1. only authorised personnel can create and revise documents; 2. all documents are appropriately reviewed and approved before issue; 3. all documents used in the workplace are the current, approved versions; 4. obsolete documents are promptly withdrawn from points of use to prevent inadvertent use; 5. every document has a unique identifier (such as a document number, version number and effective date); and 6. historical archives of obsolete documents are retained for traceability. This system is fundamental to maintaining order and consistency in the QMS.

📘 Regulatory basis

Chapter 4, “Documentation”, of the Good Distribution Practice (GDP) for Medicinal Products sets out detailed requirements. All documents must be approved, signed and dated by authorised personnel, and their contents must be clear and unambiguous. A system must be in place to prevent obsolete documents from being used inadvertently.

📗 Drew Tang's recommendations

We recommend that clients establish a Master Document List showing the current version number and effective date of every controlled document. For paper-based document systems, different-coloured stamps (such as “Controlled Copy” and “Obsolete”) can be used for management. For electronic document systems, using the access controls and version control features of document management software is more efficient and less prone to error. Appoint a document controller to manage the system’s day-to-day operation.

📕 Risk notice

If staff are found using an obsolete, handwritten-amended SOP at the workplace, this is a typical document control failure. It indicates poor management and an inability to ensure consistency of operations. If it is not possible to establish which document version was in use at the time when investigating a quality issue, root cause analysis will be exceptionally difficult.

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