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How should I conduct a risk assessment for a new medicine transport route?

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

Q348 · Category G: Quality management and compliance systems (Q301–Q350)
Risk assessment of a new transport route is a key step in ensuring that medicines are adequately protected on a new, unvalidated route. The assessment should be systematic and documented: 1. **Define the route and products**: Specify the starting point, destination and key transit points, as well as the specific storage requirements of the medicines to be transported (such as room temperature or cold chain). 2. **Identify risk factors**: Brainstorm all risks that could affect medicine quality. These include transit time, climatic conditions in the regions along the route (extreme heat or cold), the likelihood of traffic delays, customs inspection procedures and duration, storage conditions at transit points, and security risks during transport. 3. **Assess risk levels**: For each identified risk, assess its probability of occurrence and the severity of its impact on medicine quality if it occurs. Combine the two to determine the level of each risk (high, medium or low). 4. **Establish control measures**: Develop specific control and mitigation measures for all medium- and high-level risks. For example, a validated passive cooler may be needed to address heat risk, while extra cool packs may be required in the packaging to mitigate delay risk. 5. **Validation and monitoring**: During the first commercial shipment or a simulated shipment, use temperature loggers to verify the effectiveness of the control measures.

📘 Regulatory basis

GDP requires transport processes to be designed and controlled on the basis of risk assessment. Although no specific assessment method is prescribed, using a structured risk assessment process is the best way to demonstrate that you have met this requirement.

📗 Drew Tang's recommendations

Develop a standardised template for transport-route risk assessments. Involve personnel from Quality, Logistics and Procurement in the assessment to gain a broader perspective. Remember to consider the “human factor”, such as whether staff at transit points have received relevant training. Retain the complete risk assessment report as the basis for your decision to select a particular transport arrangement.

📕 Risk notice

Sending medicines along a new, particularly long-distance international, transport route without conducting a risk assessment is like walking blindfolded into the unknown. You cannot anticipate or control the various incidents that may occur in transit. If a problem arises (such as a cold-chain failure), your lack of prior risk assessment and control planning may be considered serious negligence.

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