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How should an incident during medicine transport, such as an interruption to temperature control, be handled?

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

Q38 · Category A: Licensing system and regulatory fundamentals (Q1–Q50)
An incident such as a break in temperature control during transport is a serious quality event, and the deviation handling procedure must be initiated immediately. First, transport personnel should immediately report the situation to the dispatching party’s (licensed wholesaler’s) quality management department and Person-in-Charge. Second, on receipt of the goods, if the recipient finds abnormal temperature-control records or suspects that medicine quality has been compromised, they have the right and responsibility to refuse the batch or immediately segregate it in an area for quarantined goods pending examination. The dispatching party must conduct a risk assessment of the affected medicines. The assessment should consider factors such as the medicine’s stability data and the extent and duration of the temperature deviation to determine whether its quality remains acceptable. If it cannot be demonstrated that quality has not been affected, or the assessment finds the batch non-conforming, the batch must be treated as non-conforming goods and handled under the destruction procedure described above; it must never be released to the market. The entire incident response, from discovery to final disposition, must be documented in detail.

📘 Regulatory basis

The sections on transportation, deviation handling and quality risk management in the Good Distribution Practice (GDP) for Pharmaceutical Products provide clear guidance and requirements for handling such incidents.

📗 Drew Tang's recommendations

Prevention is better than cure. We recommend that clients rigorously assess and verify logistics partners' cold-chain transport capabilities when selecting them. In addition, using validated insulated containers and real-time temperature loggers can minimise unexpected risks and provide crucial data if an incident occurs.

📕 Risk notice

Concealing or ignoring quality deviations during transport and placing non-conforming medicines on the market is highly irresponsible towards public health. If discovered, this could lead not only to a large-scale recall and substantial financial loss, but also to serious legal liability for the company and the person in charge.

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