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HONG KONG DRUG LICENSING

Who should conduct our annual self-inspection to ensure objectivity?

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

Q391 · Category H: Licensed operations and routine regulatory oversight (Q351–Q400)
The purpose of annual self-inspection is to conduct a critical and honest assessment of your own Quality Management System, so objectivity and independence are essential. To ensure this, the people or team conducting the self-inspection should be as independent as possible from the activities being inspected. Best practice is to: 1. Form a self-inspection team with members from different departments—for example, have production staff inspect the warehouse and warehouse staff inspect the quality control laboratory, creating cross-checks. 2. Appoint a member of management who is not directly responsible for specific operations, such as the quality assurance manager, to lead the team. 3. If the company’s size and resources permit, engage an independent external consultant or auditor to conduct the self-inspection. This can provide the most objective perspective and may bring experience of industry best practices. Regardless of who conducts it, self-inspection personnel must receive appropriate training and be familiar with GDP/GMP requirements and auditing techniques.

📘 Regulatory basis

Both the Code of Practice for Licensed Wholesale Dealers and GMP guidance require self-inspections to be conducted by designated, competent personnel who are independent of the department being inspected, to ensure that the inspection is impartial and thorough.

📗 Drew Tang's recommendations

We do not recommend that department heads inspect their own departments, as genuine objectivity is difficult to achieve. Treat self-inspection as an opportunity for internal learning and improvement, not fault-finding. Be open to issues identified by external auditors. Rengangyongsheng (Hong Kong) Limited provides professional third-party self-inspection services to help you review your systems from a fresh perspective and prepare for an official inspection.

📕 Risk notice

A superficial “friendly” self-inspection carried out by non-independent personnel will almost certainly miss many potential problems. This can give management the false impression that “everything is fine” and cause them to lower their guard. When Department of Health inspectors arrive and find numerous problems, you will have to address not only the problems themselves but also explain why your self-inspection system failed to identify them, making the situation worse.

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