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If my business involves “dangerous drugs”, what special security requirements apply to their storage?

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

Q76 · Category B: Licence types and scope of application (Q51-Q100)
Yes, storing “Dangerous Drugs”, such as morphine and fentanyl, which are strictly controlled narcotic and psychotropic medicines, requires security standards far higher than those for ordinary medicines. First, all Dangerous Drugs must be kept in a fixed safe or vault made of strong metal or other heavy-duty material. The safe must be firmly secured to the building structure (for example, bolted to a concrete floor or wall) to prevent it from being removed in its entirety. Secondly, access to the storage location must be strictly controlled, with only a very small number of authorised personnel having access to the keys or combination. In addition, in many cases the Department of Health will require a separate 24-hour CCTV system to provide comprehensive coverage of the safe area.

📘 Regulatory basis

The Dangerous Drugs Ordinance (Cap. 134) and its regulations contain extremely detailed and stringent requirements for the custody, records and disposal of dangerous drugs. When considering an application for a “Dangerous Drugs Licence”, the Department of Health conducts a very thorough on-site assessment of the applicant’s security measures.

📗 Drew Tang's recommendations

When designing a warehouse or Pharmacy layout, if you plan to handle dangerous drugs, you must allocate a corner or room that meets security requirements. We can advise on safe specifications that meet Department of Health standards and guide you in setting up procedures such as a dual-person, dual-lock system and stock movement registers to establish a robust security system.

📕 Risk notice

Any loss of dangerous drugs or inability to account for their whereabouts is an extremely serious incident and must be reported immediately to the Department of Health and the police. Even the loss of a single tablet may trigger a criminal investigation. If dangerous drugs are not properly safeguarded and are stolen or misused, the licence holder may face the most severe legal sanctions.

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