Guidance library · 26 conflicts and gaps

Where the guidance disagrees, and how to decide

The official sources don't always agree, and some questions they don't answer at all. Each case below shows both sides with their sources, and a risk-based way to decide that you can write down and defend.

The principle

When the sources differ, assess the risk to the product and the patient, decide, and record why. A documented, risk-based rationale is what an inspector looks for when the guidance leaves room for judgement.

01

Returns: 24 hours or 10 days?

A customer wants to send back a fridge line they bought from us. How long can it have been away before we can even consider putting it back into stock?

EU GDP gives "for example 10 days" as an acceptable return window from customers without a wholesale authorisation. In GB the MHRA position is tighter: its Inspectorate blog of May 2016, published after the current guidelines, says refrigerated returns from unlicensed sites are completed within 24 hours including transport, and ambient returns within five days.

EU GDP 6.3 (2013)

Returns from customers without a wholesale authorisation can be accepted within an acceptable time limit, for example 10 days. For cold chain items there must be documented evidence that the product stayed in its authorised storage conditions the whole time, and any deviation needs a risk assessment showing integrity.

Guidelines of 5 November 2013 on Good Distribution Practice of medicinal products for human use (2013/C 343/01), European Commission, 23 November 2013

MHRA blog (2016)

For non-defective refrigerated products returned from an unlicensed site, the return should be completed within 24 hours including transport, and within five days for ambient products. This is the MHRA position for GB.

Refrigerated medicinal products, part 2: Transportation, packing, temperature management, the use of third party couriers and returns, MHRA, 5 May 2016

HPRA IA-G0011 (2020)

Cold chain products may only go back to saleable stock where there is no reasonable possibility the cold chain was compromised, for example through a validated delivery-and-return process or a monitoring device attached to the product.

Guide to Control and Monitoring of Storage and Transportation Temperature Conditions for Medicinal Products and Active Substances (IA-G0011-3), HPRA, 2 October 2020

A risk-based way to decide

  1. Treat the time limit as a ceiling, not a test: the deciding question is whether you have evidence of storage throughout.
  2. Check the evidence chain: delivery, receipt, storage at the customer, repacking, collection and return to your fridge.
  3. Review any logger data or attached indicator against the product's labelled range.
  4. Ask the manufacturer or MAH about any deviation before deciding.
  5. Record the RP's decision and rationale, including which time limit your procedure uses and why.

Check with your inspector or RP: Agree it with the GDP Inspectorate in writing before your returns procedure allows anything longer than 24 hours for refrigerated stock or five days for ambient. The COVID-19 10-day allowance was temporary.

Applies to: Wholesalers (WDA), Community pharmacy, Hospitals and wards. In the library: Can a customer return a fridge item to us so we can resell it?; How quickly must a customer send back a fridge item for us to consider returning it to stock?; Can a returned fridge line go back into saleable stock in Ireland?; What temperature-control knowledge and availability does the MHRA expect from a wholesale RP?

02

Fridge probe: centre or mapped extremes?

Where should the permanent temperature probe go in our fridge or cold room: in the middle, or where mapping found the warmest and coldest spots?

A 2016 MHRA blog says to place probes centrally, between products and not in the door. EU GDP and WHO say to place permanent monitors where mapping shows the extremes, which may not be the centre.

MHRA blog (2016)

Calibrated probes should be placed centrally, preferably between products, and not in the door.

Refrigerated medicinal products, part 1: receipt and storage - some things to consider, MHRA, 26 January 2016

EU GDP 3.2.1 (2013)

Permanent monitoring devices should be placed according to the mapping results, in the areas that experience the extremes of fluctuation.

Guidelines of 5 November 2013 on Good Distribution Practice of medicinal products for human use (2013/C 343/01), European Commission, 23 November 2013

WHO Annex 9 (2011)

Monitoring sensors go where the greatest temperature variability is expected in the qualified volume, positioned so brief events such as door opening affect them as little as possible.

WHO TRS 961, Annex 9: Model guidance for the storage and transport of time- and temperature-sensitive pharmaceutical products, WHO, 2 August 2011

NHS SPS (2024)

Use at least one air sensor for early warning and one load sensor in a mock product to show the medicine's likely temperature.

Using temperature sensors in medicines storage areas, NHS SPS, 18 November 2024

A risk-based way to decide

  1. Start from your mapping data: identify the warm and cold spots under real loading.
  2. Decide whether the probe should represent the worst case, the typical product, or both, and say why.
  3. Consider an air probe for early warning plus a buffered load probe for product temperature.
  4. If a spot near the door alarms constantly, stop storing product there rather than moving the probe to hide it.
  5. Record the placement rationale and review it after any change to layout or equipment.

Check with your inspector or RP: Check with your inspector or RP if your mapping puts the extremes somewhere you cannot practically monitor.

Applies to: Wholesalers (WDA), Hospitals and wards, Community pharmacy, GP practices, Laboratories. In the library: Where should the temperature probe go in a fridge, and how should we stock it?; Do we have to temperature map a storage area before we start putting medicines in it?; How accurate do our temperature sensors need to be, and where should the monitoring probe go?; Should the fridge probe measure the air or be in a buffered bottle?; How many temperature probes do we need in our storage area?

03

Worst-case location vs nuisance alarms at the door

Our mapping found the warmest air by the cold room door. With the alarm probe there, it goes off every time someone picks. Are we breaking the rules if we put it somewhere else?

WHO says monitoring and alarm sensors go where temperature varies most, yet positioned to be minimally affected by brief events such as door opening. WHO Supplement 6 says monitors should not sit where door openings generate an abnormally high number of alarms, and the HPRA puts probes in a load simulator so door openings during picking do not trigger alarms. EU GDP and the MHRA mapping blog say only "the extremes of fluctuations" and "the widest temperature fluctuations", which some sites read as the door threshold. That reading produces alarms nobody listens to.

EU GDP 3.2.1 (2013)

"Temperature monitoring equipment should be located according to the results of the mapping exercise, ensuring that monitoring devices are positioned in the areas that experience the extremes of fluctuations." Nothing on doors or alarms.

Guidelines of 5 November 2013 on Good Distribution Practice of medicinal products for human use (2013/C 343/01), European Commission, 23 November 2013

MHRA mapping blog (2016)

Lists "heaters, lighting, windows and doors, loading bays" as problem areas to map, then says permanent probe positions "should cover the areas that have the widest temperature fluctuations or indicate areas with any hot or cold spots". It says nothing about door openings or nuisance alarms.

Temperature mapping - an introduction, MHRA, 14 July 2016

MHRA fridge blog (2016)

"Probes should not be placed in the door." Probes should be "sited in a central location within the refrigerator and, preferably between the products". An inspector reply (5 February 2016) adds that using a liquid to simulate the load "should be supported by a risk assessment, a mapping exercise".

Refrigerated medicinal products, part 1: receipt and storage - some things to consider, MHRA, 26 January 2016

MHRA blog reply (2018)

"Temperature monitoring systems (rather than Min/Max devices) are typically set with a small delay time for temperature alarms based on risk assessment and confirmed via validation and risk packages." A reply to a reader comment, not formal guidance.

Refrigerated medicinal products, part 1: reply in the comments (3 August 2018), MHRA Inspectorate blog, 3 August 2018

WHO Annex 9, 4.5 and 4.6 (2011)

Monitoring and alarm sensors go where "greatest variability in temperature is expected to occur", "positioned so as to be minimally affected by transient events such as door opening". Control sensors, by contrast, go at the mapped hot and cold spots "even if affected by door opening" (4.5.1).

WHO TRS 961, Annex 9: Model guidance for the storage and transport of time- and temperature-sensitive pharmaceutical products, WHO, 2 August 2011

WHO Supplement 6, 2.5.2 (2015)

"Monitors should not be placed in areas where transient events such as a door opening may affect the monitoring and generate an abnormally high number of alarms." If that cannot be resolved technically or operationally, the area "should not be used to store TTSPPs and should not be monitored".

WHO TRS 961 Annex 9, Technical Supplement 6: Temperature and humidity monitoring systems for fixed storage areas (TRS 992, Annex 5), WHO, May 2015

HPRA IA-G0011, 3.1 and 10 (2020)

Recording probes go "in locations with the greatest temperature variability as determined by temperature mapping studies" (3.1). And: "Probes should be situated within an appropriate load simulator so that transient rises in temperature (e.g. when the doors are opened during picking) do not trigger alarms" (10).

Guide to Control and Monitoring of Storage and Transportation Temperature Conditions for Medicinal Products and Active Substances (IA-G0011-3), HPRA, 2 October 2020

NHS SPS (2022)

A delay may be set "to allow for acceptable small excursions without an alert, e.g. the transient rise in temperature associated with a fridge door opening", but "as short a period as practically possible".

Establishing alerts for temperature monitoring systems, NHS SPS, 10 November 2022

A risk-based way to decide

  1. Separate two questions: where does stock get warmest, and where does the air only spike for a minute when the door opens?
  2. Map with door events logged, as WHO Supplement 8 asks when a study includes door openings, so you can see how long each spike lasts and whether stock follows it.
  3. Decide what each probe is for: an alarm on product risk, an early warning, or watching the door zone.
  4. Buffer alarm probes and check their response against the mapping data before setting any delay.
  5. If a door zone alarms constantly, fix the cause (door discipline, strip curtains, a faster door) or stop storing stock there.
  6. Record the reason for each position and each delay.

Check with your inspector or RP: Ask your inspector if your mapped worst case is at a door you can neither buffer against nor keep stock away from, or if you want a delay longer than your door-recovery data support.

Applies to: Wholesalers (WDA), Hospitals and wards, Manufacturers, Laboratories, Community pharmacy. In the library: Should the alarm probe go right by the door, since that is where the temperature swings most?; How accurate do our temperature sensors need to be, and where should the monitoring probe go?; What does the HPRA expect from temperature alarms?; Where should the temperature probe go in a fridge, and how should we stock it?; Do we have to temperature map a storage area before we start putting medicines in it?; What temperature should a fridge alarm be set to, and should it have a delay?; Should the fridge probe measure the air or be in a buffered bottle?

04

Fridge readings: once or twice a day?

How often do we really need to read and record the fridge temperature, and does it depend on which part of the UK we are in?

The Green Book minimum in England is once each working day. Public Health Scotland recommends twice daily, Northern Ireland says at least daily and preferably twice, and WHO model guidance says twice a day, seven days a week.

Green Book, England (2013)

Fridge temperatures must be monitored and recorded at least once each working day, at the same time each day, with each entry signed.

Storage, distribution and disposal of vaccines: the Green Book, chapter 3, UKHSA, 19 March 2013

Public Health Scotland (2023)

Recommends recording current, maximum and minimum temperatures twice daily, at the start and end of the working session, while acknowledging the Green Book accepts once daily.

Guidance on vaccine storage and handling (Version 1), Public Health Scotland, March 2023

PHA Northern Ireland (2024)

Temperatures should be checked and documented at least daily and preferably twice daily, with a data logger as back-up.

Guidance on vaccine handling and storage in GP practices, Public Health Agency (NI), 30 September 2024

WHO Annex 9 (2011)

Temperature records should be checked manually at least twice a day, morning and evening, seven days a week including public holidays.

WHO TRS 961, Annex 9: Model guidance for the storage and transport of time- and temperature-sensitive pharmaceutical products, WHO, 2 August 2011

A risk-based way to decide

  1. Identify which guidance applies to your setting and nation, and treat it as the floor.
  2. Assess how fast your fridge would drift out of range if it failed, using holdover or logger data.
  3. Weigh the value of the stock and how hard it is to replace.
  4. Consider whether continuous monitoring with alerts closes the gap between readings.
  5. Write the chosen frequency and rationale into your SOP.

Check with your inspector or RP: Ask your local screening and immunisation team, ICB or inspector if you operate across nations and want one frequency for every site.

Applies to: GP practices, Community pharmacy, Hospitals and wards, Care homes. In the library: How often do I need to read and record the vaccine fridge min/max temperature in England?; Is the vaccine fridge recording requirement different in Scotland?; In Northern Ireland, how often should GP practices check vaccine fridges and how long should records be kept?; How often should temperatures be checked and how often should a logger record?; How often does CQC expect GP practices to read and record vaccine fridge temperatures?

05

UKHSA's 20-minute allowance and the max/min thermometer

Our max/min thermometer shows the fridge hit 10 °C. How can we tell whether it was under 20 minutes, which is the point where guidance says no further action?

UKHSA and SPS say a one-off rise above 8 °C lasting under 20 minutes is unlikely to matter. The Green Book minimum is a max/min thermometer, which records how far the temperature went but not for how long. The allowance is NHS clinical guidance and does not apply to WDA or MIA holders: under GDP and GMP every excursion is a deviation.

UKHSA incident guidance (2022)

One-off rises above +8 °C lasting less than 20 minutes, for example during restocking, are unlikely to have breached the cold chain and need no further action beyond recording the cause.

Vaccine incident guidance: responding to errors in vaccine storage, handling and administration, UKHSA, 7 July 2022

Green Book (2013)

The minimum is a max/min thermometer that monitors continuously. Data loggers and alarmed thermometers are available but not required.

Storage, distribution and disposal of vaccines: the Green Book, chapter 3, UKHSA, 19 March 2013

NHS SPS (2024)

With only a min/max recorder, assume the excursion started just after the last reset unless you have information otherwise. Min/max recorders cannot show timing or duration.

Managing temperature excursions, NHS SPS, 9 July 2024

A risk-based way to decide

  1. Establish how you know the duration: a logger trace, an alarm log or a witnessed event.
  2. Without duration evidence, apply the worst case from the last reset, as SPS describes.
  3. Check the stock was in original packaging and that storage before the event was good.
  4. Look for repeats: the 20-minute allowance covers one-off events only.
  5. Record the cause, the evidence of duration and who decided.

Check with your inspector or RP: Contact your screening and immunisation team or the manufacturer whenever you cannot evidence that an excursion was a one-off under 20 minutes.

Applies to: GP practices, Community pharmacy, Hospitals and wards, Care homes. In the library: The fridge went to 10°C briefly while we restocked it. Do we need to do anything?; Do we need a data logger, or is a max/min thermometer enough?; We only have a min/max thermometer. How do we work out how long the fridge was out of range?; The fridge went above 8 °C for about 15 minutes while we restocked it. Is that a problem?; Is a min/max thermometer enough, or do we need a data logger or a remote monitoring system?

06

Temperature records: how long to keep them?

How long do we have to keep fridge and room temperature records, and does five years cover us?

Five years is the most common figure, but sources give different periods: at least five years under EU GDP, at least one year plus the stock's storage history under the Green Book, one year after shelf life or at least three years under WHO, ten years after expiry, clinical use or disposal for HTA human-application licensees, and RCPath guidance of 15 years for blood bank fridge charts and 5 years for most pathology fridges and freezers. These are differences between regimes more than contradictions: see [how long to keep records](/guidance/records-and-data-integrity#retention).

EU GDP chapter 4.2 (2013)

Documents should be kept for the period in national legislation but at least five years, and backups of computerised data for at least five years.

Guidelines of 5 November 2013 on Good Distribution Practice of medicinal products for human use (2013/C 343/01), European Commission, 23 November 2013

Green Book (2013)

Records should be kept for at least one year and cover the full storage history of anything in the fridge. Five years will generally cover that history.

Storage, distribution and disposal of vaccines: the Green Book, chapter 3, UKHSA, 19 March 2013

NHS SPS (2026)

At least five years for medicine storage temperature records, and eleven years for vaccine refrigerator maintenance logs.

Stock management, waste and recall records in pharmacy, NHS SPS, 29 September 2026

WHO Annex 9 (2011)

One clause says at least one year after the end of the product's shelf life; another says not less than three years. National law takes precedence.

WHO TRS 961, Annex 9: Model guidance for the storage and transport of time- and temperature-sensitive pharmaceutical products, WHO, 2 August 2011

HTA human application guide (2021)

For HTA human-application licensees, records critical to quality and safety, including raw data such as temperature monitoring records, are kept for at least ten years after expiry, clinical use or disposal, in their original format (paragraph 76).

HTA Guide to Quality and Safety Assurance for Human Tissues and Cells for Patient Treatment, HTA, January 2021

RCPath and IBMS (6th edition, 2025)

Blood bank refrigerator and freezer temperature charts: 15 years (section 6.1.5). Most other pathology fridge and freezer temperature records: 5 years. This is professional guidance, not law.

The retention and storage of pathological records and specimens (6th edition), RCPath and IBMS, October 2025

A risk-based way to decide

  1. List every rule that applies to you: licence, sector guidance, contracts and manufacturer requirements.
  2. Work out the longest shelf life of stock you hold and make sure records cover its whole storage history.
  3. Plan for monitoring system changes so historical electronic data stays readable for the full period.
  4. Separate backup from archive: backups do not replace long-term retention.
  5. Set one retention period in your SOP and record why it meets every applicable rule.

Check with your inspector or RP: Check with your inspector or regulator if you hold products for several regulated areas and the periods differ.

Applies to: All settings. In the library: How long do we have to keep temperature records?; How long must vaccine fridge temperature records be kept?; How long do we need to keep fridge and room temperature records?; How long should we keep temperature records?; How long must a tissue establishment keep temperature monitoring records for tissues and cells used in patient treatment?; Our logger software backs up to a server every night. Does that count as archiving our temperature records?

07

Small premises: how small is "a few square metres"?

Our medicines store is a small room. Can we use a risk assessment instead of a mapping study, and how small does the room have to be?

EU GDP lets small room-temperature premises of "a few square metres" use a risk assessment instead of formal mapping. No source defines the size, and the MHRA mapping blog aimed at small areas still describes mapping with probes.

EU GDP 3.2.1 (2013)

For small premises of a few square metres at room temperature, an assessment of potential risks such as heaters should be done and monitors placed accordingly.

Guidelines of 5 November 2013 on Good Distribution Practice of medicinal products for human use (2013/C 343/01), European Commission, 23 November 2013

HPRA IA-G0046 (2025)

Initial mapping must be performed for areas greater than a few square metres; smaller room-temperature areas can use a risk assessment instead.

Guide to Good Distribution Practice of Medicinal Products for Human Use (IA-G0046-8), HPRA, 8 April 2025

MHRA mapping blog (2016)

Aimed at small wholesalers, it describes mapping with enough calibrated probes for the area and risk-assessing the data to place permanent probes.

Temperature mapping - an introduction, MHRA, 14 July 2016

What is undefined

"A few square metres" has no numeric definition in any source reviewed, and the concession applies only to room-temperature areas, not fridges or cold rooms.

Guidelines of 5 November 2013 on Good Distribution Practice of medicinal products for human use (2013/C 343/01), European Commission, 23 November 2013

A risk-based way to decide

  1. Measure the room and record its size, layout and heat sources such as heaters, windows and lights.
  2. Assess what could push temperature out of range, including summer peaks and heating switched off at night.
  3. Gather some real data, for example a short logger study, even if you do not run a full mapping exercise.
  4. Place the monitor at the worst-case spot your assessment identifies.
  5. Record the rationale and review it after any change to the room.

Check with your inspector or RP: Ask your inspector before relying on the exemption if the room is borderline in size or holds high-value stock.

Applies to: Wholesalers (WDA), Community pharmacy. In the library: Our store is just a small room at room temperature - do we need a full mapping study?; Our Irish storage area is tiny. Do we need a full temperature mapping study?; How should a small wholesaler actually carry out a temperature mapping exercise?; Do we need to temperature map our medicines room and fridges, and how is it done?

08

The COVID transport flexibilities: still live?

The MHRA's COVID page allowing uncontrolled transport below 20 °C is still on GOV.UK. Can we still use it?

The April 2020 MHRA page on exceptional GDP flexibilities has not been formally withdrawn, but it was framed as temporary. Normal MHRA policy on transit storage and transport control sits elsewhere.

MHRA COVID flexibilities (2020)

Temporarily allowed non-temperature-controlled transport when ambient temperature was below 20 °C, storage equipment with limited qualification completed later, and transit hub storage up to 96 hours without a WDA(H), each with a risk assessment.

Exceptional good distribution practice (GDP) flexibilities for medicines during the coronavirus (COVID-19) outbreak, MHRA, 1 April 2020

MHRA blog (2016)

Normal policy: ambient products held in transit for under 36 hours need not be on a licence; refrigerated products need a licensed site unless they stay overnight in continuously refrigerated vehicles.

Refrigerated medicinal products, part 1: receipt and storage - some things to consider, MHRA, 26 January 2016

MHRA GDP Symposium (2023)

Delegates were given an update on the COVID flexibilities, which indicates they were not treated as a permanent change.

MHRA Good Distribution Practice Symposium 2023, MHRA, 2 May 2023

A risk-based way to decide

  1. Assume the flexibilities do not apply unless the GDP Inspectorate confirms otherwise in writing.
  2. Assess each route for temperature risk using real seasonal data, not assumptions about UK weather.
  3. Identify any "do not refrigerate" lines that could get too cold.
  4. Check transit and hub storage times against the normal 36-hour policy.
  5. Record the decision and the evidence behind it.

Check with your inspector or RP: Confirm with the MHRA GDP Inspectorate before relying on any part of the 2020 page.

Applies to: Wholesalers (WDA), Transport. In the library: Is it still allowed to use non-temperature-controlled transport when it's below 20°C outside?; Does a depot or freight site that holds our medicines overnight need to be on a wholesale licence?; Are ordinary vans or curtain-sided trailers acceptable for ambient medicines?; What transport temperature failings did MHRA inspectors cite in their deficiency data?

09

Mean kinetic temperature: allowed or discouraged?

Can we use mean kinetic temperature to show that a warm spell did not harm our ambient stock?

The MHRA Inspectorate discourages MKT in wholesale "without robust supporting information and methodology". The HPRA allows it under set conditions. NHS SPS describes MKT as a way to average out short peaks in clinical areas.

MHRA blog (2016)

MKT is appropriate only where the MA holder gives an acceptable MKT value for the product and the record is complete from the manufacturer. Use "in the wholesale environment without robust supporting information and methodology is therefore discouraged".

Refrigerated medicinal products, part 2: Transportation, packing, temperature management, the use of third party couriers and returns, MHRA, 5 May 2016

HPRA IA-G0011 (2020)

MKT applies only to controlled room temperature products, never to refrigerated ones, cannot compensate for poor control, and temperatures should not exceed 30 °C if it is used. Consult the MA holder.

Guide to Control and Monitoring of Storage and Transportation Temperature Conditions for Medicinal Products and Active Substances (IA-G0011-3), HPRA, 2 October 2020

NHS SPS (2024)

MKT can average out peaks, for example a short afternoon spike, if the daily MKT stays within the labelled range. It needs continuous logger data and should not be used routinely to compensate for poor storage.

Managing temperature excursions, NHS SPS, 9 July 2024

A risk-based way to decide

  1. Confirm you have continuous logger data; MKT cannot be calculated from min/max readings.
  2. Check the product is labelled for controlled room temperature, not refrigerated.
  3. Ask the MA holder whether MKT is applicable to the product.
  4. Note the peak temperature as well as the MKT.
  5. Treat repeated spikes as a storage problem to fix, not something to calculate away.
  6. Document the method in a written procedure.

Check with your inspector or RP: Ask your GDP inspector before using MKT in a wholesale excursion investigation.

Applies to: Wholesalers (WDA), Hospitals and wards, Community pharmacy, GP practices. In the library: Can we use mean kinetic temperature (MKT) to show an excursion didn't matter?; Can we use mean kinetic temperature (MKT) to justify an ambient excursion in Ireland?; Our data logger shows the dispensary hits 27 °C every afternoon but cools overnight. Can we use mean kinetic temperature instead of treating each spike as an excursion?; Our clinic room recorded over 30 °C. Do we have to destroy the stock?

10

Any duration, 5 minutes or 20 minutes?

The fridge went over 8 °C for a few minutes during restocking. Is that a formal deviation we have to investigate, or just something we note?

The HPRA defines an excursion as a departure from labelled conditions for any duration. A 2018 reply on the MHRA Inspectorate blog says very short excursions are typically noted but not raised as individual deviations. SPS and UKHSA use 20 minutes as the point below which a one-off rise is unlikely to matter, in clinical settings only: it does not apply to WDA or MIA holders, for whom every excursion is a deviation under GDP and GMP.

HPRA IA-G0011 (2020)

An excursion is a deviation from labelled storage conditions for any duration of time, to be notified to the RP and investigated.

Guide to Control and Monitoring of Storage and Transportation Temperature Conditions for Medicinal Products and Active Substances (IA-G0011-3), HPRA, 2 October 2020

MHRA blog reply (2018)

A reply on the MHRA Inspectorate blog, to a question about door openings on a clinical trial (IMP) fridge, says it is "not typical that very short excursions (e.g. 5 minutes or under) are reported in individual formal deviations, but these should still be noted". This is a reply to a reader comment, not formal guidance.

Refrigerated medicinal products, part 1: reply in the comments (3 August 2018), MHRA Inspectorate blog, 3 August 2018

NHS SPS (2024)

A rise above 8 °C lasting under 20 minutes, with medicines in original packaging, is unlikely to have warmed them above 8 °C, but every excursion should still be recorded locally.

Managing temperature excursions, NHS SPS, 9 July 2024

UKHSA incident guidance (2022)

One-off rises above +8 °C under 20 minutes need no further action beyond noting the cause and resetting the thermometer.

Vaccine incident guidance: responding to errors in vaccine storage, handling and administration, UKHSA, 7 July 2022

A risk-based way to decide

  1. Record every excursion, however short, so patterns can be seen.
  2. Classify by duration, peak and cause using thresholds written in your own SOP.
  3. Check whether the product was buffered by its packaging and a full fridge.
  4. Escalate repeats or unexplained excursions regardless of duration.
  5. Make sure the threshold you use matches your regulator and setting.

Check with your inspector or RP: Check with your inspector or RP if your SOP uses a minimum duration and you hold an HPRA or MHRA wholesale authorisation.

Applies to: Wholesalers (WDA), Hospitals and wards, GP practices, Community pharmacy. In the library: What does the HPRA say we must do after a temperature excursion?; The fridge went above 8 °C for about 15 minutes while we restocked it. Is that a problem?; The fridge went to 10°C briefly while we restocked it. Do we need to do anything?; What do we need to write down after a temperature excursion?; At what point should ward staff quarantine medicines after an out-of-range reading?

11

Readings between 0 and 2 °C: minor or serious?

Our fridge minimum dropped to 1 °C overnight. Is a low reading less of a worry than a high one?

UKHSA says vaccines with a recorded minimum between 0 and +2 °C are unlikely to have been affected. SPS says any excursion below 2 °C is always potentially significant, and the SW ICARS toolkit treats any time below +2 °C as a reportable breach.

UKHSA incident guidance (2022)

Vaccines whose recorded minimum was between 0 °C and +2 °C are unlikely to have been affected and can usually be used to expiry where the fridge temperature has been verified.

Vaccine incident guidance: responding to errors in vaccine storage, handling and administration, UKHSA, 7 July 2022

NHS SPS (2024)

Excursions below 2 °C are always potentially significant and should be fully explored, because freezing can irreversibly damage biologicals and vaccines.

Managing temperature excursions, NHS SPS, 9 July 2024

NHS England SW ICARS (2026)

Any excursion below +2 °C, for any length of time, is a breach to report so stability can be assessed.

Cold Chain Management and Best Practice Toolkit (South West ICARS), NHS England, March 2026

A risk-based way to decide

  1. Check whether any product actually froze, especially items touching the back wall or cooling plate.
  2. Verify the thermometer is accurate before relying on the reading.
  3. Check each product's freeze sensitivity with the manufacturer or SPS tool.
  4. Find out why the fridge ran cold: thermostat fault, overloading or probe position.
  5. Follow the reporting route for your setting and record the decision.

Check with your inspector or RP: Contact your screening and immunisation team or the manufacturer for any low reading involving vaccines or biologicals.

Applies to: GP practices, Community pharmacy, Hospitals and wards, Care homes. In the library: The minimum reading dropped to 1°C. Are the vaccines still usable?; Our fridge minimum reading was 0.5 °C. Is a low reading less serious than a high one?; What counts as a vaccine cold chain breach that has to be reported?; What happens if vaccines were exposed to temperatures below 0°C?; Is 8.3°C or 1.6°C a cold chain breach?

12

Domestic fridges: never, not recommended, or if tested?

Can we use a household fridge for medicines if it holds 2 to 8 °C?

UK vaccine guidance says domestic fridges must not be used. SPS and CQC say they are not recommended, with a narrow care home exception. WHO accepts household-style units only if independently tested against a pharmaceutical refrigerator standard.

Green Book (2013)

Vaccines and diluents must be stored in specialised pharmaceutical fridges; ordinary domestic fridges must not be used.

Storage, distribution and disposal of vaccines: the Green Book, chapter 3, UKHSA, 19 March 2013

NHS SPS (2025)

Domestic fridges and freezers are not recommended for storing medicines in healthcare settings; use a specialist medicines fridge.

Using a refrigerator or freezer to store medicines, NHS SPS, 25 July 2025

CQC care homes (2025)

Domestic fridges are not recommended. In exceptional circumstances, small services that rarely hold fridge items could use a locked container in the food fridge with full monitoring and a risk assessment.

Storing medicines in fridges in care homes, CQC, 4 November 2025

WHO Annex 9 (2011)

Refrigerators should be purpose-designed; household-style units are acceptable only if independently tested against a recognised pharmaceutical refrigerator standard.

WHO TRS 961, Annex 9: Model guidance for the storage and transport of time- and temperature-sensitive pharmaceutical products, WHO, 2 August 2011

A risk-based way to decide

  1. Identify what is stored: vaccines and high-value biologicals call for a pharmaceutical fridge.
  2. Check the unit's design: fan circulation, no ice box, even temperature.
  3. Map or log it to see whether any part drops below 2 °C or rises above 8 °C.
  4. Assess how it recovers after door openings and how long it holds in a power cut.
  5. Record the decision, and plan a replacement if the evidence does not support the unit.

Check with your inspector or RP: Check with your ICB, CQC inspector or SIT before using anything other than a pharmaceutical fridge for vaccines.

Applies to: GP practices, Community pharmacy, Care homes, Hospitals and wards, Dental. In the library: Can we store vaccines in a domestic fridge?; Can we use a domestic fridge to store medicines in a care home or GP practice?; Can a care home use a domestic fridge, or a box in the food fridge, for residents' refrigerated medicines?; Do we need to temperature map a pharmaceutical fridge, and can a household fridge be used?; Can a wholesaler use a domestic fridge, or one just labelled 'medical', for fridge lines?

13

Re-mapping: every year, every three years, or on triggers?

How often do we have to repeat temperature mapping once the first study is done?

EU GDP, the MHRA, the HPRA and SPS set no fixed re-mapping interval and leave it to risk assessment and change triggers. WHO gives "every three years" as an example.

EU GDP 3.2.1 (2013)

Mapping should be repeated according to a risk assessment or whenever significant modifications are made to the facility or temperature control equipment.

Guidelines of 5 November 2013 on Good Distribution Practice of medicinal products for human use (2013/C 343/01), European Commission, 23 November 2013

MHRA mapping blog (2016)

The risk assessment from mapping should define and justify how often future mapping is done, and be reviewed regularly.

Temperature mapping - an introduction, MHRA, 14 July 2016

HPRA IA-G0011 (2020)

Re-mapping is trigger-based: repairs, layout changes, set-point changes, condenser changes, moving a fridge or heating changes.

Guide to Control and Monitoring of Storage and Transportation Temperature Conditions for Medicinal Products and Active Substances (IA-G0011-3), HPRA, 2 October 2020

WHO Supplement 8 (2015)

Periodic re-mapping may be needed, for example every three years; where continuous fixed monitors exist, a periodic review of performance may be more appropriate.

WHO TRS 961 Annex 9, Technical Supplement 8: Temperature mapping of storage areas (TRS 992, Annex 5), WHO, May 2015

A risk-based way to decide

  1. Write a list of change triggers that require re-mapping.
  2. Review monitoring data periodically for drift or unexplained variation.
  3. Set an interval based on how critical and costly the stock is, and how stable the space has been.
  4. Re-map after any change to layout, equipment, set point or heating.
  5. Record the rationale and revisit it at self-inspection.

Check with your inspector or RP: Ask your inspector if your chosen interval is longer than a common industry convention and you want to confirm your rationale is acceptable.

Applies to: Wholesalers (WDA), Hospitals and wards, Manufacturers, Laboratories. In the library: How often should we re-map, and what is the RP's role?; Do we have to temperature map a storage area before we start putting medicines in it?; When does the HPRA expect a walk-in cold room or large fridge to be re-mapped?; How often should we repeat temperature mapping of a storage area?; How often do we have to requalify a temperature-controlled room or chamber at a manufacturing site?; Do we need to temperature map our medicines room and fridges, and how is it done?

14

Do cold rooms need summer and winter mapping?

We map our ambient warehouse in summer and winter. Do we need to do the same for the cold room inside it?

The European Commission GDP Q&A says mapping should be done in different seasons, with no exception for cold rooms. WHO Supplement 8 says two-season mapping is typically not necessary for cold rooms and freezer rooms.

European Commission GDP Q&A (2014)

Initial mapping should be done in different seasons, when the highest and lowest temperatures are reached.

Good Distribution Practice for Medicinal Products for Human Use: Questions and Answers, Version 1.0, European Commission, 28 March 2014

WHO Supplement 8 (2015)

Two studies may be needed where areas are affected by seasonal variation, but this is typically not necessary for cold rooms and freezer rooms.

WHO TRS 961 Annex 9, Technical Supplement 8: Temperature mapping of storage areas (TRS 992, Annex 5), WHO, May 2015

HPRA IA-G0011 (2020)

Warehouses should be mapped empty and full, in summer and winter. Cold rooms should be mapped on installation empty and full, with an ambient probe outside the unit.

Guide to Control and Monitoring of Storage and Transportation Temperature Conditions for Medicinal Products and Active Substances (IA-G0011-3), HPRA, 2 October 2020

A risk-based way to decide

  1. Check where the cold room sits: inside a controlled building, or against an external wall or roof.
  2. Look at how much the surrounding ambient temperature swings between seasons.
  3. Review whether the refrigeration plant has headroom on the hottest days.
  4. Use an external ambient probe during mapping to show the conditions tested.
  5. Record why you did or did not map in both seasons.

Check with your inspector or RP: Check with your inspector if your cold room is in an uncontrolled or external building and you plan a single-season study.

Applies to: Wholesalers (WDA), Hospitals and wards, Manufacturers. In the library: What does 'initial temperature mapping' actually involve, and does it have to cover summer and winter?; How long should a mapping study run, and is seasonal mapping needed for a cold room?; In Ireland, does the HPRA expect an ambient warehouse to be mapped in both summer and winter, and empty and full?; When does the HPRA expect a walk-in cold room or large fridge to be re-mapped?

15

Calibration: how often and at how many points?

How often do our probes need calibrating, and is a single-point check enough?

EU GDP makes storage calibration risk-based but sets at least yearly for transport. UK vaccine and SPS guidance say annually. SPS and the HPRA describe multi-point calibration, while WHO describes a single ice-point check only as a fallback.

EU GDP 3.3 and 9.2 (2013)

Storage monitoring equipment is calibrated at intervals based on risk and reliability; transport monitoring equipment at least once a year.

Guidelines of 5 November 2013 on Good Distribution Practice of medicinal products for human use (2013/C 343/01), European Commission, 23 November 2013

NHS SPS (2024)

Sensors should be calibrated annually to ±0.5 °C by an accredited service. 2-point or 3-point calibration is acceptable, with 3-point, in SPS's reading, required in departments under an MHRA licence (the MHRA and EU GDP texts are risk-based and set no number of points).

Using temperature sensors in medicines storage areas, NHS SPS, 18 November 2024

HPRA IA-G0011 (2020)

Probes should be calibrated at least annually at a minimum of three points across the range of use, covering the whole monitoring system.

Guide to Control and Monitoring of Storage and Transportation Temperature Conditions for Medicinal Products and Active Substances (IA-G0011-3), HPRA, 2 October 2020

WHO Supplement 10 (2015)

An ice-point check tests accuracy at 0 °C only and is described as a fallback where accredited multi-point calibration is not possible.

WHO TRS 961 Annex 9, Technical Supplement 10: Checking the accuracy of temperature control and monitoring devices (TRS 992, Annex 5), WHO, May 2015

A risk-based way to decide

  1. Define the range each probe is used over and calibrate across that range, not at one point.
  2. Set the interval from drift history and how critical the stock is; annual is the common minimum.
  3. Calibrate the whole system: probe, receiver and display.
  4. Review each certificate against acceptance criteria and act on any failure, including past readings.
  5. Keep monitoring running during calibration with spare calibrated probes.

Check with your inspector or RP: Ask your inspector if you plan to extend calibration beyond a year or rely on in-house checks.

Applies to: All settings. In the library: How often do we need to calibrate the thermometers and loggers in our warehouse?; How often must temperature loggers used in vans and shipping boxes be calibrated?; How often do fridge thermometers and probes need calibrating, and to what standard?; What calibration does the HPRA expect for temperature monitoring probes?; We can't get our thermometers to an accredited calibration lab. Is an ice-water check acceptable?; How often do vaccine fridge thermometers need calibrating?

16

Data logger fitted: do we still write it down every day?

We have a continuous logger with alerts on the vaccine fridge. Do we still need the daily paper reading?

CQC says GP practices must still read, record and reset each working day even with a logger. SPS points to continuous monitoring with remote alerts as the answer to closed periods. The MHRA treats stored electronic data as the raw data, with a paper chart as a secondary record.

CQC GP mythbuster 17 (2024)

Even with a data logger, practices must still read and record minimum, maximum and current temperatures and reset each working day. It does not address whether an alarmed remote system could replace this.

GP mythbuster 17: Vaccine storage and fridges in GP practices, CQC, 20 August 2024

NHS SPS (2022)

Monitor continuously, check, record and reset min/max at least daily, with an independent daily check. Networked alerts are "the most robust means of alerting users" out of hours.

Establishing alerts for temperature monitoring systems, NHS SPS, 10 November 2022

VMD (2026)

Data loggers do not replace daily checks that the device is working and no alert has fired.

VMD blog: Heatwaves, temperature control and veterinary medicines - how to store medicines safely, VMD, 13 August 2026

MHRA data integrity guidance (2018)

Where a device stores data electronically, that stored data is the raw data, and a paper chart is a secondary record.

'GXP' Data Integrity Guidance and Definitions (Revision 1, March 2018), MHRA, 9 March 2018

A risk-based way to decide

  1. Identify which record is the original and how the paper and electronic records link.
  2. Keep the daily check unless your regulator or commissioner agrees otherwise in writing.
  3. Use the daily check to confirm the logger is working and alerts are reaching someone.
  4. Review logger data on a set schedule, not only after an incident.
  5. Record the arrangement in your cold chain policy.

Check with your inspector or RP: Check with your ICB or CQC inspector before dropping paper records in favour of an alarmed remote system.

Applies to: GP practices, Community pharmacy, Veterinary, Care homes. In the library: If we have a data logger in the vaccine fridge, do we still need to do daily manual readings?; How often do fridge temperatures have to be checked and recorded?; What thermometer or data logger set-up does the VMD expect in a vet practice, and how often should it be checked?; We read the fridge display and write the temperature on a paper chart. Is that acceptable from a data integrity point of view?; We use a mix of paper logs and an electronic logger. Is a hybrid system acceptable?

17

Room temperature: 25 °C ceiling or a tolerance in heatwaves?

Our treatment room went over 25 °C during a heatwave. Do we have to quarantine everything labelled "store below 25 °C"?

UKHSA says most medicines should be kept below 25 °C. SPS says a single excursion of less than 5 °C over the limit for under seven days is unlikely to matter. The 2015 NHS QA document set a stricter quarantine trigger and noted its Q10 method is not accepted under GDP.

UKHSA hot weather guidance (2024)

Most medicines should be kept below 25 °C, somewhere cool and dry, away from direct sunlight.

Supporting vulnerable people before and during hot weather: healthcare professionals, UKHSA, 19 December 2024

NHS SPS ambient (2026)

Ideally all storage areas would be controlled between 15 and 25 °C; storing outside stated conditions takes a medicine outside its licence and needs governance review.

Storing medicines at ambient temperatures, NHS SPS, 24 June 2026

NHS SPS excursions (2024)

A single, isolated excursion of less than 5 °C above the labelled maximum, lasting under 7 days, is unlikely to harm medicines. It does not cover rooms that run hot every summer, or WDA holders.

Managing temperature excursions, NHS SPS, 9 July 2024

NHS Pharmaceutical QA Committee (2015)

Example trigger: quarantine ambient stock if the limit was exceeded by more than 5 °C or for more than a day. Its Q10 expiry-reduction method is for clinical areas and is not accepted by the MHRA under GDP.

Risk Management of Medicines Stored in Clinical Areas: Temperature Control (Edition 1), NHS Pharmaceutical QA Committee, June 2015

A risk-based way to decide

  1. Check each product's label: some allow 30 °C, some have no stated condition.
  2. Establish the peak and the duration from logger data, not min/max alone.
  3. Decide whether this was a one-off or a pattern; repeat summers need cooling or a documented plan.
  4. Note your regulatory status: wholesale licence holders must meet their requirements in full.
  5. Record the assessment, any shortened expiry and who approved it.

Check with your inspector or RP: Contact your pharmacist, RP or the manufacturer before releasing stock after a prolonged or repeated excursion.

Applies to: Hospitals and wards, GP practices, Care homes, Community pharmacy. In the library: Is there official hot-weather guidance saying medicines must be kept below 25 °C?; What room temperature should medicines storage areas be kept at, and what can we do in hot weather without air conditioning?; Our treatment room reached 28 °C for three days during hot weather. Are the 'store below 25 °C' medicines still usable?; After a heatwave, how much should we shorten the expiry of 'store below 25 °C' medicines kept on the ward?; At what point should ward staff quarantine medicines after an out-of-range reading?; What temperature ranges do VMD inspectors expect for refrigerated and ambient veterinary medicines?

18

RP experience: one year or six months?

We operate in GB and Ireland. How much experience does our Responsible Person need?

MHRA Guidance Note 6 says at least one year's practical experience of the licensed activities. The HPRA GDP guide treats six months' full-time direct GDP experience as the minimum.

MHRA Guidance Note 6 (2023)

The RP must have at least one year's practical experience of the licensed activities, with knowledge of storage conditions and temperature control.

MHRA Guidance Note 6: Notes for applicants and holders of a Wholesale Dealer's Licence (WDA(H)) or Broker Registration, MHRA, 2023

HPRA IA-G0046 (2025)

Evidence of six months' full-time direct GDP experience is the minimum, with suitability assessed case by case.

Guide to Good Distribution Practice of Medicinal Products for Human Use (IA-G0046-8), HPRA, 8 April 2025

A risk-based way to decide

  1. Check the candidate against each authority's own text.
  2. Assess knowledge of the specific products and their storage needs, not just time served.
  3. For a contract RP, set time on site by documented risk assessment and record it.
  4. Make sure the RP can show oversight of delegated tasks such as daily checks.
  5. Record the suitability assessment.

Check with your inspector or RP: Ask each regulator at application if a candidate meets one authority's minimum but not the other's.

Applies to: Wholesalers (WDA). In the library: What temperature-control knowledge and availability does the MHRA expect from a wholesale RP?; What experience does the HPRA expect of a Responsible Person, and can the RP be contracted?

19

Who checks the fridge at the weekend?

We are closed at weekends and bank holidays. How do we know the fridge was fine, and is a Monday reading enough?

GP guidance and contracts require readings on working days, so weekends are covered only by the next max/min reading. CQC asks care homes for at least once a day. WHO expects checks seven days a week, and SPS points to continuous monitoring with remote alerts.

NHS England GP enhanced service (2024–26, now expired)

Readings must be recorded on all working days, with action when out of range.

General Practice Enhanced Service Specification COVID-19 vaccination programme: 1 September 2024 to 31 March 2026, NHS England, May 2024

CQC care homes (2025)

Record the fridge temperature at least once a day, which in a 24/7 home means every day.

Storing medicines in fridges in care homes, CQC, 4 November 2025

WHO Annex 9 (2011)

Check twice a day, seven days a week, including public holidays.

WHO TRS 961, Annex 9: Model guidance for the storage and transport of time- and temperature-sensitive pharmaceutical products, WHO, 2 August 2011

NHS SPS (2022)

Audible alarms can be missed out of hours; networked alerts by SMS, email or phone reach users when no staff are present.

Establishing alerts for temperature monitoring systems, NHS SPS, 10 November 2022

A risk-based way to decide

  1. Work out the longest unattended period, for example a bank holiday weekend.
  2. Estimate how much stock would be at risk if the fridge failed at the start of it.
  3. Decide how you would detect a failure: logger download, remote alert or a call-out.
  4. Name who responds to an alert and test the route.
  5. Add a closing check before weekends and holidays to your routine.

Check with your inspector or RP: Talk to your commissioner or inspector if your stock value or patient impact makes a Monday-only check hard to justify.

Applies to: GP practices, Community pharmacy, Care homes, Hospitals and wards. In the library: Is there a contractual requirement for GP practices to record vaccine fridge temperatures?; How should a care home record medicines fridge temperatures to satisfy CQC?; How often should temperatures be checked and how often should a logger record?; Who will know if the fridge fails overnight or at the weekend when nobody is in the building?; Our GP practice is closed at weekends. How do we know the vaccine fridge was fine over Saturday and Sunday?

20

Alarm testing: how often?

How often should we test that our temperature alarms actually work?

EU GDP says alarms should be regularly tested but gives no frequency. WHO says at least every six months. SPS and the HPRA give no interval, leaving it to local policy.

EU GDP 3.3 (2013)

Alarm levels should be set appropriately and alarms regularly tested; no test frequency is defined.

Guidelines of 5 November 2013 on Good Distribution Practice of medicinal products for human use (2013/C 343/01), European Commission, 23 November 2013

WHO Annex 9 (2011)

Alarm functionality should be checked at least once every six months at the set points, with records kept.

WHO TRS 961, Annex 9: Model guidance for the storage and transport of time- and temperature-sensitive pharmaceutical products, WHO, 2 August 2011

NHS SPS (2022)

Alarms should never be permanently silenceable; SPS does not say how often they should be tested.

Establishing alerts for temperature monitoring systems, NHS SPS, 10 November 2022

HPRA IA-G0011 (2020)

Alarms should be checked regularly at their set points without exposing product, with records kept; no specific frequency is given.

Guide to Control and Monitoring of Storage and Transportation Temperature Conditions for Medicinal Products and Active Substances (IA-G0011-3), HPRA, 2 October 2020

A risk-based way to decide

  1. Test at both high and low set points, not just one.
  2. Include the whole notification route: sounder, SMS, call-out and the person who answers.
  3. Set the interval from how critical the stock is and how often settings change.
  4. Test after any change to settings, contacts or equipment.
  5. Record each test and its result.

Check with your inspector or RP: Ask your inspector if you rely on remote alerts out of hours and want to confirm your test scope covers them.

Applies to: Wholesalers (WDA), Hospitals and wards, Laboratories, All settings. In the library: Do we need temperature alarms, and do they have to be tested?; How often should we test that our temperature alarms actually work?; What temperature should a fridge alarm be set to, and should it have a delay?; What does the HPRA expect from temperature alarms?; What temperatures should we set our alarms at?

21

Paper and electronic together: control it or replace it?

We keep a paper log and an electronic logger. Is that acceptable, or should we move to one system?

The MHRA accepts hybrid systems if the full data set is defined, reviewed and kept. WHO says replacing hybrids should be a priority with a documented CAPA plan.

MHRA data integrity guidance (2018)

Hybrid systems are allowed if it is clearly documented what makes up the whole data set and all of it is reviewed and kept, with more data review because changes may not be attributable.

'GXP' Data Integrity Guidance and Definitions (Revision 1, March 2018), MHRA, 9 March 2018

WHO data integrity guideline (2021)

Where hybrid systems are used, even for an interim period, risks should be assessed with documented controls, and replacing them should be a priority with a documented CAPA plan.

WHO TRS 1033, Annex 4: WHO Guideline on data integrity, WHO, 10 October 2021

A risk-based way to decide

  1. Document which record is the original for each reading.
  2. Map how paper and electronic records link and who reviews both.
  3. Assess where unattributed changes could happen, for example shared logins or transcription.
  4. Decide whether a single system is proportionate for your size and risk.
  5. Record the decision and any plan to move away from hybrid records.

Check with your inspector or RP: Ask your inspector if your process relies on transcribing electronic readings onto paper.

Applies to: All settings. In the library: We use a mix of paper logs and an electronic logger. Is a hybrid system acceptable?; We read the fridge display and write the temperature on a paper chart. Is that acceptable from a data integrity point of view?; Our temperature monitoring system stores readings electronically. Can we just print and file the weekly reports instead of keeping the electronic data?; We are a small operation. How much data integrity control does the MHRA expect for our temperature records?

22

How full can the fridge be?

Is there a maximum we can fill the medicines fridge to?

The Green Book and the MHRA give no percentage and ask for air circulation and evidence. Public Health Scotland says no more than two-thirds, and Northern Ireland no more than half.

Green Book (2013)

Leave enough space for air to circulate and keep vaccines away from side and back walls; no percentage is given.

Storage, distribution and disposal of vaccines: the Green Book, chapter 3, UKHSA, 19 March 2013

MHRA blog (2016)

If a fridge is filled to capacity, investigate the effect on temperature distribution.

Refrigerated medicinal products, part 1: receipt and storage - some things to consider, MHRA, 26 January 2016

Public Health Scotland (2023)

Fill fridges to no more than two-thirds.

Guidance on vaccine storage and handling (Version 1), Public Health Scotland, March 2023

PHA Northern Ireland (2024)

Fridges should be no more than 50% full.

Guidance on vaccine handling and storage in GP practices, Public Health Agency (NI), 30 September 2024

A risk-based way to decide

  1. Follow the fridge manufacturer's loading guidance where it exists.
  2. Map or log the fridge at your real full load.
  3. Keep stock off the walls, floor and cooling plate.
  4. Watch for freezing near the back wall when the fridge is packed.
  5. Set a fill limit in your SOP and record how you chose it.

Check with your inspector or RP: Check with your local team if you work across nations and want one fill limit for every site.

Applies to: GP practices, Community pharmacy, Wholesalers (WDA). In the library: How full can I stock the vaccine fridge, and where should vaccines go?; Is it a problem if our pharmacy fridge is packed full, or we chill gel packs in it?; Is the vaccine fridge recording requirement different in Scotland?; What extra requirements apply to GP vaccine fridges in Northern Ireland?

23

Storage in transit: 36 hours or 48 hours?

Our courier holds stock at a depot overnight. When does that depot need a wholesale authorisation?

MHRA policy uses 36 hours for ambient products in transit and requires licensing for refrigerated storage unless it stays in refrigerated vehicles. The HPRA uses 48 hours and treats any storage of refrigerated product as needing a WDA.

MHRA blog (2016)

A site need not be named on a licence if ambient products are held for under 36 hours in transit and ownership has not transferred. Refrigerated products need a licensed site unless they stay overnight in continuously refrigerated vehicles.

Refrigerated medicinal products, part 1: receipt and storage - some things to consider, MHRA, 26 January 2016

HPRA IA-G0046 (2025)

Storage for more than 48 hours during transport, or any storage of refrigerated product regardless of time, is storage requiring a WDA.

Guide to Good Distribution Practice of Medicinal Products for Human Use (IA-G0046-8), HPRA, 8 April 2025

A risk-based way to decide

  1. Map every point where stock stops between dispatch and delivery.
  2. Record how long stock sits at each point and under what conditions.
  3. Check whether any activity beyond holding, such as picking or returns, happens there.
  4. Apply the threshold of the country where the depot sits.
  5. Put the arrangement and its limits in the transport contract.

Check with your inspector or RP: Confirm with the MHRA or HPRA for any cold chain cross-dock arrangement.

Applies to: Wholesalers (WDA), Transport. In the library: Does a depot or freight site that holds our medicines overnight need to be on a wholesale licence?; Does a haulier or courier holding medicines in transit in Ireland need a wholesale authorisation?; If we use a 3PL or courier, what do we need in place?

24

GMP and GDP: map on risk, or requalify on a schedule?

We manufacture and distribute from the same site. Do our stores follow the GDP mapping rule or the GMP requalification rule?

GDP asks for mapping before use, then a repeat on risk assessment or after significant change. GMP Annex 15 asks for qualification and evaluation at an appropriate frequency, with any fixed period justified, and never uses the word mapping. Neither sets an interval for storage; Annex 1 sets fixed intervals only for cleanrooms. These are differences of approach rather than a conflict.

EU GDP 3.2.1 (2013)

Map each storage area before use under representative conditions, place monitoring at the extremes, and repeat the mapping according to a risk assessment or after significant modifications to the facility or temperature control equipment.

Guidelines of 5 November 2013 on Good Distribution Practice of medicinal products for human use (2013/C 343/01), European Commission, 23 November 2013

EU GMP Annex 15, 4.1 and 4.2 (2015)

Evaluate facilities, equipment and systems at an appropriate frequency to confirm they remain in control. Where requalification is done at a specific time period, justify the period and define the evaluation criteria.

EudraLex Volume 4, Annex 15: Qualification and Validation, European Commission, 30 March 2015

EU GMP Annex 1, 4.32 (2022)

Requalify grade A and B cleanrooms at least every 6 months and grade C and D at least every 12 months. This applies to classified cleanrooms, not storage.

EudraLex Volume 4, Annex 1: Manufacture of Sterile Medicinal Products (2022), European Commission, 22 August 2022

WHO Supplement 8 (2015)

Periodic re-mapping may be needed, for example every three years; where continuous fixed monitors exist, a periodic re-evaluation may be more appropriate.

WHO TRS 961 Annex 9, Technical Supplement 8: Temperature mapping of storage areas (TRS 992, Annex 5), WHO, May 2015

A risk-based way to decide

  1. List every space and the regime each one serves: GMP storage, GDP storage, or both.
  2. Qualify GMP spaces through Annex 15, using mapping as the evidence, and map GDP spaces before use.
  3. Run one change control list of remapping triggers for every space.
  4. Review continuous monitoring data every year as the periodic evaluation.
  5. Set and justify an interval for each space and record it in the validation master plan.

Check with your inspector or RP: Ask your GMP inspector if a shared store relies on GDP-style trigger-based remapping alone, with no periodic evaluation.

Applies to: Manufacturers, Wholesalers (WDA), Laboratories. In the library: Do we have to temperature map a storage area before we start putting medicines in it?; How often do we have to requalify a temperature-controlled room or chamber at a manufacturing site?; Does Annex 15 require temperature mapping of our cold rooms and stability chambers?; Annex 1 gives fixed requalification intervals for cleanrooms. Do they apply to our cold rooms too?; How often should we repeat temperature mapping of a storage area?; Is there an industry standard for how often to remap a controlled temperature chamber?

25

GMP and GDP: how long to keep storage records?

GDP says at least five years. Our GMP batches expire in three years. Which retention period applies to storage temperature records?

GDP keeps all documents at least five years. GMP ties retention to the batch: one year after expiry or five years after QP certification, whichever is longer, and keeps raw data supporting the marketing authorisation, such as stability data, while the authorisation is in force. API records run one year after expiry, or three years after complete distribution for retest-dated APIs. Chapter 4 does not name temperature records, so which period applies depends on what the record supports.

EU GDP 4.2 (2013)

Keep documents for the period in national legislation but at least five years; keep backups of computerised data at least five years (3.3.1).

Guidelines of 5 November 2013 on Good Distribution Practice of medicinal products for human use (2013/C 343/01), European Commission, 23 November 2013

EU GMP Chapter 4, 4.11 and 4.12 (2011)

Keep batch documentation one year after batch expiry or at least five years after QP certification, whichever is longer. Keep critical documentation, including raw data relating to validation or stability that supports the marketing authorisation, while the authorisation remains in force.

EudraLex Volume 4, EU GMP Part I, Chapter 4: Documentation, European Commission, 30 June 2011

EU GMP Part II, 6.13 (2014)

For APIs, keep records at least one year after the batch expiry date, or at least three years after complete distribution for APIs with retest dates.

EudraLex Volume 4, EU GMP Part II: Basic Requirements for Active Substances used as Starting Materials, European Commission, 13 August 2014

A risk-based way to decide

  1. Decide what each temperature record supports: a batch release, a stability study, a qualification or distribution.
  2. Apply the period of the record it supports, and never less than five years where GDP also applies.
  3. Keep stability chamber records with the stability data for the life of the marketing authorisation.
  4. Make sure the monitoring system, or your archive, keeps the data and audit trail readable that long.
  5. Write one retention schedule with the clause behind each period.

Check with your inspector or RP: Ask your inspector if you plan to keep storage records for less than five years on the strength of a short batch expiry.

Applies to: Manufacturers, Wholesalers (WDA), Laboratories. In the library: How long must a manufacturer keep storage temperature records?; How long do we have to keep temperature records?; How long must an API manufacturer keep records, including storage records?; How long must batch records for an investigational product be kept?; Our logger software backs up to a server every night. Does that count as archiving our temperature records?

26

GMP and GDP: alarm testing and calibration intervals

GDP says alarms must be regularly tested and transport loggers calibrated yearly. GMP says neither. What should a manufacturer do?

Only GDP asks for alarms to be regularly tested (3.3) and gives a calibration minimum, at least once a year for transport monitoring equipment (9.2). GMP asks for calibration at defined intervals (3.41) and, in sterile areas, for alarms to be acknowledged and trended and delays justified (Annex 1), but says nothing about testing alarms. An MHRA Inspectorate blog reply (Sara Berry, 26 February 2018) says "the general expectation is that equipment should be calibrated annually".

EU GDP 3.3 and 9.2 (2013)

Set alarm levels appropriately and test alarms regularly. Calibrate transport monitoring equipment at regular intervals, at least once a year.

Guidelines of 5 November 2013 on Good Distribution Practice of medicinal products for human use (2013/C 343/01), European Commission, 23 November 2013

EU GMP Chapter 3, 3.41 (2015)

Calibrate and check measuring, weighing, recording and control equipment at defined intervals by appropriate methods, and keep records.

EudraLex Volume 4, EU GMP Part I, Chapter 3: Premises and Equipment, European Commission, 1 March 2015

EU GMP Annex 1, 4.16 and 5.2 (2022)

Warn operators instantly of critical pressure failures, justify any alarm delay in the contamination control strategy, and acknowledge and trend alarm events. No alarm test interval is given.

EudraLex Volume 4, Annex 1: Manufacture of Sterile Medicinal Products (2022), European Commission, 22 August 2022

MHRA blog reply (2018)

The general expectation is that equipment should be calibrated annually.

Temperature mapping - an introduction: inspector reply in the comments (26 February 2018), MHRA Inspectorate blog, 26 February 2018

A risk-based way to decide

  1. Treat an untested alarm as unqualified: test it in OQ and then on a cycle.
  2. Set calibration intervals from risk and history, starting from annual.
  3. Include the whole alarm path in each test, from sensor to the person on call.
  4. Trend alarm events, as Annex 1 asks, to spot units that alarm too often.
  5. Record the intervals and the reasons in your procedures.

Check with your inspector or RP: Ask your inspector if you plan a calibration interval longer than a year for probes that monitor product storage.

Applies to: Manufacturers, Wholesalers (WDA), Laboratories. In the library: Do we need temperature alarms, and do they have to be tested?; How often must temperature loggers used in vans and shipping boxes be calibrated?; How often does EU GMP say our temperature probes and recorders must be calibrated?; Does Annex 1 say anything about how monitoring systems are specified and how alarms are reviewed?; When we qualify a cold room or freezer, which alarm tests should be in the OQ?; How often should we test that our temperature alarms actually work?

20-minute compliance check

Would your rationale stand up to an inspector?

In 20 minutes we go through how you decide and record excursions, mapping and monitoring, and where the gaps are. You get them in writing. No product tour.