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Temperature mapping and qualification, from the source

When to map, how often to repeat it, where the probes go and what the MHRA, EU GDP and WHO guidance say about qualifying stores, fridges and vehicles.

Reviewed by Jake Farrow, Managing DirectorLast reviewed 19 October 2026

Temperature mapping is the study that proves a store, fridge, cold room or vehicle holds its labelled range everywhere you keep stock, and it tells you where the permanent monitoring probes belong. The one thing to remember: no UK or EU source sets a fixed re-mapping interval, so your frequency, triggers and method are yours to justify in a written risk assessment.

Why it matters

A probe only tells you about the air around it

A monitoring probe reports on one point. A warehouse, cold room or large fridge is not one temperature: stock high in the racking, by a heater or near a loading bay door can sit well away from the reading on the wall, so the record can look perfect while product elsewhere goes out of range. That is why EU GDP 3.2.1 asks for permanent monitors to be placed according to the mapping results, where the extremes of fluctuation are.

The risk runs both ways. The MHRA Inspectorate blog points out that vaccines, insulin and blood products are vulnerable to freezing as well as heat, so a cold spot matters as much as a warm one. Mapping is how you find both before your stock does.

What the rules say

From the licence condition to the mapping clause

For a wholesaler the duty starts in law. Regulation 43 of the Human Medicines Regulations 2012 makes compliance with the GDP guidelines a condition of the licence and requires premises and equipment that maintain the quality of the products. For Great Britain those guidelines are, in practice, the EU GDP Guidelines 2013/C 343/01 as they stood at the end of the transition period. The MHRA GDP Inspectorate enforces them; in Ireland the HPRA does.

Section 3.2.1 is short. Map the storage area before use, under representative conditions; put the permanent monitors where mapping shows the extremes; and repeat according to a risk assessment or after significant modifications to the facility or its temperature-controlling equipment. Small premises of a few square metres at room temperature may use a risk assessment (of heaters, for example) instead. Section 9.4 applies the same idea to temperature-controlled vehicles, taking account of seasonal variations.

If you are applying for a licence, MHRA Guidance Note 6 says you must be inspection-ready at the point of application, which includes a mapping exercise of the proposed wholesale area with a clear methodology.

How the inspectors and WHO fill the gaps

The guidelines do not say how to map, how many sensors to use or how long to run, and the MHRA mapping blog says so. Its advice is practical: map before stock goes in, using dummy product in empty fridges and cold stores; map again when fully stocked; repeat to cover seasonal variation; and include the highest storage point, heaters, lighting, windows, doors, loading bays, mezzanines and the controlled drug, packing, returns and quarantine areas. The RP should be involved throughout.

The European Commission GDP Q&A adds that probe numbers follow a risk analysis, not a fixed count, and that mapping should be done in different seasons. For numbers, most people turn to WHO Technical Supplement 8: loggers every 5 to 10 metres, at low, middle and high level where ceilings are 3.6 m or lower, at least seven consecutive days for an ambient warehouse (five working days and a weekend) and 24 to 72 hours for cold rooms and freezer rooms. WHO presents these as guidance, not rules.

What good looks like

A mapping programme, not a one-off report

A good study starts with a protocol approved before any logger goes in: the area, the conditions tested (empty, loaded, summer, winter), logger positions with reasons, run length and acceptance criteria. WHO Supplement 8 expects one logger type per study, sampling at the same interval of 1 to 15 minutes, each with a valid 3-point calibration within ±0.5 °C. If a contractor runs the study, your organisation still reviews and approves it: MHRA's 2015 GMP deficiency data cite contractor mapping the company had not approved.

The report should end in decisions: where the permanent probes go, where stock must not be stored, and when to re-map. If your monitoring went in before the mapping, or the two were never reconciled, see how to justify each probe position. WHO's guidance adds that if a spot near a door causes alarms that cannot be fixed, stop storing product there rather than moving the probe. Triggers worth writing into your procedure:

  • significant modifications to the facility or its temperature-controlling equipment (EU GDP 3.2.1);
  • reconfiguring the storage area (MHRA mapping blog);
  • changes to loading, airflow, refrigeration equipment or set point, and unexplained variability in monitoring data (WHO Supplement 8);
  • repair or replacement of a refrigeration unit, changes to how duty and back-up condensers run, and moving a fridge (HPRA IA-G0011, for Irish sites, and a useful checklist anywhere).

Fridges, cold rooms and freezers

The HPRA expects large fridges and walk-in cold rooms to be mapped on installation, empty and full, with an ambient probe outside the unit. WHO Supplement 8 adds that a room with duplicate refrigeration units should be mapped with each unit running on its own. WHO Supplement 7 asks qualification to show how long a new store holds temperature after a power failure and how quickly it recovers, tested while the store is empty because the test can cause an excursion. The result feeds your contingency plan.

The MHRA blog says the effect on temperature distribution should be investigated if a fridge is filled to capacity, and the freezer blog says freezers must be qualified, monitored and mapped like refrigerators. Vans and shippers are covered on the transport page.

Worked example

Mapping a new ambient store before go-live

This is an illustrative example; the site and readings are invented. A small wholesaler has fitted out an ambient store with racking to 5 m ahead of its licence application, for stock labelled 'do not store above 25 °C'.

Week one, the protocol. Using WHO Supplement 8 as the reference, the QA lead plans a grid of loggers, vertical arrays over the full racking height, and extra loggers by the roller door, the south-facing windows, the heaters and the returns cage. Logger calibration certificates are checked and filed, and the RP approves the protocol.

Monday 09:00 in July, the summer run. It runs seven days including a weekend. On Saturday afternoon the logger at the top of the rack by the windows peaks at 26.4 °C; every other position stays in range. What they do: mark the top beam in those bays 'not for use', raise a change control for solar film, put that zone's permanent probe at the top of the rack, and book a winter run for January.

What they record: the protocol, raw data, calibration certificates, the report with the deviation and its investigation, the reason for each permanent probe position, the re-mapping triggers and the RP's sign-off. That file is the evidence Guidance Note 6 asks applicants to show.

Where it is unclear

The worst case, not the door threshold

Mapping often finds the biggest swings by a door or a loading bay, and some sites put the alarm probe right there. It then alarms on every delivery and the team stops listening. That is not what the guidance asks for. WHO Annex 9 puts monitoring sensors where the greatest variability is expected, but positioned so as to be minimally affected by transient 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.

So the alarm probe goes at the mapped worst case that represents stock, and it is buffered so a door opening does not trip it. There are three ways to buffer it:

  • A sensor whose housing is the buffer. A sealed device with its sensing element inside, such as our Node+ Embedded, where the housing's thermal mass damps brief air changes. There is no liquid to top up or spill, no cable to snag and nothing to replace, which suits warehouses and ambient or cold stores. Confirm its response against your mapping data before setting delays.
  • An external probe in a simulant: water, glycol or glycerol, glass beads or a block, with the container and fill volume fixed and written down.
  • A product probe: a probe in a real or mock unit of product. For blood, that means a 200 mL water-equivalent simulant with no delay on the product alarm (blood product simulants).

Interval, seasons and small rooms

Three questions come up again and again. How often to re-map: EU GDP, the MHRA, the HPRA and SPS set no interval (our recommendation is below), and WHO's 'every three years' is an example (re-mapping frequency). Whether cold rooms need summer and winter runs: the Commission's Q&A says different seasons with no exception, WHO says typically not (seasonal mapping of cold rooms). And how small 'a few square metres' is: nobody defines it (small premises).

Two more sit at the edges. A 2016 MHRA blog suggests a central fridge probe while EU GDP points to the mapped extremes (probe position), and no UK source gives a fridge fill limit (fill limits). WHO's Supplement 8 excludes fridges from mapping, while its 2020 storage guideline includes them.

Which source says what about mapping
ControlEU GDPMHRA blogWHO Supp. 8HPRA
Map before first use✓✓✓✓
Map to cover the seasons (ambient)·✓✓✓
Re-map after significant change✓✓✓✓
A fixed re-mapping interval····

A tick means the source states it. WHO says a second seasonal study 'may be needed'; its three-year interval is an example, not a requirement.

Inspection findings

What inspectors have found

The MHRA GDP deficiency data for 2016, a sample of 148 of 1,428 inspections, record major findings where mapping was not adequate to show the areas were suitable or to place thermometers at the extremes. They also cite a warehouse thermometer not calibrated across its operating range, and an ambient thermometer installed so its readings did not come from the calibrated probe.

On the manufacturing side, the 2015 GMP deficiency data include a storage room reconfigured without assessing the impact on the existing mapping. The 2016 report is the only GDP-specific deficiency dataset found on GOV.UK, so patterns may have changed since. For manufacturing sites, where Annex 15 qualification applies as well as or instead of the GDP mapping clause, see GMP storage, mapping and monitoring.

In summary

The short version

  • Map every storage area before use, under representative conditions, and keep the protocol, data and report.
  • Place permanent probes where mapping shows the extremes, and record why each one is there.
  • Test the conditions that change the answer: empty and full, summer and winter, each refrigeration unit alone.
  • Use calibrated loggers of one type per study, and check the certificates first.
  • Approve any contractor's protocol and report yourself, with the RP involved.
  • Write down your re-mapping interval and triggers, and review them at self-inspection.
  • Where the sources differ, assess the risk and record your reasoning.

Mapping and qualification

Questions, answered from the source

Last checked 19 October 2026. Each answer links to its source and says whether it is law, formal guidance or interpretation.

Do we need to temperature map a pharmaceutical fridge, and can a household fridge be used?Guidance

WHO model guidance says refrigerators and freezers should be purpose-designed, and household-style units are acceptable only if independently tested against a recognised standard for pharmaceutical refrigerators. It says qualification may not be needed for equipment with little or no site assembly that has been independently tested, provided it is installed correctly. WHO's mapping supplement explicitly does not cover refrigerators or freezers, because they are generally tested and prequalified independently.

What's agreed, and what isn't

WHO's later Good Storage and Distribution Practices guideline (TRS 1025, Annex 7, 2020) lists refrigerators and freezers among the places where mapping should be done, which conflicts with Supplement 8. Follow your inspector's or sector guidance, and document why you did or did not map.

Status
Formal guidance
Applies to
Wholesalers (WDA), Hospitals and wards, Laboratories, Community pharmacy
Last checked
18 October 2026
Can we use a domestic freezer, or the ice box of a fridge, for frozen medicines or cold packs?Interpretation

The MHRA freezer blog says refrigerator ice boxes are 'not supported in any circumstance' for GDP use. It warns that domestic freezers may have auto-defrost cycles causing high excursions and are less able to hold a narrow range. Freezers storing medicines should be dedicated, or shown not to be affected by freezing cold packs. Most frozen medicines need -15°C to -20°C, and freezers must be qualified, monitored and mapped like refrigerators.

What's agreed, and what isn't

The blog does not ban domestic freezers outright; it lists their drawbacks and leaves the choice to qualification evidence. It also flags that combined fridge-freezers on one compressor can compromise both compartments. If you only stock a few frozen lines, it suggests not holding them or outsourcing.

Source
Use of Freezers MHRA, 20 June 2017
Status
Interpretation
Applies to
Wholesalers (WDA)
Last checked
18 October 2026
Is it a problem if our pharmacy fridge is packed full, or we chill gel packs in it?Interpretation

Quoting the Green Guide, the MHRA blog says enough space should be kept for air circulation, products should not touch the walls or floor, and if a fridge is filled to capacity, the effect on temperature distribution should be investigated. Where non-refrigerated items such as unconditioned gel packs go into the fridge, the temperature rise they cause should be assessed. Stock of different status (incoming, quarantine, returned, outgoing) should be segregated.

What's agreed, and what isn't

No fill limit is given; the expectation is evidence (for example mapping at full load) rather than a percentage rule. The 2017 freezer blog makes the same point for freezers, recommending dedicated units for medicines rather than shared use for conditioning cold packs.

Status
Interpretation
Applies to
Wholesalers (WDA)
Last checked
18 October 2026
For a general sale (GSL) wholesaler in Ireland, how should a temperature deviation be classified in our own deviation system?Guidance

The HPRA's model quality system for general sale wholesalers gives 'temperature deviations' as an example of a Major deviation (potential to compromise product quality) in the company's own classification scheme, alongside a Critical tier (e.g. failure to quarantine unsuitable product) and a Minor tier. Its temperature SOP template requires initial mapping or a documented RP-approved risk assessment, worst-case probe placement and daily max/min recording.

What's agreed, and what isn't

This is a company-level deviation classification example, not the HPRA's inspection grading. The guide says inspection frequency for these distributors is risk-based, between six months and five years.

Status
Formal guidance
Applies to
Wholesalers (WDA)
Last checked
18 October 2026
Annex 1 gives fixed requalification intervals for cleanrooms. Do they apply to our cold rooms too?Guidance

No. Annex 1, 4.32 sets a maximum of 6 months between requalifications for grade A and B areas and 12 months for grade C and D, covering tests such as particle counts and pressure differentials. Those intervals are for classified cleanrooms. Storage areas, cold rooms and chambers fall under Annex 15, which asks for evaluation "at an appropriate frequency" with any fixed period justified (4.1, 4.2).

What's agreed, and what isn't

Because Annex 15 sets no number for storage, your requalification interval is a decision you write down and defend, usually from the risk of the stored product and the trend of the continuous monitoring data.

Status
Formal guidance
Applies to
Manufacturers
Last checked
19 October 2026
Do our stability chambers have to be qualified and monitored like any other equipment?Guidance

Yes. Chapter 6, 6.29 says equipment used for the ongoing stability programme, "stability chambers among others", should be qualified and maintained following Chapter 3 and Annex 15. The stability protocol states the storage conditions, using the standard ICH conditions consistent with the label (6.30), and out-of-specification results or significant atypical trends must be investigated (6.35).

What's agreed, and what isn't

ICH Q1A(R2) adds that the actual temperature and humidity should be monitored during stability storage, and that excursions beyond tolerance for more than 24 hours go in the study report. Normally at least one batch a year of each strength and primary pack goes on stability (6.32), so a chamber failure can touch years of data.

Status
Formal guidance
Applies to
Manufacturers, Laboratories
Last checked
19 October 2026
Do refrigerated vans have to be temperature mapped?Guidance

Yes, if temperature-controlled vehicles are used. EU GDP 9.4 says temperature mapping under representative conditions should be carried out and should take account of seasonal variations, and the monitoring equipment should be maintained and calibrated. For temperature-sensitive products, qualified equipment (thermal packaging, temperature-controlled containers or vehicles) should be used between manufacturer, wholesaler and customer.

What's agreed, and what isn't

No method, duration or re-mapping interval is specified. 'Seasonal variations' is generally read as summer and winter mapping, but the guideline does not say so. Customers can ask for evidence that products stayed within their temperature conditions, and you should be able to provide it.

Status
Formal guidance
Applies to
Wholesalers (WDA), Transport
Last checked
18 October 2026
Do we have to temperature map a storage area before we start putting medicines in it?Guidance

Yes. EU GDP 3.2.1 says an initial temperature mapping exercise should be carried out on the storage area before use, under representative conditions. The permanent monitoring devices should then be placed according to the mapping results, in the areas that experience the extremes of fluctuation. Mapping should be repeated according to a risk assessment or whenever significant modifications are made to the facility or the temperature-controlling equipment.

What's agreed, and what isn't

The guideline does not say how to map, how many sensors to use, how long to run it, or a fixed re-mapping interval; these are left to the company's risk assessment. 'Representative conditions' is not defined, which is why MHRA inspectors have also expected loaded and seasonal mapping (see the MHRA mapping blog).

Status
Formal guidance
Applies to
Wholesalers (WDA)
Last checked
18 October 2026
Do we need to temperature map our medicines room and fridges, and how is it done?Guidance

SPS describes mapping as placing calibrated data loggers throughout an area to check every point is suitable and to decide where permanent sensors go. It is usual to use 8 to 25 loggers in an ambient room. In a full-size fridge, put one in each corner of the top and bottom shelves plus one in the middle. Mapping usually runs for at least 48 hours, covering busy and quiet periods. Initial ambient mapping should be done in both summer and winter. Fridges should be mapped full, and new fridges mapped empty first to get a baseline.

What's agreed, and what isn't

SPS makes re-mapping frequency risk-based and sets no fixed interval. Ambient rooms with no structural or HVAC changes need mapping less often than fridges or cold rooms holding high-cost drugs. Small GP practices and care homes rarely map in practice, and SPS does not say mapping is mandatory for them.

Status
Formal guidance
Applies to
Hospitals and wards, Community pharmacy, GP practices, Care homes
Last checked
18 October 2026
Do we need to test how long our cold room holds temperature in a power cut?Guidance

WHO says qualification of a new temperature-controlled store should show how long temperatures stay within limits after a power failure (holdover time) and how long they take to recover once power returns, as well as recovery after a typical door opening. Supplement 7 describes running the test until an excursion occurs, or for a fixed period such as two hours. It recommends doing this during OQ while the store is empty, because the test can cause an excursion. For cold rooms there are usually no set acceptance criteria; the results feed into emergency planning, for example for standby generators.

What's agreed, and what isn't

Re-running holdover tests on a loaded store puts stock at risk, so most sites rely on the original OQ data unless the equipment changes. WHO also expects monitoring to keep working during power failures, and wireless sensors to buffer data during outages.

Status
Formal guidance
Applies to
Wholesalers (WDA), Hospitals and wards, Laboratories
Last checked
18 October 2026
Does Annex 15 require temperature mapping of our cold rooms and stability chambers?Guidance

Annex 15 never uses the word "mapping". It requires facilities, equipment and utilities to be qualified through a lifecycle (URS, DQ, IQ, OQ, PQ), with OQ testing upper and lower operating limits or worst-case conditions (3.11) and PQ under normal operating conditions (3.14). For a temperature-controlled space, a mapping study is the usual way to show those things: that the whole volume holds its range, empty and loaded.

What's agreed, and what isn't

Mapping as a word comes from EU GDP 3.2.1 (map before use, then on risk or after change) and, in sterile manufacture, from Annex 1 for autoclave loads (8.64 and 8.65). Chapter 6, 6.29 says stability chambers must be qualified to Chapter 3 and Annex 15. So the requirement for a chamber is qualification; mapping is the evidence most inspectors expect to see.

Status
Formal guidance
Applies to
Manufacturers, Laboratories
Last checked
19 October 2026
How long should a mapping study run, and is seasonal mapping needed for a cold room?Guidance

WHO Supplement 8 says there is no formal time limit. Typically ambient warehouses should be mapped for at least seven consecutive days, including five working days and a weekend. Cold rooms and freezer rooms should be mapped for 24 to 72 hours, or longer if justified. Rooms with duplicate refrigeration units should be mapped with each unit running on its own. Where areas are affected by seasonal variation, two studies (warmest and coldest seasons) may be needed, but this is "typically" not necessary for cold rooms and freezer rooms.

What's agreed, and what isn't

The European Commission GDP Q&A says mapping should be done in different seasons without exempting cold rooms. A refrigerated room in an uncontrolled or external building may still be affected by the seasons, so assess your own situation. Supplement 8 also suggests products should return within limits within 30 minutes of a defined door opening, where door openings are part of the study.

Status
Formal guidance
Applies to
Wholesalers (WDA), Hospitals and wards, Laboratories
Last checked
18 October 2026
How many data loggers do we need for a mapping study and where do we put them?Guidance

WHO Supplement 8 suggests a risk-based grid with loggers every 5 to 10 metres along the length and width (up to 20 to 30 metres in very large facilities), positioned where products are actually stored. Where ceilings are 3.6 m or lower, place loggers at low, middle and high level (for example floor, 1.2 m and 3.0 m). For taller spaces use vertical arrays, for example at 0.3, 1.8, 3.6 and 5.4 m in a 6 m store. Loggers should be one type per study, sample at the same interval of 1 to 15 minutes, start at the same time, and hold a valid 3-point calibration with error within ±0.5°C.

What's agreed, and what isn't

The grid is guidance, not a rule; WHO itself says a risk-based approach can define locations. High-bay racking is singled out as prone to stratification and needs mapping over its full working height.

Status
Formal guidance
Applies to
Wholesalers (WDA), Hospitals and wards, Laboratories
Last checked
18 October 2026
How often do we have to requalify a temperature-controlled room or chamber at a manufacturing site?Guidance

EU GMP Annex 15 sets no fixed interval. It says facilities, equipment and systems should be evaluated "at an appropriate frequency" to confirm they remain in control. Where requalification is done on a time basis, the period should be justified and the evaluation criteria defined, and the possibility of small changes building up over time should be assessed.

What's agreed, and what isn't

WHO Technical Supplement 8 gives an example of remapping every three years, but says a periodic re-evaluation may be more appropriate where several fixed monitors provide continuous data. Whatever interval you choose, document the rationale.

Status
Formal guidance
Applies to
Manufacturers, Laboratories
Last checked
18 October 2026
How often should we repeat temperature mapping of a storage area?Guidance

WHO Supplement 8 says new temperature-controlled areas must be mapped before use. After that, depending on the monitoring strategy, periodic remapping may be needed, "for example, every three years". Where several fixed monitors give continuous data, a periodic re-evaluation of system performance since the initial mapping may be more appropriate. Mapping should also be repeated after significant changes (for example to loading, airflow, refrigeration equipment or set point) and may be justified when monitoring shows unexplained variability.

What's agreed, and what isn't

Three years is an example, not a requirement. EU GMP Annex 15 also leaves the interval to a justified, risk-based choice. Inspectors mainly look for a documented trigger list and rationale.

Status
Formal guidance
Applies to
Wholesalers (WDA), Hospitals and wards, Laboratories
Last checked
18 October 2026
In Ireland, does the HPRA expect an ambient warehouse to be mapped in both summer and winter, and empty and full?Guidance

Yes. The HPRA temperature guide (IA-G0011) says warehouses should be mapped in the empty and full states and that mapping should be performed during both summer and winter to assess worst-case conditions. Mapping should be repeated after significant modification to the premises, changes in stock layout or changes to the heating system, and areas such as skylights and controlled drug cabinets should be included.

What's agreed, and what isn't

The guide does not set a fixed re-mapping interval (e.g. every X years); re-mapping is trigger-based. It also flags turning heating off overnight or at weekends as something to consider. The EU GDP Guidelines themselves only say mapping should be done 'under representative conditions'; the explicit summer/winter and empty/full wording is HPRA elaboration.

Status
Formal guidance
Applies to
Wholesalers (WDA), Manufacturers
Last checked
18 October 2026
Our Irish storage area is tiny. Do we need a full temperature mapping study?Guidance

The HPRA GDP guide says an initial mapping exercise must be performed and documented for areas greater than a few square metres; for room-temperature areas smaller than that, a risk assessment can be used instead. Continuous monitoring probes should then be placed according to the mapping or risk assessment in all storage areas, including pick-face, quarantine and returns, with at least a max/min thermometer read and reset daily.

What's agreed, and what isn't

This mirrors EU GDP 3.2.1, which has the same 'few square meters' concession; the HPRA wording makes mapping a 'must' above that size. 'A few square metres' is not defined numerically. The concession applies to room-temperature areas only; IA-G0011 still expects mapping to inform probe locations in small fridges. Products with no labelled storage condition may be stored at temperatures not exceeding 30°C according to the same guide.

Status
Formal guidance
Applies to
Wholesalers (WDA)
Last checked
18 October 2026
Our store is just a small room at room temperature - do we need a full mapping study?Guidance

EU GDP 3.2.1 makes a specific allowance: for small premises of a few square metres at room temperature, an assessment of potential risks (for example heaters) should be conducted and temperature monitors placed accordingly. This is offered instead of the formal mapping exercise described for larger storage areas.

What's agreed, and what isn't

'A few square metres' is not defined. The MHRA's 2016 mapping blog, aimed at small storage areas and small fridges, still describes a mapping exercise with calibrated probes, so many inspectors will expect some recorded data, not only a desk-based risk assessment. The allowance covers room-temperature premises only, not fridges or cold rooms. Check with your inspector if in doubt.

Status
Formal guidance
Applies to
Wholesalers (WDA)
Last checked
18 October 2026
We moved racking and replaced a compressor in a qualified cold room. Do we need to requalify?Guidance

Annex 15 says changes should be assessed through change control for their impact on product quality, validation, calibration and maintenance, with a plan for any necessary verification or requalification (11.4), and the effectiveness of the change evaluated afterwards (11.7). Requalification at a fixed period must be justified, and gradual change over time should be considered (4.2).

What's agreed, and what isn't

Annex 15 does not list triggers. The HPRA temperature guide, which includes manufacturers in its scope, gives repair or replacement of the refrigeration unit, layout changes and set-point changes as re-mapping triggers, and the MHRA's 2015 GMP deficiency data cite a storage room reconfigured with no assessment of the effect on its mapping.

Status
Formal guidance
Applies to
Manufacturers, Laboratories
Last checked
19 October 2026
We're applying for a new WDA(H) - do we need mapping done before the inspection?Guidance

Yes. MHRA Guidance Note 6 says applicants must be inspection-ready at the point of application. That includes being able to show a temperature mapping exercise of the proposed wholesale area with a clear methodology, and evidence of transport validation. Applicants should also give details of ambient and cold chain storage, transport arrangements, computerised systems and business contingency plans.

What's agreed, and what isn't

GN6 does not define what counts as adequate transport validation. For small applicants using couriers, this usually means courier qualification plus packaging or lane qualification evidence. The MHRA mapping blog notes that new applicants are often unclear about mapping expectations.

Status
Formal guidance
Applies to
Wholesalers (WDA)
Last checked
18 October 2026
What qualification stages does a new cold room, freezer or stability chamber need under GMP?Guidance

Annex 15 sets a lifecycle from the user requirements specification (URS) to retirement. Design qualification checks the design against the URS (3.3). Installation qualification covers installation checks, supplier manuals and calibration of instrumentation (3.9). Operational qualification tests the upper and lower operating limits or worst case (3.11). Performance qualification shows performance under normal operating conditions with worst-case loads (3.14). Tests done at the factory or site acceptance can be credited if transport and installation do not affect the function (3.6).

What's agreed, and what isn't

WHO Supplement 7 describes the same four phases for temperature-controlled stores: OQ empty (alarm tests, empty mapping, door-opening and power-failure tests) and PQ loaded. The monitoring system on the chamber is a separate computerised system, validated under Annex 11.

Status
Formal guidance
Applies to
Manufacturers, Laboratories
Last checked
19 October 2026
When does the HPRA expect a walk-in cold room or large fridge to be re-mapped?Guidance

IA-G0011 says large refrigerators and walk-in cold rooms should be mapped on installation in the empty and full states, with an ambient probe outside the unit. Re-mapping is expected after significant changes such as repair or replacement of the refrigeration unit, changes to internal layout, changes to set points, and changes to how duty/back-up condensers are run, including swapping which is main and which is back-up; if units are routinely rotated, both should be in the mapping study. Moving a small fridge may also require re-mapping.

What's agreed, and what isn't

These are specific triggers that go further in detail than the EU GDP text. The guide's wording varies in strength: re-mapping after a change to how duty/back-up condensers are run 'is required', while moving a fridge 'may' require it, and most other triggers use 'should'. None of it is a legal requirement. No fixed periodic re-mapping frequency is given.

Status
Formal guidance
Applies to
Wholesalers (WDA), Manufacturers
Last checked
18 October 2026
When we qualify a cold room or freezer, which alarm tests should be in the OQ?Guidance

WHO Supplement 7 says OQ is normally done empty and includes alarm tests: at least one high and one low alarm test, plus door-open alarms, and every notification route (sounder, strobe, remote or SaaS service, SMS or phone) needs to be tested. OQ also covers empty mapping for at least 24 hours, door-opening recovery and a power-failure holdover test.

What's agreed, and what isn't

WHO writes for storage and distribution, but the supplement covers ultra-low freezers, freezers, cold rooms and controlled ambient stores, and its steps match the Annex 15 OQ. Do not start PQ until OQ deviations are closed (2.6).

Status
Formal guidance
Applies to
Manufacturers, Laboratories, Wholesalers (WDA)
Last checked
19 October 2026
Do our production areas and WIP stores need temperature mapping, or is monitoring enough?Interpretation

An MHRA group manager, replying on the Inspectorate blog in 2016, said the normal expectation is temperature monitoring only within production areas, but mapping may be required if the product is temperature sensitive. Mapping of WIP or intermediate storage may also be needed to show the routine monitoring positions are representative of the worst case.

What's agreed, and what isn't

This is an inspector's reply, not guidance. EU GMP itself asks for production areas to have temperature control appropriate to the products (Chapter 3, 3.12) and for environmental controls to be recorded (Chapter 5, 5.43). Write the decision, and the data behind it, into your qualification file.

Status
Interpretation
Applies to
Manufacturers
Last checked
19 October 2026
How often should we re-map, and what is the RP's role?Interpretation

The MHRA blog says the risk assessment from mapping should define and justify how often future mapping is done, and should be reviewed regularly, for example during self-inspection. Mapping should be repeated for seasonal variation and if the storage area is reconfigured. The RP should be involved in the whole mapping process, aware of the findings and recommendations, supervise routine daily min/max monitoring, and be consulted on any temperature excursion.

What's agreed, and what isn't

No fixed re-mapping interval is set by EU GDP or this blog. Annual or summer/winter mapping is a common industry convention, not an MHRA rule. Be ready to justify whatever interval you choose.

Source
Temperature mapping - an introduction MHRA, 14 July 2016
Status
Interpretation
Applies to
Wholesalers (WDA)
Last checked
18 October 2026
How should a small wholesaler actually carry out a temperature mapping exercise?Interpretation

The MHRA mapping blog says to map before stock is stored if possible, using dummy product in empty fridges, freezers and cold stores, and to repeat the mapping when fully stocked and to cover seasonal variation. Cover the highest point of storage and problem areas such as heaters, lighting, windows, doors, loading bays and mezzanines. Include CD rooms, packing, returns and quarantine areas. Use enough calibrated probes for the size of the area, then risk-assess the data to place permanent probes at hot and cold spots.

What's agreed, and what isn't

The blog notes that EU GDP requires mapping but 'does not state how this should be done'. It gives no probe numbers, grid spacing or duration. Larger sites often use specialist third parties. The blog does not answer how long each mapping run should last.

Source
Temperature mapping - an introduction MHRA, 14 July 2016
Status
Interpretation
Applies to
Wholesalers (WDA)
Last checked
18 October 2026
If a contractor carries out our temperature mapping, is their report enough?Interpretation

No; the company has to review and approve it. MHRA's 2015 GMP deficiency examples include mapping of production and warehouse areas by a contractor that "had not been approved by the company". Other findings were a retention sample store with no temperature logger nearby, a drug storage room reconfigured without assessing the impact on the existing mapping, and laboratory sample and standard storage areas with no temperature recording.

What's agreed, and what isn't

WHO Supplement 8 likewise says a protocol prepared by a third party should be authorised by the responsible person in the commissioning organisation. These are deficiency examples, not formal guidance.

Status
Interpretation
Applies to
Manufacturers, Laboratories
Last checked
18 October 2026
In a GLP lab, do refrigerators with data capture need a user requirement specification and mapping?Interpretation

In its 2016 laboratories symposium Q&A, the MHRA said any equipment using electronic data capture is within scope of OECD GLP guidance document No. 17 on computerised systems. The level of validation depends on complexity. Where a computerised system captures or monitors data, an assessment of fitness for use is expected, including a specification covering temperature range and alarms. The refrigerator should be fit for purpose and able to deliver the required performance, which 'may require equipment validation such as temperature mapping'.

What's agreed, and what isn't

The answer is framed for GLP test facilities. Mapping is described as possibly required, not mandatory, so the extent should be risk-based and documented.

Status
Interpretation
Applies to
Laboratories
Last checked
18 October 2026
Is there an industry standard for how often to remap a controlled temperature chamber?Interpretation

Not a fixed one. ISPE's Good Practice Guide on controlled temperature chambers (second edition, December 2021) moved to a risk-based periodic review, judged on the risk of failing to keep a uniform temperature and how critical the stored product is, "rather than a standard, one-size-fits-all time span". It also covers mapping with load effects, using the data to find worst-case locations and the number of monitoring sensors, and adds ultra-low freezers.

What's agreed, and what isn't

ISPE guides are licensed industry guidance, not regulation; this paraphrases ISPE's public description. It agrees with Annex 15 (an appropriate, justified frequency) and with WHO, which gives three years only as an example.

Status
Interpretation
Applies to
Manufacturers, Laboratories
Last checked
19 October 2026
What does 'initial temperature mapping' actually involve, and does it have to cover summer and winter?Interpretation

The Commission's Q&A describes initial mapping as placing sensors at the points a risk analysis shows to be most critical (for example different heights, near a sunny window, next to doors), measuring over a period, and then putting the monitoring sensors where the greatest fluctuation occurred. It says mapping should be done in different seasons, when the highest and lowest temperatures are reached.

What's agreed, and what isn't

WHO Technical Supplement 8 agrees on two-season mapping for areas affected by seasonal variation, but says it is "typically" not necessary for cold rooms and freezer rooms. The Commission Q&A does not make that exception. For ambient warehouses, plan for both seasons. For refrigerated rooms, justify your choice.

Status
Interpretation
Applies to
Wholesalers (WDA)
Last checked
18 October 2026
Does the HPRA temperature guide apply to manufacturers in Ireland, or only wholesalers?Guidance

Its scope covers human and veterinary medicinal product manufacturers, wholesalers and transporters in Ireland, and manufacturers of APIs. It says a continuous temperature monitoring system is required for the storage of medicinal products, recording probes should be independent of controlling probes and placed at the greatest variability found by mapping, warehouses mapped empty and full in summer and winter, and probes calibrated at least annually at a minimum of three points.

What's agreed, and what isn't

Its legal basis and much of its wording are written for wholesale (it cites the wholesale regulations and the RP), so present it as HPRA temperature guidance that includes manufacturers, not as a GMP guideline. Irish manufacturers' legal duty to follow GMP is in S.I. No. 539/2007, regulation 10.

Status
Formal guidance
Applies to
Manufacturers
Last checked
19 October 2026
How accurate do our temperature sensors need to be, and where should the monitoring probe go?Guidance

WHO says monitoring sensors should be accurate to ±0.5°C or better for electronic devices, and ±1°C for alcohol, bimetal or vapour-pressure thermometers. They should be placed where the greatest temperature variability is expected within the qualified storage volume, but positioned to be minimally affected by brief events like door opening. Control sensors (the thermostat) should be independent of the monitoring system. WHO Supplement 6 says ambient areas should be monitored at the seasonal hot and cold spots found in mapping, and cold rooms at the operational hot and cold spots.

What's agreed, and what isn't

WHO Supplement 6 adds that if a spot near a door causes frequent alarms that cannot be fixed, products should not be stored there at all, rather than moving the probe to hide it. 'Worst case but not affected by door opening' can be a real tension in small walk-in rooms.

Status
Formal guidance
Applies to
Wholesalers (WDA), Hospitals and wards, Laboratories
Last checked
18 October 2026
Should the alarm probe go right by the door, since that is where the temperature swings most?Guidance

No. WHO Technical Supplement 6 (section 2.5.2) says 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". Ambient stores are monitored at the seasonal hot and cold spots found in mapping, and cold rooms and freezer rooms at the operational hot and cold spots. If door openings trigger out-of-range alarms too often and that cannot be fixed technically or operationally, for example by limiting door openings, the area should not be used to store product at all.

What's agreed, and what isn't

The HPRA reaches the same place by a different route: IA-G0011 section 10 says probes should be in an appropriate load simulator so that transient rises when the doors are opened during picking do not trigger alarms. EU GDP 3.2.1 and the MHRA mapping blog say only that monitors go at the extremes found by mapping, which some sites read as the door threshold. Record why each probe is where it is, and how it is buffered.

Status
Formal guidance
Applies to
Wholesalers (WDA), Hospitals and wards, Manufacturers, Laboratories
Last checked
19 October 2026
What monitoring and records does the Red Book expect for blood component storage areas?Guidance

Storage areas must run within a specified temperature range. Areas and equipment should be validated before routine use and checked for calibration to a documented schedule after that. A permanent continuous record of storage temperatures should be made, reviewed and stored, along with a log of alarm events describing the corrective action taken. Written procedures should cover validating and monitoring storage conditions, authorised access, segregation by status (quarantine, non-conforming, returned, stock) and stock rotation.

What's agreed, and what isn't

The Red Book sets no calibration frequency or alarm set points; these are left to local validation. It is written for UK blood services, but hospital transfusion laboratories commonly apply it.

Status
Formal guidance
Applies to
Blood, Hospitals and wards
Last checked
18 October 2026
How many temperature probes do we need in our storage area?Interpretation

The European Commission's GDP Q&A says the number of probes and where they go depend on a risk analysis of the site, and placement should agree with the mapping results. It gives no fixed number.

What's agreed, and what isn't

WHO gives more concrete starting points. For walk-in spaces the number of monitoring points depends on size and on variations seen during mapping. For a refrigerator or freezer at least one monitoring point is needed, and WHO notes some regulators want two (warmest and coldest points). The Q&A states it is not legally binding.

Status
Interpretation
Applies to
Wholesalers (WDA)
Last checked
18 October 2026
The monitoring system supplier gave us a validation pack. Is that enough to show the system is validated?Guidance

Not on its own. MHRA says computerised systems must be validated for their intended purpose, and "the acceptance of vendor-supplied validation data in isolation" from your configuration and intended use is not acceptable. Vendor testing done away from your process and IT setup is likely to be functional verification only, and may not meet performance qualification requirements. Vendor documents can feed into your validation, but you still need to show the system works as configured at your site.

What's agreed, and what isn't

How much site testing is needed depends on risk and complexity (MHRA section 4.3). WHO Supplement 6 expects installed monitoring systems to be qualified through IQ, OQ and PQ after a commissioning period. For SaaS systems the supplier may do much of the work, but the user still has to confirm the system meets its own requirements.

Status
Formal guidance
Applies to
Wholesalers (WDA), Manufacturers, Hospitals and wards, Laboratories, Blood, Tissue and mortuary
Last checked
18 October 2026
Can we qualify insulated cold-chain shippers in an environmental chamber for Irish distribution?Guidance

IA-G0011 states that qualification should use actual transport conditions and that chamber studies 'are not considered to be reflective of actual conditions'. Studies should send containers with loggers to the furthest delivery location, cover seasonal extremes (possibly separate summer and winter pack-outs), full and empty loads, and any door openings during delivery. The time of packing, not dispatch, should be recorded so receivers can confirm receipt within the validated time.

What's agreed, and what isn't

Ice-pack conditioning and re-freezing times should form part of validation, and freezers used for ice packs are subject to the same qualification as product freezers. The position on chamber studies is a notable HPRA-specific statement; it is not wording from the EU GDP Guidelines.

Status
Formal guidance
Applies to
Wholesalers (WDA), Transport
Last checked
18 October 2026
Does the HPRA require refrigerated vans to be temperature mapped?Guidance

Where refrigerated vehicles or containers are the primary means of environmental control, IA-G0011 says they should be validated and monitored, including mapping to find hot and cold spots under worst-case conditions (loaded to capacity, seasonal extremes) and considering door openings, power sources and breakdowns. Loads at risk of freezing should be monitored with calibrated data loggers, and single-use monitors should be qualified.

What's agreed, and what isn't

Vehicle validation is not necessary if a validated container/packaging configuration provides the primary environmental control. The guide gives no mapping frequency for vehicles.

Status
Formal guidance
Applies to
Wholesalers (WDA), Transport
Last checked
18 October 2026
How do we qualify a refrigerated delivery van?Guidance

WHO Supplement 11 recommends a static mapping first to find hot and cold spots in the load space. This is followed by at least four tests: maximum and minimum payload in the warmest season, and maximum and minimum payload in the coldest season, ideally on a real worst-case route with multiple drops and door openings. The vehicle can be only provisionally qualified after the first season's tests, and fully qualified once both seasons are done, unless a test chamber is used to simulate them. An alternative is full qualification of each vehicle type plus an installation qualification for each new vehicle.

What's agreed, and what isn't

Requalification is expected after significant modifications and should be considered when monitoring shows unexplained variability. WHO sets no fixed interval.

Status
Formal guidance
Applies to
Transport, Wholesalers (WDA)
Last checked
18 October 2026
What are the temperature rules for transporting blood components?Guidance

Transit containers, packing materials and procedures should be validated to keep component surface temperature within range. Routine transport temperatures should be monitored periodically, with revalidation after any change to containers, packing or procedure. Containers should be equilibrated to storage temperature before filling, not exposed beyond their validated range and time, and dead air space minimised; melting ice must not touch components. For red cells the validated surface range is 2-10°C, with 10°C acceptable between supplier and hospital on one occasion of up to 12 hours. Donations intended for platelets must not drop below 18°C on the way from the donor session.

What's agreed, and what isn't

The Red Book accepts that red cells sometimes leave the supplier before they have cooled to 4 ±2°C. In that case the 2-10°C transport range may not be achievable and local judgement applies. A 2016 JPAC change notice used different wording, so use the live online Red Book.

Status
Formal guidance
Applies to
Blood, Transport
Last checked
18 October 2026
How do we prove veterinary medicines stay in range in practice vehicles and courier deliveries?Interpretation

VMD expects vehicle cold storage to be researched, tested and validated before use. Records should show when the unit reached temperature, when medicines went in, and that they were removed before any excursion. Where vehicle ambient temperatures may exceed 25°C, use validated insulated containers or active cooling. For deliveries, including by courier, send validated test parcels through the real service at least twice a year, ideally in very cold and very warm weather, on the highest-risk routes identified by risk assessment. The test should show how long the packaging holds and that deliveries arrive within that time.

What's agreed, and what isn't

A thermometer left in a packed parcel in a room does not count as a valid test. Delivery to parcel collection boxes must be included in the validation, and the VMD suggests that in some cases the safest option is not to use it. Responsibility stays with the supplying premises even when a courier gives assurances.

Status
Interpretation
Applies to
Veterinary, Transport
Last checked
18 October 2026
Do the blood storage rules apply to a hospital blood bank, or only to blood establishments?Law

They apply to hospital blood banks too. Regulation 9 requires the person managing a hospital blood bank to keep a quality system that gives effect to the EDQM Good Practice Guidelines (reg 9(1)(b)), make sure storage, transport and distribution conditions meet Part 4 of the Schedule, and validate all Part 4 processes that apply to its activities. Documentation must be available for inspection, traceability data must be kept for at least 30 years, and serious adverse event records for at least 15 years.

What's agreed, and what isn't

Regulation 9 does not itself specify how storage must be monitored (continuous, alarms, mapping); that detail comes in through the EDQM Good Practice Guidelines the quality system must give effect to. MHRA inspectors apply those, GMP-style expectations and the Red Book in practice. The 30-year requirement covers traceability data, not necessarily raw temperature logs, so a local retention decision is needed for those. For blood bank refrigerator and freezer temperature charts, the RCPath and IBMS retention guidance (6th edition, October 2025, section 6.1.5) says 15 years; that is professional guidance, not law. The retention table on the records and data integrity page compares the periods.

Status
Law
Applies to
Blood, Hospitals and wards
Last checked
18 October 2026
Does changing our insulated shipper or heating settings need formal change control in Ireland?Guidance

Yes, the HPRA GDP guide gives a change of insulated shipper for cold-chain products, a change to heating system settings and relocation of a storage area as examples of changes needing change control. Changes should be evaluated for impact on quality and traceability, including validation, and approved by relevant managers and the RP before implementation.

What's agreed, and what isn't

Such changes can also be mapping or qualification triggers under IA-G0011. The guide notes wholesalers working to other accredited standards should do a gap analysis against GDP.

Status
Formal guidance
Applies to
Wholesalers (WDA), Transport
Last checked
18 October 2026
If we outsource mapping, calibration or monitoring, who is responsible when it goes wrong?Guidance

You are. ICH Q10, 2.7 says the pharmaceutical company is ultimately responsible for processes that assure control of outsourced activities, with a written agreement between contract giver and acceptor. Management review should include feedback on outsourced activities (4.1), and deviations go through CAPA with effort proportionate to risk (3.2.2).

What's agreed, and what isn't

MHRA's 2015 GMP deficiency examples include mapping by a contractor that the company had not approved. Approve the protocol before the study, review and approve the report, and audit the supplier. For a monitoring platform, Annex 11 asks for formal agreements with suppliers and service providers (clause 3).

Status
Formal guidance
Applies to
Manufacturers, Laboratories
Last checked
19 October 2026
What temperature-related problems do MHRA GDP inspectors most often find?Interpretation

In the MHRA's published 2016 GDP deficiency data, a sample of 148 of 1,428 inspections, major findings under premises and equipment included the following. Mapping was not adequate to show the areas were suitable or to place thermometers at the extremes. Cold chain deviations were recorded but not put through CAPA. A warehouse thermometer had not been calibrated across its operating range. An ambient thermometer was installed so readings did not come from the calibrated probe. A fridge had ice build-up, read 0.6°C, and had unrecorded changes to its control dial.

What's agreed, and what isn't

This is the only GDP-specific deficiency report found on GOV.UK. The 2018 and 2019 deficiency files published on GOV.UK are GMP data, and later GDP data were not found. Patterns may have changed since 2016. The MHRA warns against focusing only on these deficiencies at the expense of risks specific to your business.

Status
Interpretation
Applies to
Wholesalers (WDA)
Last checked
18 October 2026

20-minute compliance check

How would you answer an inspector on temperature?

In 20 minutes we go through monitoring, alarms, mapping, calibration and excursions with you. You get the gaps in writing. No product tour.