GDP Audit Checklist

This GDP Audit Checklist can be used by wholesale distributors of pharmaceutical products to assess and ensure compliance with Good Distribution Practices.

GDP Audit Checklist



Transportation

1. Does the company outsource transportation services or does the company transport in company-owned vehicles?


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2. Are vehicles cleaned and fit for purpose?


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3. Is temperature monitoring data for selected shipments provided?


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4. What is the organization's approach to planning transportation?


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5. Are drivers trained in GDP, do they have access to relevant written procedures?


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6. How are storage conditions ensured during transportation?


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7. What happens if storage conditions are not maintained during transportation?


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8. How are storage conditions maintained during temporary storage in hubs or reloading during transportation?


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9. What kind of additional control systems does the company have in place for the delivery of these products?


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10. Are there protocols or policies in place to address the occurrence of theft?


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11. Are narcotics or other products at high risk for theft appropriately handled?


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12. Are highly toxic or radioactive products appropriately handled?


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13. Are temperature-sensitive products appropriately handled?


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14. Who owns the vehicles used?


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15. How is equipment maintained and calibrated?


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16. How are the necessary storage conditions achieved within the vehicles?


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17. Has appropriate temperature mapping of each vehicle’s controlled storage area been performed?


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18. How is packaging chosen for the transportation of medicines?


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19. How are cool packs handled and packed?


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20. What information is part of transport labeling?


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21. Has each packaging configuration been appropriately qualified?


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22. Are all packages correctly labeled with all the relevant information, e.g., identity, source, handling, temperature, and storage conditions? 


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23. Have temperature-controlled containers or thermal packaging been fully qualified?


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24. Are narcotics or other products at high risk for theft handled?


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25. Are highly toxic or radioactive products handled?


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26. Are temperature-sensitive products handled?


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27. Are appropriate procedures available for handling high-risk narcotics, highly toxic, or radioactive products?


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28. Are procedures available for handling temperature-sensitive products?


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General

1. Is the content of the license/application accurate with the following: Procurement Holding/Storage Supply Export Contracted operation


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2. Is the content of the license/application accurate with any medicines the company may handle in line with national legislative definition?


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3. Have deficiencies from previous inspections been appropriately addressed in line with corrective/preventative actions (CAPAs) outlined in the company's response to previous inspection findings?


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4. Are changes to operations that may affect the risk profile of the organization e.g. premises, equipment, computerized systems, subcontracted activities, key personnel, and products handled? 


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5. Were changes managed in accordance with appropriate change control procedures?


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Change Control

1. Is there an appropriate procedure available?


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2. Is there a log of change requests raised in the period since the last inspection?


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3. Is there a classification in accordance with quality risk management principles?


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4. Were the changes notified and approved by the relevant authorities if it was required?


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Deviation Management

1. Is an appropriate procedure defining deviation management available?


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2. Is there a record of deviations raised in the period since the last inspection?


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3. Is there a classification in accordance with quality risk management principles and appropriately documented?


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4. Have appropriate CAPAs been taken to correct and prevent deviations?


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Management Of Outsourced Activities

1. Are any GDP-related activities outsourced?


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2. Have the principles of quality risk management been incorporated?


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3. How does the company initially approve a service provider?


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4. Is there a system for monitoring and reviewing the performance of contract acceptors?


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Management Review And Monitoring

1. Is there an appropriate procedure available?


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2. Is the outcome of the review documented and communicated internally?


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Quality Risk Management

1. Is there an appropriate procedure available?


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2. Have the principles been incorporated into the company’s management of change, deviations, complaints, and outsourced activities?


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3. Which processes identify risks to the quality of the product?


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Personnel

1. Is an organization chart available?


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2. Is the number of persons involved in wholesaling operations adequate or appropriate for the GDP operations?


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3. Are job descriptions available for key personnel?


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4. Does the job description reflect the key responsibilities?


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5. Have relevant personnel received initial and continuous GDP training?


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6. Are training records available?


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7. Are assessments conducted and documented?


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8. Is there a program for regular periodic training in GDP?


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9. Does the training program include aspects related to falsified medicinal products?


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10. Is specific training provided related to temperature-sensitive products and controlled drugs?


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11. Have personnel received training in SOPs relevant to their role?


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12. Are assessments conducted and documented?


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13. Is training provided in updated revisions to SOPs?


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14. Is specific training provided pertaining to medicines handled, e.g. related to temperature-sensitive, hazardous, radioactive products and controlled drugs?


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15. Is there an appropriate procedure in place covering health, hygiene, and clothing requirements?


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Premises And Equipment

1. Is there adequate lighting and ventilation in the storage areas?


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2. Is access to storage areas appropriately restricted to authorized personnel?


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3. Are rejected products, returned products, expired products, and recalled products physically segregated?


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4. Do procedures require falsified medicinal products to be physically segregated?


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5. Are products not authorized for the approved market physically segregated, even in cold storage areas?


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6. Are these areas clearly identified and demarcated?


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7. Are controlled drugs stored in accordance with national legislation?


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8. Are radioactive materials and other hazardous products stored in accordance with national legislation?


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9. Are the procedures and controls for the management of inbound and outbound goods appropriate?


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10. Are radioactive materials and other hazardous products, as well as products presenting a special safety risk of fire or explosion, stored in accordance with national legislation?


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11. Do receiving and dispatch bays protect products from prevailing weather conditions?


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12. Is there sufficient space/capacity to allow safe storage and handling of products?


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13. Are the storage areas appropriately maintained?


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14. Are there cleaning procedures and records available?


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15. Is there a pest control program in place?


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16. Are pest control records available?


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17. Are the rest, wash, and refreshment areas appropriately segregated from the storage areas?


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18. Are the environmental conditions monitored and are such records available?


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19. Has temperature mapping been conducted for the storage areas?


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20. Where required by local legislation, is humidity monitored and equipment appropriately verified?


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21. Were any hot spots or cold spots identified?


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22. Are these locations routinely monitored?


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23. Is there an appropriate procedure in place for handling/management of temperature excursions outside of predefined temperature limit extremes, and according to the written procedure? 


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24. Have the temperature monitoring devices been calibrated within the intended operating range?


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25. Is the continuous temperature monitoring data available?


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26. Are temperature alarms installed and tested regularly to ensure adequate functionality?


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27. Is there an appropriate procedure for handling temperature excursions?


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28. Is there a backup system in the event of fridge/cold room failure?


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29. Has temperature mapping been conducted for fridge/cold stores?


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30. Are the temperature monitoring devices positioned in the appropriate locations to monitor the storage condition? 


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31. Is there a program/schedule in place for planned maintenance?


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32. Are maintenance records available?


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33. Is there a program/schedule in place for calibration?


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34. Are the calibrations traceable to national/international standards?


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35. Are records of calibration available?


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36. Are alarm/alert systems in place to highlight temperature excursions?


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37. Are appropriate mechanisms or alarms in place to identify other deviations, where appropriate (e.g., automated equipment such as picking automation, A-frames, etc.) and how are these calibrated?


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38. Is there such a system in place that can ensure the integrity of the product in the event of equipment failure? 


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39. Is there a list of computerized systems available?


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40. Are systems validated or tested?


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41. Is user access restricted by role?


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42. Is the computer system auditable?


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43. Are detailed descriptions of the systems including diagrams available?


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44. Are appropriate security controls in place to prevent unauthorized access?


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45. Is access to stored data checked on a periodic basis?


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46. Are appropriate backup procedures in place?


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47. Is there an appropriate procedure for power loss and disaster recovery of data?


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48. Has the company identified which equipment is required to be qualified and which processes to be validated?


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49. Have principles of quality risk management been used to determine the extent of qualification and validation required?


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50. Are the risk assessments available?


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51. Are the qualification/validation reports available?


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52. Have deviations been recorded and addressed?


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53. Have the qualification/validation reports been completed and approved prior to the use of the equipment?


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54. Are there criteria and appropriate procedures established for requalification and revalidation?


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Documentation

1. Is there an index of procedures available?


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2. Are procedures approved and dated by relevant personnel?


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3. Is version control in place?


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4. Are the correct and current procedures available in the work areas?


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5. Are procedures reviewed periodically? 


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6. Are appropriate controls in place for the process of updating documents?


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7. Are invoices available for purchases and sales?


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8. Are delivery slips/orders available?


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9. Are records stored in a manner to ensure they are protected from loss or damage?


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10. Do the records demonstrate full traceability of goods, from purchase, transportation, receipt, and onward sale?


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11. Are archived documentation appropriately stored and accessible?


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12. Are records made in a clear, legible, and indelible manner?


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13. Are customs documentation available, where applicable?


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Operations

1. Is there a list of approved suppliers available?


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2. Is there an appropriate procedure for supplier qualification/approval?


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3. Have checks of suppliers been done to verify the authority of suppliers to supply the classifications of medicinal products received?


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4. Have ‘due diligence’ checks been conducted?


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5. Are periodic checks conducted using the principles of quality risk management? 


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6. Are records of the above checks available?


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7. How do you ensure that the supplies of medicinal products are obtained only from persons/organizations who are in possession of a valid wholesale distribution authorization or manufacturing authorization?


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8. Is there a list of qualified customers available?


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9. Is there an appropriate procedure for customer qualification and approval including requirements for the opening of a new account?


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10. Have checks been done to verify the authority of customers to receive the classifications of medicinal products supplied?


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11. Are the records provided?


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12. Are periodic checks conducted using the principles of quality risk management?


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13. Are records of the qualification of each customer available?


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14. For products at risk of diversion, is there a monitoring system for all sales?


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15. Is there an appropriate procedure for investigating irregularities in sales patterns?


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16. How do you ensure that medicinal products are only supplied to persons/organizations who are in possession of a valid distribution authorization or who are authorized or entitled to supply to the public?


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17. Is there an appropriate procedure in place for goods receipt to include checking against a purchase order? 


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18. Are records of the receipt of goods available?


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19. Are records of the temperature conditions during transportation available?


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20. Are records of routine stock checks and any subsequent investigations available?


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21. Are there checks to ensure goods have been authorized for sale?


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22. Do procedures for receipt of goods require the person checking the goods to consider whether the goods may be falsified?


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23. For products with special storage requirements, are checks conducted at receipt to ensure correct storage conditions have been maintained during transportation?


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24. Is there an appropriate procedure for handling non-conforming products at receipt?


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25. Is stock rotated in accordance with the First Expiry First Out (FEFO) principle?


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26. Is there a system in place to ensure products that expired or nearing the expiry date are removed from saleable stock?


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27. Are provisions in place to ensure products are not stored directly on the floor? Are stock inventories checked periodically and appropriate investigation of irregularities conducted?


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28. Are stock records available?


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29. Are appropriate procedures in place for handling products with special storage conditions?


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30. Are medicines segregated or protected from harmful substances?


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31. Is access to the premises and storage area appropriately controlled?


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32. Does the company employ security measures, e.g., alarm systems, CCTV, locker searches, and person searches? Are alarms linked to personnel, security, and police?


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33. Does the company vet personnel within sensitive areas, e.g., controlled drug storage areas?


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34. Does the company require any additional security measures relating to the nature of their business, to protect medicines and public health? E.g., controlled substances, vaccine handling, etc.


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35. Is there an appropriate procedure for handling material for destruction?


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36. Is a storage area for expired and/or obsolete goods available and is it appropriately segregated and labeled?


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37. Are records available for products that have been destroyed?


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38. Are controls in place to ensure the correct product is picked?


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39. Is there a check to ensure sufficient shelf life remaining?


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40. Have delivery notes, and packing lists been provided with the products supplied?


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41. Are supply records available?


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42. Are appropriate procedures in place for import and export activities?


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Complaints, Returns, Suspected Falsified Medicinal Products And Medicinal Product Recalls

1. Is there an appropriate procedure for handling complaints and who is responsible?


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2. How are complaints recorded and investigated?


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3. How are complaints received by the organization and how are they handled upon receipt?


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4. What mechanisms are in place to distinguish service and quality complaints?


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5. What mechanisms are in place to protect against falsified medicinal products when assessing complaints?


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6. How are complaints escalated, in case of a product quality defect?


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7. How is an investigation of a complaint closed?


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8. From whom does the company accept returns?


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9. Is there any access restriction for the returns area?


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10. Does the company have an appropriate procedure for handling returns?


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11. Is this procedure risk-based?


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12. How does the company perform an assessment of returned products?


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13. Who is responsible for different stages of the returns process?


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14. How does the company handle returns of products requiring specific storage conditions?


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15. How is FEFO maintained?


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16. What are the appropriate procedures that cover vigilance against falsified medicinal products?


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17. How does the company assess risk to medicines handled by the company where the risk of falsification is higher?


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18. How was this list compiled?


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19. Is a review of the paper/documentation audit trail for the purchase of high-risk products from other wholesalers done?


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20. Is a review of product ownership in relation to movement done?


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21. Is a review of dispatch documents vs. receiving documents. done?


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22. Are purchase discounts provided since the last inspection?


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23. Is a sample of purchase orders cross-checked for these products against the seller’s wholesale authorization?


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24. What procedures are in place to identify potentially falsified medicinal products when receiving goods returned from customers?


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25. Has the company received unsolicited offers of products at cheaper prices?


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26. Has the company received deliveries through unusual means, e.g., unmarked vans?


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27. How does the company report suspicious approaches concerning the purchase of medicinal products to the competent authority?


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28. Are the appropriate procedures for handling recalls provided?


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29. Are there records of recalls that have been received and assessed/undertaken by the wholesaler?


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30. How do you ensure recalls can be actioned in a timely manner at any time, e.g., able to be actioned at any time day or night?


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31. How does the company communicate recalls to the customer?


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32. Are the roles and responsibilities of staff clearly defined? Is it explained how the company liaises with the competent authority/marketing authorization holder before any recall action is undertaken?


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33. Is there a clear and effective process for the identification and traceability of products subject to recall?


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34. How does the company handle and segregate recalled products in the warehouse?


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35. Are arrangements explained for the return of recalled medicinal products to the MA holder/or destruction?


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36. Is a final report of the recall activity (including reconciliation and destruction) recorded?


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37. How and how often does the company challenge the recall procedure?


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38. How does the company check for active product recalls? From where is information regarding recalls received?


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Outsourced Activities

1. Are quality agreements in place and are these being followed for all related activities?


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2. Are current contracts reviewed with service providers and relevant details to the business model and activities described assessed?


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3. Are audits allowed in the contract?


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4. Is the audit schedule shown?


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5. How does the company ensure that no work is handed off to a third party without their knowledge?


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6. Is there a process to manage the quality of products or services? Are there records available?


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7. Are there records and examples of cases where the quality of a product or service was in question?


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Self-Inspections

1. Is your appropriate procedure provided for self-inspection?


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2. Is your self-inspection plan provided?


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3. Are self-inspections performed in accordance with local procedures and as scheduled?


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4. How are auditors selected?


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5. How are personnel trained to perform self-inspections?


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6. How does the company ensure that the auditor is independent of the area being inspected?


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7. What is the process for the timely rectification of any issues identified?


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8. How are CAPAs verified as being effective?


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Checklist by GoAudits.com – Please note that this checklist is intended as an example. We do not guarantee compliance with the laws applicable to your territory or industry. You should seek professional advice to determine how this checklist should be adapted to your workplace or jurisdiction.

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