1How many data loggers a mapping study needs.
No regulation fixes a number. WHO’s mapping supplement sets spacing and heights and leaves the count to arithmetic and risk:¹
- Length and width. A logger every 5 to 10 metres, or 20 to 30 metres in very large facilities, adjusted for alcoves, airflow and where product is stored; none may be needed where product never goes.
- Ceiling of 3.6 m or less. Three per grid point, high, medium and low, such as floor level, 1.2 m and 3.0 m.
- Ceiling above 3.6 m. Bottom, several in the middle, and top. WHO’s example for a 6 m store is 0.3, 1.8, 3.6 and 5.4 m. High-bay racking is “particularly susceptible to temperature stratification”.
- Extra positions. Centre pallets in a cold room; heating and cooling units, air outlets and existing sensors;¹ heaters, lighting, windows, doors, loading bays and mezzanines.²
- No active temperature control. WHO says such spaces “may also need” mapping;¹ EU GDP asks small room-temperature premises for a risk assessment of hazards such as heaters, with monitors placed to match.³
The MHRA puts the top logger at “the highest point of storage not the highest shelf or pallet location”.² This page counts points along a side as length ÷ spacing, rounded up, plus one, so the grid reaches both walls. Then:
Loggers = points along the length × points across the width × heights + extra positions.
| Space | Grid | Heights | Typical duration |
|---|---|---|---|
| Ambient warehouse | Every 5 to 10 m; 20 to 30 m if very large | 3 up to 3.6 m; more above | 7 days or more, in the warmest and coldest seasons |
| Cold or freezer room | Every 5 to 10 m, plus centre pallets | 3 up to 3.6 m | 24 to 72 hours |
| Chamber or freezer | No grid: top and bottom, front and rear | Within the cabinet | Long enough for compressor and defrost cycles |
2Example: counting loggers for a warehouse, a cold room and a chamber.
All three are invented.
2.1Warehouse W2: 57 loggers.
An ambient store for products labelled 15 to 25 °C, 30 m by 20 m, open plan, with racking that runs with the airflow and top loads at 5.4 m: WHO’s 10 m spacing, and four heights because racking this tall stratifies.
- Grid: 30 ÷ 10 = 3, plus one, is 4 points along the length; 20 ÷ 10 = 2, plus one, is 3 across. 4 × 3 = 12 positions.
- Heights: 0.3, 1.8, 3.6 and 5.4 m. 12 × 4 = 48 loggers.
- Extras: 2 dock doors and 2 heater outlets, problem areas the MHRA names;² one beside each of the 4 fixed monitoring probes, to compare readings; and one outside in the shade, since external temperature is one of three factors WHO says drive a store’s stability.¹ 2 + 2 + 4 + 1 = 9.
- Total: 48 + 9 = 57. At 5 m spacing the grid alone would need 7 × 5 × 4 = 140; at 10 m with three heights, 36.
| Plan view | 0 m | 10 m | 20 m | 30 m |
|---|---|---|---|---|
| Dock wall, 0 m | P01, D1, M1 | P02 | P03, D2 | P04, M2 |
| Middle, 10 m | P05 | P06, H1 | P07, H2 | P08 |
| South wall, 20 m | P09, M3 | P10 | P11 | P12, M4 |
2.2Cold room CR-1: 22 loggers.
A 2 to 8 °C room, 6 m by 4 m, 3.0 m high, shelved to 2.4 m, two pallets in the centre. At 5 m: 6 ÷ 5 rounds up to 2, plus one, is 3; 4 ÷ 5 rounds up to 1, plus one, is 2; 6 positions. Three heights, the top at 2.4 m, the highest stock: 18. Extras: 2 on the centre pallets, 1 in the evaporator’s air stream and 1 inside the door: 22. A full cold room qualification is worked in IQ, OQ and PQ.
2.3Stability chamber SC-3: 10 loggers.
A reach-in chamber held at 25 °C and 60% RH, with five shelves. WHO’s mapping supplement leaves out small equipment such as refrigerators and freezers, which are generally prequalified; its qualification supplement wants loggers “at the top and bottom of the cabinet as well as at the rear and front”, and no product on door shelves.¹⁴ Asked how many monitoring sensors a walk-in stability chamber needs, the MHRA replied that “There is no specific guidance on this”, and that the number “should be defined based on mapping studies, equipment capabilities and the capacity of the chamber”.²
- Layout. An illustrative choice, not a rule: the front and rear, left and right corners of the top and bottom shelves, 8; the centre of the middle shelf, 1; beside the chamber’s own sensor, 1. Each logs temperature and humidity, because WHO puts humidity monitors at the worst case in the qualified volume and the MHRA says mapping is how probe positions are found.⁶²
- Pass criteria. Every logger within 25 °C ± 2 °C and 60% RH ± 5% RH, ICH Q1A(R2)’s tolerances for this condition; door-opening spikes are “accepted as unavoidable”.⁷
- Tests. Health Canada’s list for refrigerators and freezers: empty and full loads, door-open, power-loss and alarm challenges, “sufficient duration in studies to capture compressor and defrost cycles”, and cool-down after a warm load.⁵ For small refrigerators and freezers the MHRA says the simulated load should represent what will be stored, and empty boxes are not appropriate.²
WHO’s qualification supplement covers ultra-low freezers too, and the MHRA sets the same mapping requirements for freezers as for refrigerators, so the same layout and tests serve them.⁴⁸
3Temperature mapping protocol template.
Copy these sections. WHO’s steps 1 to 5, from choosing loggers to marking their locations, must be done before the protocol is approved.¹
| Section | What it holds | Source |
|---|---|---|
| Approval and history | Author, reviewer, approver, versions; a contractor’s protocol authorised by your responsible person | S8 2.2.1¹ |
| Rationale | Why now: new, modified, periodic or unexplained readings | S8 1.1, 2.2.3¹ |
| Scope | Areas, empty or loaded, which seasons | S8 2.2.4¹ |
| Objectives | Hot and cold spots, no-storage zones, probe positions, remedial actions | S8 2.2.5¹ |
| Loggers | One type; 1 to 15 minute interval; 3-point calibration within ±0.5 °C; Part 11 software or equivalent | S8 2.1, step 1¹ |
| Site survey | Dimensions, racking, heating and cooling units, air outlets, existing sensors | S8 step 3¹ |
| Acceptance criteria | Label limits; door-opening frequency and duration; recovery time | S8 step 4¹ |
| Locations | Grid, heights, logger serial numbers, thermostat set points | S8 steps 5 to 7¹ |
| Execution | One interval and start time, conditioning, duration, door and power-cut log | S8 steps 7 to 9, 2.3¹ |
| Tests | The five tests in the next section | S7 2.2.3⁴ |
| Report | Summary, deviations, conclusions; annexes: survey, raw data, graphs, hot and cold spots, calibration certificates | S8 2.2.7¹ |
| Review | Independent peer review; contracted studies approved by whoever commissioned them | S8 2.4.5¹ |
3.1Who does what, and how long it takes.
- Protocol. Written from the site survey and approved, by QA or whoever your procedures name, before the study starts; a wholesaler’s Responsible Person should be “party to the whole mapping process”.¹²
- Set-up. One interval and start time; loggers fastened so they “cannot be damaged or displaced”.¹
- Runs. Seven consecutive days in each extreme season for an ambient store, so a first qualification spans about half a year; 24 to 72 hours for a cold room, each duplicate cooling unit running alone.¹ The MHRA expects the length justified “by way of a risk assessment of the storage area concerned”.²
- Report. Peer reviewed and approved;¹ probe moves and no-storage zones then go through change control.
4Tests, durations and acceptance criteria.
| Test | When | Duration | Pass when | Source |
|---|---|---|---|---|
| Empty mapping | OQ, before first use | At least 24 hours | Every logger within limits | S7 2.5.6⁴ |
| Loaded mapping | PQ, normal stock | As for OQ; ambient stores 7 days a season | Every logger within limits | S7 2.6.2;⁴ S8 step 9¹ |
| Door opening | Longest routine opening | Until recovery | Back in range in the set time, such as 30 minutes | S7 2.6.3⁴ |
| Power failure | OQ, empty | Until out of range, or a fixed time | No set criterion for rooms: record holdover and recovery | S7 2.5.7⁴ |
| Alarms | OQ | One high and one low test | Every notification route works | S7 2.5.5⁴ |
4.1Judgement calls the sources settle.
- No product to load yet. The MHRA suggests dummy product in a small empty area, and mapping again once it is fully stocked.²
- A logger lost or dead mid-study. WHO checks collected loggers’ serial numbers and locations against the installation notes, and puts deviation reports in the report’s annexes, which “may include a recommendation for partial or total re-mapping”.¹ The deviation should show that neighbouring loggers still cover the gap; if it was a likely extreme, such as a rack top, door or heater, re-map that zone.
- Peaks or means. WHO confirms true hot and cold spots from trends and averages, without disregarding readings outside the range.¹
- Humidity. EU GMP asks for special storage conditions such as humidity to be “provided, checked and monitored”, and WHO places humidity sensors “to monitor worst-case humidity levels within the qualified storage volume”, positions that mapping finds.⁹⁶
5Example: the mapping report and where the probes go.
Warehouse W2, fully stocked, was mapped from Monday 12 to Monday 19 January 2026 and from Monday 6 to Monday 13 July 2026: 57 loggers at a 5-minute interval, so 7 × 288 = 2,016 readings per logger per study, against 15.0 to 25.0 °C. The summer results decided the outcome:
| Logger | Min °C | Max °C | Mean °C | Finding |
|---|---|---|---|---|
| P12 at 5.4 m | 19.8 | 26.3 | 23.1 | Above 25.0 °C on 2 afternoons, 9 hours in all |
| P12 at 3.6 m | 19.5 | 24.8 | 22.6 | Hottest position inside the range |
| D2 at 1.8 m | 17.0 | 25.4 | 20.6 | Above 25.0 °C while loading; back in range within 20 minutes |
| P09 at 0.3 m | 16.8 | 21.2 | 18.7 | Lowest mean; 15.9 °C in January |
| M4 at 1.8 m | 19.1 | 24.1 | 21.5 | The fixed probe here never saw the heat above it |
| Outdoor | 11.6 | 33.8 | 21.4 | Reference only |
The recommendations follow WHO’s list of outcomes:¹
- Deviation DEV-26-118 for the 9 hours at P12; the stock there assessed as a temperature excursion.
- The top beam level at P12 closed to stock until its roof vent is rebalanced, then follow-up mapping in July 2027 to show the fix worked.
- Probes moved to the persistent extremes: M4 up to 3.6 m at P12, the hottest level still holding stock, and M3 down to 0.3 m at P09, the coldest by mean. WHO puts monitoring sensors at the greatest variability “within the qualified and/or tested storage volume”, so M4 rises to 5.4 m only if the 2027 mapping reopens that level, and keeps them “minimally affected by transient events such as door opening”, so none goes at D1 or D2.⁶
6When to re-map.
| Situation | Re-map? | Source |
|---|---|---|
| New store or equipment | Yes, before any product goes in | EU GDP 3.2.1;³ S8 1.1¹ |
| Layout or loading changed | Yes, if loading or air circulation may change | S8 1.1¹ |
| Cooling, heating or set point changed | Yes | EU GDP 3.2.1;³ S8 1.1¹ |
| Significant repair | Requalify | EU GDP 3.3.2³ |
| Unexplained variability | Consider it | S8 1.1¹ |
| Nothing has changed | At an interval a risk assessment sets and justifies | EU GDP 3.2.1;³ Annex 15 4.2¹⁰ |
WHO gives three years as an example, and where fixed monitors record continuously, says “a periodic re-evaluation which assesses all aspects of system performance since the initial mapping may be more appropriate”.¹ Nephron had one study, in January 2020, plus a three-year review of fixed-monitor data; the investigators still found it wanting, because “these monitor locations are not based on a scientific justification”.¹¹ Map both seasons first and put the monitors at the extremes found; then their data can carry the periodic review.
7What each regulator requires.
| Jurisdiction | Rule | What it asks |
|---|---|---|
| EU and UK wholesalers | EU GDP 3.2.1 | Map before use “under representative conditions”; monitors at the extremes; small room-temperature premises need a risk assessment |
| EU manufacturers | GMP Chapter 3.19; Annex 15 | Stores kept “within acceptable temperature limits”; qualified and requalified like any facility |
| US | 21 CFR 211.142(b), 211.46(b) | Storage “under appropriate conditions of temperature, humidity, and light”; temperature control where appropriate |
| Canada | GUI-0069 | Worst-case locations found by mapping, and monitored |
Part 211 does not use the word mapping, but FDA cites 211.142(b) when a warehouse runs hot, as in its warning letter to kdc/one Chatsworth of 8 September 2026.¹²¹³ USP’s 2023 chapter <1079.4>, Temperature Mapping for the Qualification of Storage Areas, covers the method, and FDA’s procedures say chapters numbered above 1000 are typically “considered informational and not requirements”.¹⁴¹⁵
8What inspectors cite.
“Temperature mapping exercises had not been adequately conducted, to establish the suitability of the storage areas or to determine the placement of the thermometers in the areas that experience the extremes of temperature fluctuations. No conclusion had been drawn as to the suitability of the storage areas.” MHRA GDP inspection deficiency data 2016, November 2017¹⁶
“Your firm did not establish worst case monitoring locations for the temperature monitoring done in your warehouse. The warehouse temperature mapping study is inadequate for the storage conditions listed on your finished drug product label.” Nephron Pharmaceuticals, Murray, Kentucky, warehouse, Form FDA 483, observation 4, 2 December 2022¹¹
A 483 records an investigator’s observations, not a final FDA decision. This one also faults missing data “to support the temperature sensor locations and heights chosen to demonstrate control throughout the warehouse during seasonal temperature fluctuations”: heights and seasons, not only a floor grid.¹¹
9How it runs in Seal.
In Seal, a mapping study can run as a commissioning and qualification test. The protocol is generated from an approved test design, executors scan each instrument with its calibration status at the time of use, and a failed acceptance becomes an exception tied to the exact requirement and evidence. The released baseline is then the reference for change control and periodic review, so requalification follows risk and evidence. If a logger later fails calibration, the mapping run it measured appears among its recorded uses for impact assessment.
Warehouse sensor data keeps its source identity, and an excursion opens a governed assessment with the exposed population already assembled, as in cold chain and temperature excursions.
References
- 1Temperature mapping of storage areas, Technical Supplement 8 to WHO Technical Report Series No. 961, Annex 9, sections 1.1, 2 to 2.5 and Annex 1, World Health Organization, May 2015. https:/
/ www. who. int/ docs/ default- source/ medicines/ norms- and- standards/ guidelines/ distribution/ trs961- annex9- supp8. pdf (read 8 November 2026) - 2Temperature mapping – an introduction, MHRA Inspectorate blog, 14 July 2016, with the MHRA’s replies to readers’ comments of 15 July 2016, 17 November 2016, 25 January 2017, 17 August 2017 and 6 November 2017. https:/
/ mhrainspectorate. blog. gov. uk/ 2016/ 07/ 14/ temperature- mapping- an- introduction/ (read 8 November 2026) - 3Guidelines of 5 November 2013 on Good Distribution Practice of medicinal products for human use (2013/C 343/01), sections 3.2.1, 3.3 and 3.3.2, European Commission, Official Journal C 343, 23 November 2013. https:/
/ eur- lex. europa. eu/ legal- content/ EN/ TXT/ HTML/ ?uri=CELEX:52013XC1123(01) (read 8 November 2026) - 4Qualification of temperature-
controlled storage areas, Technical Supplement 7 to WHO Technical Report Series No. 961, Annex 9, sections 1.1, 2.2.3, 2.5.5 to 2.5.7, 2.6.2, 2.6.3 and 2.7, World Health Organization, May 2015. https:/ / www. who. int/ docs/ default- source/ medicines/ norms- and- standards/ guidelines/ distribution/ trs961- annex9- supp7. pdf (read 8 November 2026) - 5Guidelines for environmental control of drugs during storage and transportation (GUI-0069), sections 5.1 and 5.5, Health Canada, issued August 2020. https:/
/ www. canada. ca/ en/ health- canada/ services/ drugs- health- products/ compliance- enforcement/ good- manufacturing- practices/ guidance- documents/ guidelines- temperature- control- drug- products- storage- transportation- 0069. html (read 8 November 2026) - 6Model guidance for the storage and transport of time- and temperature-
sensitive pharmaceutical products, WHO Technical Report Series No. 961, Annex 9, sections 4.5.2, 4.5.4 and 4.7, World Health Organization, 2011. https:/ / cdn. who. int/ media/ docs/ default- source/ medicines/ norms- and- standards/ guidelines/ distribution/ trs961- annex9- modelguidanceforstoragetransport. pdf (read 8 November 2026) - 7ICH Q1A(R2), Stability Testing of New Drug Substances and Products, section 2.2.7.1 and the glossary’s storage condition tolerances, ICH, Step 4 version of 6 February 2003. https:/
/ database. ich. org/ sites/ default/ files/ Q1A%28R2%29%20Guideline. pdf (read 8 November 2026) - 8Use of freezers, MHRA Inspectorate blog, 20 June 2017. https:/
/ mhrainspectorate. blog. gov. uk/ 2017/ 06/ 20/ use- of- freezers/ (read 8 November 2026) - 9EudraLex Volume 4, EU GMP Part I, Chapter 3: Premises and Equipment, section 3.19, European Commission, in operation since 1 March 2015. https:/
/ health. ec. europa. eu/ document/ download/ 18d76565- 137b- 41d2- a602- 794527f708c1_ en?filename=chapter_ 3. pdf (read 8 November 2026) - 10EudraLex Volume 4, Annex 15: Qualification and Validation, sections 3 and 4.2, European Commission, in operation since 1 October 2015. https:/
/ health. ec. europa. eu/ document/ download/ 7c6c5b3c- 4902- 46ea- b7ab- 7608682fb68d_ en?filename=2015- 10_ annex15. pdf (read 8 November 2026) - 11Nephron Pharmaceuticals, Murray, KY, warehouse, Form FDA 483 inspectional observations, FEI 3010247115, inspection 8 November to 2 December 2022, observation 4, FDA. https:/
/ www. fda. gov/ media/ 168157/ download (read 8 November 2026) - 1221 CFR Part 211, Current Good Manufacturing Practice for Finished Pharmaceuticals, sections 211.46(b) and 211.142(b), full text searched, eCFR. https:/
/ www. ecfr. gov/ current/ title- 21/ chapter- I/ subchapter- C/ part- 211 (read 8 November 2026) - 13kdc/one Chatsworth, Inc., warning letter, MARCS-CMS 733205, FDA, 8 September 2026. https:/
/ www. fda. gov/ inspections- compliance- enforcement- and- criminal- investigations/ warning- letters/ kdcone- chatsworth- inc- 733205- 09082026 (read 8 November 2026) - 14〈1079.4〉 Temperature Mapping for the Qualification of Storage Areas, USP–NF general chapter, United States Pharmacopeia, 2023, public preview of section 1. https:/
/ doi. usp. org/ USPNF/ USPNF_ M16681_ 02_ 01. html (read 8 November 2026) - 15MAPP 5019.1 Rev. 1, Allowable Excess Volume/Content in Injectable Drug and Biological Products, footnote 10, FDA Center for Drug Evaluation and Research, effective 28 January 2022. https:/
/ www. fda. gov/ media/ 155066/ download (read 8 November 2026) - 16MHRA GDP Inspection Deficiency Data 2016, EU GDP Chapter 3 deficiency examples, MHRA, November 2017. https:/
/ assets. publishing. service. gov. uk/ government/ uploads/ system/ uploads/ attachment_ data/ file/ 667494/ GDP_ 2016_ Deficiency_ data. pdf (read 8 November 2026)
AQuestions and answers
Do production areas and work-in-progress stores need temperature mapping?
Usually monitoring is enough in production rooms. The MHRA has explained that mapping may be needed where the product is temperature sensitive and extra controls are used, judged by how long the product is exposed at each step. That risk assessment can extend mapping to work-in-progress stores, such as blend or tablet core storage, because intermediates can sit there for long periods, and the mapping shows whether the routine monitoring positions represent the worst case.
Can the mapping data loggers stay in place as monitoring probes?
Only if they meet what a monitoring system must do, and only at the positions the mapping chose. WHO asks room monitoring to record at least six times an hour, keep working through a power failure and be checked twice a day; EU GDP asks for alarms that are tested. A logger set to the 15-minute end of WHO’s mapping range records only four times an hour, and WHO’s method downloads the loggers at the end of the study rather than reading them live. Keep fixed, alarmed probes at the hot and cold spots the report identifies.
Should a mapping study measure humidity as well as temperature?
Where the products need it. The MHRA has said that UK packs carry no stated humidity limits, so EU GDP does not require humidity in mapping and monitoring, though a store with a challenging environment may add it by risk. WHO ties humidity control to products labelled for dry storage that their packaging does not protect enough. If any product in the area carries a humidity condition, map and monitor humidity there too, as a stability chamber does.
