How to write a URS for pharmaceutical storage areas and TCUs

Author: Adam Hartmann-Kruckow, Co-founder of Eupry

Why do storage systems need their own URS?

Qualified storage areas and TCUs have compliance requirements that go beyond those of monitoring systems or mapping studies. They involve fixed infrastructure, HVAC integration, layout planning, controlled access, and security measures. Without a dedicated URS, critical facility‑specific requirements can be missed, leading to regulatory observations, operational inefficiencies, or costly remediation. A tailored URS ensures suppliers and internal teams have a shared, documented understanding of what is required for both compliance and operational performance.

Also read: How to create a URS for temperature mapping equipment and services.

What are the biggest challenges in developing a storage URS?

Developing a URS for qualified storage areas and TCUs that satisfies inspectors while being practical for day‑to‑day operations requires balancing science, regulations, and operational realities. The document must act both as an audit‑ready reference and a working tool for your teams.

Key challenges include:

• Including enough detail to satisfy regulatory inspections without over‑engineering: Overly complex requirements slow projects and drive up costs, while vague requirements risk non‑compliance.
• Defining measurable acceptance criteria tied to risk assessments: Clauses should be backed by product risk evaluations and environmental risk mapping.
• Coordinating input from multiple functions — quality, engineering, validation, and operations: Each function has its own priorities, so early alignment is essential.
• Addressing both equipment and facility considerations in one document: Many URSs fail because they focus too heavily on one aspect, creating compliance gaps.

How do you design a GxP‑compliant storage URS?

A robust storage URS integrates compliance, operational needs, and flexibility for future changes. Begin by mapping your operational requirements and aligning them with regulatory expectations, then translate those into measurable, auditable requirements.

Consider:

• Clearly defining the scope and objectives: State whether the URS applies to a cold room, warehouse, fridge, freezer, or ULT, and define intended use.
• Anchoring every clause in relevant regulations: This ensures defensibility during inspections and alignment with WHO GDP, EU GMP Annex 15, and ISPE guidance.
• Using measurable, unambiguous requirements: For example, “±0.5 °C accuracy” rather than “high accuracy.”
• Linking requirements to product risk and criticality: This ensures that resources are directed to the most critical controls.
• Building in flexibility: Plan for expansion, equipment replacement, or layout changes without triggering full requalification.

What should be included in a storage area URS?

Qualified storage areas such as warehouses and cold rooms must maintain environmental stability and protect against contamination or damage.

Your URS should outline:

• Environmental control ranges and tolerances: Define acceptable temperature and humidity limits and how they will be maintained and monitored.
• Mapping methodology, including seasonal requalification: Specify how temperature uniformity will be verified and requalified under different conditions.
• HVAC integration and redundancy: Define how backup systems will maintain conditions during equipment failure.
• Layout that supports airflow and uniform temperatures: Poor airflow can create hot or cold spots that threaten compliance.
• Security and controlled access measures: Outline how access will be restricted, monitored, and documented.

Also read: Developing a URS for your temperature monitoring system: Best practices, pitfalls, and templates

What should be included in a TCU URS?

Temperature‑controlled units such as fridges, freezers, and ULTs require precise control and redundancy to safeguard products.

A TCU URS should specify:

• Operating range and measurement accuracy: Define setpoints, ranges, and sensor accuracy requirements.
• Calibration and maintenance intervals: Include frequency, method, and adherence to calibration standards.
• Alarm functionality and escalation procedures: Specify trigger points, notification methods, and response timelines.
• Placement within the facility to ensure performance: Improper placement can compromise stability and airflow.
• Backup power or failover systems: Define how conditions will be maintained during power loss.

What mistakes should you avoid in a storage URS?

Common pitfalls in URS development often stem from failing to balance regulatory compliance with practical operations. Avoid:

• Using generic content that ignores site‑specific needs: Leads to compliance gaps and mismatched solutions.
• Failing to address HVAC or building system dependencies: Misses critical environmental stability factors.
• Leaving out acceptance criteria for mapping and monitoring results: Makes it harder to verify compliance.
• Neglecting scalability and change control: Creates requalification bottlenecks when facilities or equipment are upgraded.

These mistakes can lead to rework, delays, or regulatory observations. Linking the URS to ongoing thermal validation and preventive maintenance programs keeps it relevant and compliant.

What do WHO, ISPE, and other bodies require for storage areas and TCUs?

Regulatory frameworks set the baseline for compliant storage environments:

• WHO GDP: Requires validated storage processes, documented acceptance criteria, and formal change control.
• EU GMP Annex 15: Details qualification and validation requirements for facilities and equipment, supported by objective evidence.
• ISPE guidance: Recommends risk‑based strategies for mapping, monitoring, and environmental control.

Your URS should translate these high‑level principles into specific, measurable requirements for your facilities and TCUs.

Also read: Key regulations of temperature compliance