Showing posts with label PV. Show all posts
Showing posts with label PV. Show all posts

May 7, 2022

Pharmacovigilance trainings: four basic considerations for establishment of training environment

Pharmacovigilance trainings: You love it or hate it, but can not ignore it 

Yes, you read it right! You love it or hate it but can not ignore it. If someone says WHY? The reason is quite clear and simple..it is regulatory requirement👮

Need to understand further refer my previous blog "Pharmacovigilance Trainings: a succinct summary from GVP Modules"

First thing we need to understand that pharmacovigilance trainings fall under pharmacovigilance quality systems (GVP Module I – Pharmacovigilance systems and their quality systems) (consider it serious as other pharmacovigilance process).  

Below mention four basic considerations will save you from future observation from audit (internal/external) or regulatory inspection

Let's discuss some of them one by one - 

1. All person involved in pharmacovigilance training should receive initial and follow-up continuing trainings whether new or existing employee. 

New Employee: - New employee should undergo all necessary trainings according to job role and training plan. 

Let's understand this with possible trainings case processor/data entry role

  • Pharmacovigilance (PV) Trainings - Introduction of MedDRA and MedDRA coding, MedDRA  Term Selection: Points to Consider, Module VI – Collection, management and submission of reports of suspected adverse reactions to medicinal products, ICH Guidelines (ICH E2A, ICH E2B and E2D at least)
  • Quality Perspective Trainings: GVP Module I- Pharmacovigilance systems and their quality system, Case level quality and Field level quality parameters or fields from the database, Organizational quality policy
  • Audit and Inspection Specific Trainings: Module-III - Pharmacovigilance Inspections and Module IV- Pharmacovigilance Audits
  • MAH/Organization specific controlled documents Trainings: Standard Operating Procedures (SOP), Work Instructions (WI), Job-Aid, Policy, Any other document deemed important by respective Marketing Authorization Holder (MAH) or organization.
  • Human Resource Trainings (not direct relation with pharmacovigilance but essential to understand organization DNA and work environment)
  • Database Trainings
  • Trainings assessment methodology 

Existing Employee: 

  • Training upon new introduction of controlled documents (SOP/WI/Job-Aid/Policy)
  • Change or update in regulatory guidelines
  • Change in PV database functionalities 
  • Changes/Updates in Safety Data Exchange Agreements (SDEA)- MAH, Distributors and Manufacture type
  • Trainings related to outcome of audit or findings of regulatory inspection
  • Quality related re-trainings
  • Periodic refresher trainings
2. Training plan and Training records- documented evidences that  proves person undergone sufficient relevant trainings which demonstrate competency for assigned job role

3.  Training of Non-Pharmacovigilance Persons - Any person who directly or indirectly involved in receipt of any type of safety information (which includes company's sales representative, receptionist, persons handling company's social media, HR & Admin, etc.)

4. If any organization uses training software or portal then relevant user manual or work instruction, audit trail, system generated outputs including compliance reports, user access management process, training allocation handling process is advisable to have documented.

In short, all staff should be appropriately trained with evidences of their training (theoretical and practical) in ongoing manner. 

     


Sep 2, 2020

Marketing Authorization Holders (MAH) should know these 10 things from BREXIT- MHRA Guidance on Pharmacovigilance Procedures

 MHRA has published updated guidance on pharmacovigilance procedures on 01 September 2020 and new rules will be effective from January 2021 (post-Brexit transition period comes to an end this year).

1. General Approach to the operation of pharmacovigilance

This document outlines the submission requirements of pharmacovigilance data from 01 January 2021. There will be some different requirements for products placed on the market in the UK with respect to Great Britain (England, Wales and Scotland) and Northern Ireland. Products placed on the market in Northern Ireland will need to be in line with EU legislation and follow EU requirements.

The Marketing Authorization Holder (MAH)  of products authorized in Great Britain need to follow pharmacovigilance data submission requirements as per MHRA.

  •          UK and non-UK Individual Case Safety Reports (ICSRs)
  •          Periodic Safety Update Reports (PSURs)
  •          Risk Management Plans (RMPs)
  •          Post-Authorization Safety Studies (PASS) protocols and final study report

The Good Vigilance Practices (GVP) modules will remain in force but MHRA will publish a guidance note on the exceptions and modifications to the EU guidance on good vigilance practices in due course.

For medicines authorized to be sold or supplied in Northern Ireland information will need to be submitted according to EU requirements.

For medicines which are the subject of a UK MA covering both Great Britain and Northern Ireland, information will need to be submitted in accordance with requirements for both Great Britain and the EU, as appropriate.

MHRA may ask historical data for assessment purpose.

2. Actions for submitting and receiving ICSRs

Submission of all UK ICSRs (serious and non-serious) and serious ICSRs from other countries via the new MHRA Gateway or/ICSR Submissions portal which have been developed.

MAH can register on the MHRA-Gateway and/or ICSR Submissions portal to enable configuration for their systems prior to 1 January 2021.

For products placed on the market in Northern Ireland MAH will need to submit ICSRs according to EU requirements to the Eudravigilance database.

 3. Signal detection

MHRA will not require MAH to conduct signal detection against MHRA database. MAH also obliged to notify MHRA of signals arising from any data source. From 1 January 2021 this also includes standalone signal notifications submitted by MAH to the EMA that are relevant to MAH products as well as signals raised by the EMA.

For products placed on the NI market, MAH additionally needs to report to the EMA those safety signals that are considered to meet the definition of an emerging safety issue (see GVP-Module IX Signal Management).

From 1 January 2021 the MHRA will carry out assessment of signals and issue decisions for both signals identified by the MHRA and those highlighted internationally.

Notify MHRA about emerging safety issues within 3 working days after establishing that a signal or a safety issue from any source meets the definition of an emerging safety issue.    

 4. Risk Management Plans (RMPs)

The MHRA will continue to accept EU versions of the RMP. On scenario where specific request made by MHRA then information to be included this may need to be provided in a specific annex.

For CAPs the current approved version of the RMP should be included in the initiating sequence as part of the conversion process.

RMPs and updates to RMPs for products authorized to be sold or supplied in the UK should be submitted to the MHRA, via the appropriate variation procedure.

5. Periodic Safety Update Reports (PSURs)

5.1 PSURs submitted after 1 January 2021

The MHRA will continue to accept EU versions of the PSUR, but where the MHRA has made a specific request for information or where there is UK-specific information relevant to the benefit/ risk assessment this should be included in a specific annex.

MHRA may develop their own submission requirements and develop a list of UK reference dates, but until this happens the EU reference date (EURD) list should be followed and PSURs, with submission dates after 1 January 2021, should be submitted to the UK at the same time as submission to the EU.

All PSURs, for products which are the subject of a UK MA, with the same active/combination, should be submitted as part of the same procedure. The content and format will remain the same as currently required in the EU, and the expectation is that the same PSUR will be submitted to the MHRA as to the EU.

Unless the marketing authorization specifies differently, PSURs for actives/combinations not currently on the EURD list and therefore not subject to the single assessment process should be submitted to the MHRA, at least six monthly during the first 2 years following placing on the market, once a year for the following 2 years and every 3 years after that.

MHRA will issue the outcomes of assessments shortly after publication of the EU assessment, at the latest, in order to maintain harmonization with the submission requirements on the EURD list. submission requirements, where appropriate.

MHRA has developed their own submission portal for PSURs which will be ready for use from 1 January 2021. More detailed requirements for submission will be issued but PSURs can be submitted to the portal in PDF or Word or as part of a zip file format. PSUR submissions will not be required as part of the CTD lifecycle in the UK and should not be submitted as part of the initiating sequence in the conversion process for centrally authorized to Great Britain MAs.

A fee of £890 will be payable for the assessment of PSURs for actives/ combinations currently listed on the EURD (or future UK reference date list) which are submitted to the MHRA. There will be a reduction to £445 for each PSUR where more than one PSUR is involved in the procedure.

Following assessment, MHRA will publish the outcome of PSUR assessment procedures including any amendments to the SPC and PL wording. No further fee will be payable for the amendment of the product information as a result of the UK assessment which will generally be made by a Type IA variation.

For Great Britain-only MAs the PSUR should be submitted to the MHRA system.

For products authorized to be sold or supplied in Northern Ireland, PSURs should be submitted in line with EU requirements and submitted to the EMA via the EU PSUR repository. The outcomes from the EU procedure should be implemented.

PSURs for UK MAs covering both Great Britain and Northern Ireland will need to be submitted to both the MHRA and EMA.

 5.2 PSURs submitted before 1 January 2021

For Great Britain-only MAs where a PSUR has been submitted before 1 January 2021 but the EU single-assessment procedure has not been concluded, MHRA will assess the PSUR considering any relevant information, including any EU decision and may request further information, where appropriate, in order to conclude the assessment.

Where the PSUR is for a product authorized by a UK MA, in respect to both Great Britain and Northern Ireland the procedure will continue in line with the single-assessment procedure.

 Where the assessment has been concluded but the outcome not implemented before 1 January 2021, the MHRA will take the necessary steps to implement the outcome.

6. Post Authorisation Safety Studies (PASS)

6.1 PASS protocols and results submitted after 1 January 2021

For PASS where the study is a condition of the UK MA, prior to the start of the study the draft protocol should be submitted to the MHRA and will be assessed in line with usual practices. Where the MA extends to Northern Ireland or is an Northern Ireland only MA the draft study protocol should also be submitted to the Pharmacovigilance Risk Assessment Committee (unless the study is only to be conducted in the UK at the request of the MHRA).

 For all PASSs that are non-interventional, that are either voluntary or a condition of the MA and that involve collection of safety data from patients/healthcare professionals MAH should send the final study reports to the MHRA for assessment

MAH should submit the final study report (and abstract of study results) to the MHRA. Where the MA extends to Northern Ireland or is a Northern Ireland only MA the study report should also be submitted to the Pharmacovigilance Risk Assessment Committee (unless the study was only conducted in the UK at the request of the MHRA).

The final study report should be submitted within 12 months of the end of data collection. The fee for assessment of PASS protocols or final study reports is £8,309. Both protocols and final study reports should be submitted to us using the Type II complex variation route (classification C.I.13) with the corresponding fee.

 6.2 Ongoing issues regarding PASS protocols after 1 January 2021

For products authorized in the UK where the EU PRAC (Pharmacovigilance Risk Assessment Committee) has either endorsed a draft study protocol or made a substantial amendment to a draft protocol before 1 January 2021, MHRA will accept the draft or the amended draft study protocol but may request that further information is submitted to us within a specified time.

Where a non-interventional PASS has been proposed or imposed but the draft protocol has not been endorsed prior to 1 January 2021, any information required by the PRAC, together with any information required by the MHRA regarding the protocol must be submitted directly to the MHRA. This must happen even if the information was submitted via the EU procedure prior to 1 January 2021. The MHRA will then assess the information in line with the usual procedures.

6.3 Ongoing issues with PASS final study reports after 1 January 2021

For products authorized in the UK, where a final study report was submitted to the EMA before 1 January 2021 but no recommendation was made before that date, it may be required that the study report and abstract of the study report are submitted to the MHRA together with any further information relating to the study. In any event MAH should evaluate the impact of the results on the authorization and submit a variation application as necessary.

Where PRAC made a recommendation prior to 1 January 2021, the MHRA will implement the agreed measures in line with the agreed timetable. MAH should submit any variation to us (for converted CAPs please refer to the guidance on our website and MHRA will determine the application within the usual timeframes).

7. Safety Referrals

For procedures started but not concluded before 1 January 2021, such as where a CHMP/CMDh opinion had not been reached the MHRA will complete the assessment, where appropriate, and make a decision on the procedure based upon the information, including any decision made at EU level prior to 1 January 2021. MHRA may request further information regarding the procedure on a case-by-case basis where deemed appropriate and take the necessary steps to implement the decision.

Where the the referral has been concluded but the decision not implemented before 1 January 2021, the MHRA will take the necessary steps to implement the final decision.

8. Major Safety Reviews

From 1 January 2021, where there are concerns regarding a medicine or class of medicines that are authorized in the UK, the MHRA may conduct a major safety review to review the available data and consider what regulatory action may be needed.

In these circumstances, MHRA will publicly announce the initiation of the review, outlining the reasons for the review, the list of affected active substances and products, and the timescales for the review.

Where MAH holds a MA for an affected product, MAH will be notified of the start of and reasons for the review. List of questions will be provided that should be addressed by all MAHs along with the deadline by which the requested information should be submitted.

In the first instance, this correspondence will be done via the Qualified Person for Pharmacovigilance (QPPV) but a different or additional contact for future correspondence can be nominated.

The outcome of the review will be published. Where the recommendations include proposals for regulatory action the details of the measures to be taken including any changes to the product information will be published.

 A major safety review will incur the following fees for assessment: 

  • £51,286 where one or two active ingredients or combinations of active ingredients are included
  • £59,595, where three active ingredients, or combinations of active ingredients, are included
  • £67,904, where four active ingredients, or combinations of active ingredients, are included
  • £76,213, where five or more active ingredients, or combinations of active ingredients, are included

Where the review relates to 2 or more authorizations, the fee will be divided by the number of authorizations forming part of the review and MAH will pay that reduced fee for each relevant authorization it holds.

9. Post-authorization Measures (PAMs)

Post-authorization obligations, including specific obligations, Annex II conditions, additional pharmacovigilance activities in the RMP (MEA), legally binding measures (LEG) or recommendations, in place on 1 January 2021 will remain in place.

For converted EU MAs MHRA recommends that MAH need to use the current application forms for PAMs and submits the information to us as a post-authorization commitment, following the same principles for submission as for variations in the CAPs conversion guidance.

Where data relating to a PAM has been submitted before 1 January 2021, but the assessment has not been concluded MHRA will conclude the assessment where appropriate. For converted EU MAs a copy of the application should be included in the data submission package.

Where MAH evaluation of data supporting a MEA or LEG suggests that an update to the product information is required this should be submitted via a Type II variation application.

10. Implementation of outcomes of referrals and procedures concerning PSURs, PASS, signal assessments and PAMs

Where an amendment to the product information is required as a result of the above procedures, this will be implemented via a variation procedure. Where the the procedure has been concluded before 1 January 2021, but the variation has not been submitted, the outcome will be implemented by the same procedure as for the EU (Type IA, Type IB or Type II).

Where the variation has been submitted, but not finally processed before 1 January 2021, the variation will be concluded in line with the outcome of the procedure.

Where there has been no EU decision before 1 January 2021, MHRA will carry out assessment where appropriate and the outcomes of assessments will be published together with advice on implementation

Source: MHRA Updated guidance on pharmacovigilance procedures, Published 01 September 2020                      

Dec 16, 2018

Pharmacovigilance Abbreviations / Acronyms


Term Description
ADCO Addendum to Clinical Overview
ADRs Adverse Drug Reactions
AE Adverse Event
AERS Adverse Event Reporting System
ANDA Abbreviated New Drug Application
ATC Anatomical Therapeutic Chemical  (in Anatomical Therapeutic 
Chemical
Classification System)
ATMP Advanced Therapy Medicinal Product
CAPA Corrective And Preventive Action
CCDS Company Core Data Sheet
CCSI Company Core Safety Information
CHMP Committee for Medicinal Products for Human Use
CIOMS Council for International Organizations of Medical Sciences
CMDh Coordination Group for Mutual Recognition and Decentralised
 Procedures - Human
CMS Concerned Member State
CRO Contract Research Organization
CT Clinical Trial
CTD Common Technical Document
DCP Decentralised Procedure
DDD Defined Daily Dose
DHPC Direct healthcare professional communication
DIBD Development international birth date
DLP Data Lock Point
DME Designated Medical Event
DSUR Development safety update report
DUS Drug Utilization Study
EMA European Medicine Agency
EU European Union
EURD European Union Reference Date
EV Eudravigilance
FDA Food and Drug Administration
GCP Good Clinical Practice
GMP Good Manufacturing Practice
GVP Good Pharmacovigilance Practice
IB Investigator´s Brochure
IBD International birth date
ICH  International Council for Harmonisation of Technical Requirements for 
Pharmaceuticals for Human Use
ICSRs Individual Case Safety Reports
IME Important Medical Event
IND Investigational New Drug
INN International Non-proprietary Name
LBI Late Breaking Information
MA Marketing Authorisation
MAH Marketing Authorisation Holder
MedDRA Medical Dictionary for Regulatory Activities
MHRA Medicines and Healthcare Products Regulatory Agency
MRP Mutual Recognition Procedure
NAP National Authorised Product
NCA National Competent Authority
NDA New Drug Application
PASS Post-authorisation safety study
PBRER Periodic Benefit-Risk Evaluation Report
PI Product Information
PIL Product Information Leaflet
PL Package Leaflet
PRAC Pharmacovigilance Risk Assessment Committee
PSMF Pharmacovigilance system master file
PSUR Periodic Safety Update Report
PSUSA Periodic Safety Update Single Assessment
PT Preferred Term
PTD Patient Treatment Days
PTY Patient Treatment Years
PV Pharmacovigilance
QPPV Qulified Person responsible for Pharmacovigilance
REMS Risk Evaluation & Mitigation Strategies
RMM Risk Minimisation Measure
RMP Risk Management Plan
RMS Reference Member State
RSI Referenced Safety Information
SAE Serious Adverse Event
SAR Serious Adverse Reaction
SDEA Safety Data Exchange Agreement
SmPC Summary of Product Characteristics
SMQ Standardized MedDRA Query
SOC System Organ Class
SOP Standard Operating Procedure
TSSS Tabular Summary of Safety Signals
WHO World Health Organization 
XEVIMPD Extended EudraVigilance Investigational Medicinal Product Dictionary
XEVPRM eXtended EudraVvigilance Product Report Message