Pharmacovigilance and Drug Safety

The first part in our series discussed the minimum requirements for the professional training and experience for an EU Qualified Person (QPPV) for pharmacovigilance services throughout the EEA. The second part of our series moves onto the responsibilities held by each QPPV for manufacturing and initial quality control verification, which will begin to explain why their appointment is obligatory within any pharmaceutical company’s pharmacovigilance services. In order to do this, we are going to examine the exact specifications contained within Directive 2001/83/EU, the law providing the primary definition of the role of all QPPVs.

Why are QPPVs so important?

Any pharmaceutical company wishing to market any medical product (eg- a pharmaceutical medicine) within the EEA must become a Marketing Authorisation Holder (MAH) for each and every individual product placed onto the market. The granting of a Marketing Authorisation (MA) can be seen as an exercise in public protection in that it requires that a comprehensive and appropriate pharmacovigilance system is established and maintained for each individual product before, during and after it is ever placed on the EEA market. And one key element of the laws governing the Marketing Authorisation is the stipulation without exception that a QPPV must be appointed to fulfil certain crucial roles within that pharmacovigilance system.

Manufacturing and initial quality control

PPVs are highly qualified, highly skilled professionals who are charged with a variety of roles defined within Article 51 of Directive 2001/83EC. Each country within the EEA must be certain that a QPPV is fulfilling a number of roles for each MAH. They must ensure that all medicinal products which have been manufactured within the country in question have been produced and checked in full compliance with the laws of that country. They must furthermore ensure that the manufacturing and checking process also meets the requirements of the MA legislation.

Should the medicinal products in question be sourced from another country, the QPPV must verify that each production batch has been subject to testing conducted within the (recipient) country for:

• A comprehensive quantitative analysis of the product as a whole
• A comprehensive quantitative analysis of the product’s active substances as an absolute minimum
• All other quality testing and/or verification procedures required by the MA

Should the company wish to market the product in another EEA country, providing it has been subjected to the above three quality control criteria, it does not need to be re-subjected to those criteria in the ‘new’ country. As you might expect, this allowance is only permissible providing the correct reports are available, signed off by the QPPV in the ‘original’ EEA country concerned.

If the medicines or medicinal products have been sourced from a third EEA country, it is necessary to verify that the quality controls upheld by the manufacturing process (and by necessity therefore the elements of pharmacovigilance services) were appropriate. The standards should be at least equivalent to the QPPVs work of verifying that the product has been subjected to quantitative analysis; its active components have been subjected to quantitative analyses; and that all other quality control testing has taken place in compliance with the requirements of the MA.

The law is very practical and does recognise those cases where the QPPV would be duplicating quality control work already performed and verified within suitable settings in other countries. Should the quality controls we have already discussed have been carried out correctly and to equivalent standards within the country of origin, under a formal arrangement with EU authorities, documentation alone becomes the issue for those products. The law does not require the QPPV to perform a second round of quality control here, since it has simply already been done.

In summary, the duties above represent only a ‘layman’s guide’ to the exacting stipulations of Directive 2001/83/EU – quality professional pharmacovigilance advice is individually tailored to each situation as it arises. Having said this, it does help to understand the initial stipulations of 2001/83/EU, since it becomes clear that there is no other professional within any pharmaceutical company who is able by law to fulfil their duties. The next part of our series about the work of the QPPV within pharmacovigilance services moves onto examining their role in ensuring quality control for each real life batch of medicine sold within the EEA as the product lifespan unfolds.

Adverse Drug Reaction (ADR)
A response to a medicinal product which is noxious and unintended and which occurs at doses normally used in man for the prophylaxis, diagnosis or therapy of disease or for the restoration, correction or modification of physiological function. A causal relationship between the medicinal product and an AE should at least be a reasonable possibility.  An ADR in post-marketing situations normally refers to ADRs occurring at therapeutic doses, but for the purposes of reporting any dosage should be considered.

Adverse Event (AE)
Any untoward medical occurrence in a patient or clinical investigation subject administered the pharmaceutical product that does not necessarily have to have a causal relationship with the treatment for which the product is used. An AE can therefore be any unfavourable and unintended sign (including an abnormal laboratory finding), symptom or disease temporally associated with the use of the medicinal (investigational) product, whether or not considered related to the medicinal (investigational) product. A pre-existing condition which, worsened in severity after administration of the product would also be considered as an adverse event.

For clinical studies, the definition of an Adverse Event includes any untoward events occurring at any time after the subject’s formal entry into the study (being after receipt of the signed informed consent) until the follow-up period as defined in the respective study protocol.

Annual Safety Report (ASR)
An aggregate Safety Report in the context of clinical trials, taking into account all newly available safety information produced during a defined reporting period. Where several clinical trials are conducted with the same Investigational Medicinal Product (IMP) the reporter should include a concise global analysis of the actual safety profile of the tested IMP based on the experience for all the clinical trials.

Company Core Data Sheet (CCDS)
This document is prepared by the Marketing Authorisation Holder and contains, in addition to safety information, material relating to indications, dosing, pharmacology and other aspects of the product.

Consumer
A person who is not a healthcare professional such as a patient, lawyer, friend or relative/ parents/ children of a patient.

Expedited Reporting
Notification (submission) of an ICSR in a designated format to the appropriate Regulatory Authorities in compliance with the parameters and timelines specified by legislation and local regulatory guidelines. An expedited report would be an ICSR meeting the criteria for rapid transmission to a Competent Authority.

Healthcare Professional
Within the EU, a healthcare professional would be described as a medically qualified doctor, dentist, pharmacist, nurse or coroner.  When the report originates from a pharmacist or nurse, further information should be sought from a medically qualified doctor responsible for the patient.

Individual Case Safety Report (ICSR)
A report received by a company or agency which describes an adverse event.

Investigator Brochure (IB)
A compilation of the clinical and non-clinical data on the Investigational Medicinal Product relevant to the study of the product in humans.

Investigational Medicinal Product (IMP)
A pharmaceutical form of an active substance or placebo being tested or used as a reference in a clinical trial, including products already with a marketing authorisation but used or assembled in a different way from the authorised form, or when used for an unauthorised indication, or when used to gain further information about the authorised form.

Marketing Authorisation (MA)
The approval granted by the Regulatory Authority to market a specific product in a particular country

Marketing Authorisation Holder (MAH)
The company named on the Marketing Authorisation for a specific product in a particular country.

Medicinal Product
A substance or combination of substances presented as having properties for treating or preventing disease in human beings; or a substance or combination which may be used in or administered to human beings either with a view to restoring, correcting or modifying physiological functions by exerting a pharmacological, immunological or metabolic action, or to making a medical diagnosis.

Concerned Member State (CMS)
The Regulatory Authority in whose territory a clinical trial with the IMP is being conducted or is involved in the registration of a medicinal product in the EU under Mutual Recognition Procedures, as distinct from the Reference Member State that initiated the Procedure.

Non-interventional Trial
A study where the medicinal product is prescribed in the usual manner in accordance with the terms of the marketing authorisation. The assignment of the patient to a particular therapeutic strategy is not decided in advance by a trial protocol but falls within the current practice and the prescription of the medicine is clearly separated from the decision to include the patient in the study. No additional diagnostic or monitoring procedures shall be applied to the patients and epidemiological methods should be used for the analysis of the collected data.

Pharmacovigilance
The process of monitoring, evaluating and improving the safety of medicines. It is carried out by pharmaceutical companies on their products and by government agencies on all medicinal products. Also, the science and activities relating to the detection, assessment, understanding and prevention of adverse effects or any other drug-related problems (WHO).

Post-authorisation Study
A clinical study conducted within the conditions of the approved Summary of Product Characteristics or under normal conditions of use. A post-authorisation study may also be a Post-authorisation safety study (PASS).

Post-authorisation safety study (PASS)
A pharmacoepidemiological study or a clinical trial carried out in accordance with the terms of the Marketing Authorisation, with the aim of identifying or quantifying a safety hazard relating to an authorised medicinal product.

Risk Management System
A a set of Pharmacovigilance activities and interventions designed to proactively identify, characterise and prevent or minimise risks relating to Medicinal Products, including risk communication and the assessment of the effectiveness of risk minimisation and interventions.

Spontaneous Report
An unsolicited communication by a regulatory authority, healthcare professional, consumer or other person that describes an ADR/AE in a patient administered the Product and which does not derive from a study or any organised data collection scheme.