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Written by:
Dr.Shraddha Bhange.
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Pharmacovigilance Readiness for a Successful Product Launch
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Dr.Shraddha Bhange.
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Compliance in Pharmacovigilance by
Marketing Authorisation holders and vendors
Written by:
Dr.Shraddha Bhange.
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References :
GVP Module I: Pharmacovigilance Systems and Quality Systems
FDA – Guidance on Pharmacovigilance Practices
WHO – Pharmacovigilance Indicators & Systems
Pharmacovigilance(PV) is not a cost center its a cost saving center
If you have worked in mid to senior roles in PV, you may
have come across this dilemma where we need to continuously convince,
communicate and influence other non-pharmacovigilance departments regarding the
importance of pharmacovigilance. And the more difficult task for someone in
leadership is to also break the myth that "PV is a cost center"
meaning PV does not bring any money, and on the contrary, we have to invest the
money in running the pharmacovigilance department.
And the basis of this argument, is actually coming from the
fact that, pharmacovigilance requires setting up the call center (toll free
number, telephony and employees working 24/7 to handle the calls), then
collection of adverse event via other sources, safety database (very costly
licenses), and other application supporting safety database, costly aggregate
reporting applications, signal detection applications, so on and so forth. All these
applications need to be validated and upgraded every time, hence this is never
ending payments to the application owners. Also its a niche area, so the human
resource has to be highly trained and experts (pharmacists, doctors), so this
also adds to the cost. Moreover, the inspection and audits add to the cost. So,
what people perceive does have a basis? Owing to all of these factors,
there is always an ongoing struggle to get more budget and investment for pharmacovigilance-related
assignments in the PV department.
How do we change this perception? No definite or one-size-fits-all
answer. But one thing we can do is to convert the data that we analyse and the
outcomes we generate from this data into meaningful and relevant, easy-to-understand
impact and value we create for patients.
These are thinking points for each person working in
pharmacovigilance and not for the department heads, because as working professionals,
even when we work as data entry, we need to know the value, impact and
importance of our own PV work we do. Additionally, we need to be prepared to
also spread the awareness and message to others whenever needed.
Key components that can be used for building our case
1. Regulatory expectations:
Understanding and complying with the regulatory guidance is
not an easy task. While the regulatory affairs department is the one leading
the dialogue and ensuring compliance, pharmacovigilance is the one who is
implementing and ensuring we have documented evidence to showcase our
compliance to regulatory authorities.
Markets the drug is being marketed are covered by that
country's pharmacovigilance regulation from national health authorities.
Although at a high level the PV requirements remain consistent, they are
changing, evolving and differing at the country level. This needs to showcase how
we meet those specific country requirements.
Having a core data available that can be presented regarding
the most complex health authorities' requirements and how PV meet them with
ongoing addition of examples on changes adapted to meet this HA compliance will
make it easy for non-PV leadership to also understand the importance. E.G.
Instead of showcasing we met FDA requirements, add an example of FDA
requirements and give an example of how they were met and what the outcome.
2. All is well until its not /Inspections
Build and maintain a database on pharmacovigilance
inspections done by various regulatory authorities in terms of the name of the health
authority, type of inspection, duration, inspectors, findings, category of each
finding, outcome of inspection, and what corrective and preventive actions were
implemented. Talk about the outcome, especially the positive, how it saved
money in terms of not having non-compliance.
3. Outsourcing vs inhouse
The age-old dilemma of having a pharmacovigilance department
in a pharma company or outsourcing the PV to CRO/KPO/BPO (Vendors). Both has
its own merits. Clear, Definite and Ongoing continuous evolving PHARMA-Vendor
model of partnership serves as the best solution. For a pharma company, due
diligence on the vendor is a must i.e. are the processes set, is it a working
model, what would be the cost of implementation, how much oversight will be
needed. Ultimately, having an actionable plan that can be referenced in terms
of the business value the vendor is bringing is a must.
4. Data points that can be used
While showcasing the impact and value pharmacovigilance
creates, the easiest data points is volumes i.e. how adverse events are
received and processes (ICSR volumes), submission compliance ( timelines met to
submit to each health authority) how many aggregate reports processed ( PSUR,
DSUR, PADERs), how many articles reviews, how many data sources screened for
signals, number of signals identified and validated.
The tricky data points that are difficult to put in a coherent
and relatable manner are what this means for business and patients. For this,
we need to build stories, if a signal is validated, how was it addressed, and
how it helps patients, if there was a health authority request, how was it
managed. If there was no requirement asked by the health authority and we could
say no, and it was accepted, e.g. conducting a phase IV study, how much money
was saved, etc.?
Written by:
Dr.Shraddha Bhange.
Connect with me Via comments below. (I do not respond to Facebook messages)
Support the cause of better rural education with me: ThinkSharp Foundation http://thinksharpfoundation.org/#home
Written by:
Dr.Shraddha Bhange.
Connect with me Via comments below. (I do not respond to Facebook messages)
Support the cause of better rural education with me: ThinkSharp Foundation http://thinksharpfoundation.org/#home
3. Treem, W.R., Palmer, M., Lonjon-Domanec, I. et al. Consensus Guidelines: Best Practices for Detection, Assessment and Management of Suspected Acute Drug-Induced Liver Injury During Clinical Trials in Adults with Chronic Viral Hepatitis and Adults with Cirrhosis Secondary to Hepatitis B, C and Nonalcoholic Steatohepatitis. Drug Saf 44, 133–165 (2021). https://doi.org/10.1007/s40264-020-01014-2
4. International consensus definitions of clinical trial outcomes for kidney failure: 2020Adeera Levin ,Rajiv Agarwal,William G. Herrington,Charu Malik, Vlado PerkovicInternational Society of Nephrology’s 1st International Consensus Meeting on Defining Kidney Failure in Clinical Trials
DSUR (Developmental Safety Update Report)
DSUR which is prepared while the product is still in development phase, which stands for Developmental Safety Update Report. We can also call it as a pre-marketing equivalent of a PSUR (Periodic Safety Update report).
Before we go to the core of content and format, first let’s understand what a DSUR is?
DSUR is an internationally harmonized, safety document which covers the safety summary of investigation products during their development or clinical trial phase. This means that all new drugs under development that are currently undergoing a clinical trial must submit a DSUR to the regulatory authorities.
Now you might be wondering, why do we come across DSURs for medicines which are already on the market. There will also be instances where a product is already on the market, but the sponsor/MAH (Marketing Authorization Holder/Pharma Company, wants to further evaluate the drug; for example, for a new dose, new formulation or a new indication that is not covered by the drugs approved marketing status. In that case, the sponsor must submit DSUR until the clinical trials for a marketed drug are ongoing.
What are the objectives of a DSUR? The purpose of a DSUR is to provide a comprehensive annual analysis of the safety summary collected during the clinical trial. You may consider the document as a communication to the regulators about adequate monitoring and evaluation of a safety profile of a drug under investigation.
What is the scope of products for a DSUR? A DSUR may be required for any of the following
- Investigational drugs
- Investigational Biologicals
- Investigational Vaccines
- Combination products under investigation.
Clinical trials using an investigational drug
Clinical trials conducted to support changes in the manufacturing process of medicinal products
Clinical trials conducted using marketed drugs in approved indications
Therapeutic use of an investigational drug
What is DIBD?: - Developmental international Birthdate (DIBD) – it is the date of first authorization from a regulatory agency to the sponsor to conduct any clinical trial for an investigational product anywhere in the world.
How long is it to be submitted?- A DSUR is to be submitted as long as the clinical trial is ongoing. When submission of an annual report is no longer required in an individual country or region, the sponsor should indicate that the final DSUR serves as the last annual for the investigational drug in that country or region.
What is the frequency of a DSUR submission?- Usually the DSUR is submitted annually (the frequency may vary occasionally as per national or regional regulatory requirement).
The first DSUR should have a data lock point which should be within a year of its DIBD.
Also note that the DSUR is to be submitted to the regulatory authorities within 60 calendar days after the DSUR data lock point.
What is the reference safety document for a DSUR? Unlike PSUR, in case of DSUR the IB i.e. the Investigators Brochure stands as a reference document for the DSUR report.
The Format and Content is described in International Conference on Harmonization (ICH) guideline E2F.
Each section of DSUR is highlighted in the table below, along with a brief overview of what each section entails.
DSUR | PSUR | Comment for ease of understanding |
Part I | Title Page | Information about company, author of DSUR, Reviewers , data period etc |
Part II | Executive Summary | Snapshot of DSUR , summary of risk-benefit of product |
1 | Introduction | - DIBD and Reporting period - Details of investigational drug- mechanism of action, therapeutic class, dose, route, and formulation, indication etc |
2 | Worldwide Marketing Authorization Status | - Date of first approval - Indication(s), approved dose(s), and countries where approved, if applicable. |
3 | Actions Taken In the reporting interval for Safety Reasons | - Significant safety related actions taken during the reporting period along with reasons for each action. e.g. Regulatory authorities requested hold on clinical trials, withdrawal of product etc |
4 | Changes to Reference Safety Information | Significant safety-related changes to the Investigators Brochure OR USPI or other such RSI documents within the reporting period. |
5 | Inventory of clinical trials ongoing and completed during the reporting period | - Overview of the clinical trials ongoing and completed by the sponsor during the reporting period.
|
6 | Estimated Cumulative Exposure 6.1 Cumulative Subject Exposure in the Development Programme 6.2 Patient Exposure from Marketing Experience | - Sections 6.1 and 6.2 of the DSUR should provide information on cumulative exposure in clinical trials and the marketed setting, respectively.
|
7 | Data in Line Listings and Summary Tabulations 7.1 Reference Information 7.2 Line Listings of Serious Adverse Reactions During the Reporting Period 7.3 Cumulative Summary Tabulations of Serious Adverse Events
| This should present important clinical safety information through line listings (cumulative and reporting period) |
8 | Significant Findings from Clinical Trials during the Reporting Period - 8.1 Completed Clinical Trials - 8.2 Ongoing Clinical Trials - 8.3 Long-term Follow-up - 8.4 Other Therapeutic Use of Investigational Drug - 8.5 New Safety Data Related to Combination Therapies | - Each sub section should provide a brief summary of clinically important emerging efficacy and safety findings from clinical trial |
9 | Safety Findings from Non Interventional Studies | - Relevant safety information from sponsored or co-sponsored non-interventional studies (e.g. observational studies, epidemiological studies, active surveillance programmes) |
10 | Other Clinical Trial/Study Safety Information | - Relevant safety information from any other sponsored or co-sponsored clinical trial/study sources (e.g. results from pooled analyses or meta analyses of randomized clinical trials) |
11 | Safety Findings from Marketing Experience | - Applicable in case investigational drug has been approved for marketing in any country - Should provide a summary of key safety findings that have arisen from marketing experience. |
12 | Nonclinical Data | - Major safety findings from non-clinical in vivo and in vitro studies (e.g. carcinogenicity, reproduction or immunotoxicity studies) ongoing or completed during the reporting period. |
13 | Literature | - New and significant findings, either published in the scientific literature or available as unpublished manuscripts, relevant to the investigational drug during the reporting period. |
14 | Other DSURs | - In case, multiple DSURs are to be prepared for a single investigational drug, this section should summarise significant findings from other DSURs. .
|
15 | Lack of Efficacy | - Data indicating lack of efficacy for investigational drugs intended to treat serious or life-threatening illnesses (e.g. excess cardiovascular adverse events in a trial of a new antiplatelet drug for acute coronary syndromes) |
16 | Region-Specific Information | - The information in this section can be used to comply with national or regional requirements and can be provided in appendices to the DSUR. |
17 | Late-Breaking Information | - Important safety findings that arise after the data lock point but while the DSUR is in preparation. |
18 | Overall Safety Assessment 18.1. Evaluation of the Risks 18.2 Benefit-risk Considerations
| - Concise, integrated evaluation of all new relevant clinical and non-clinical and epidemiological information obtained during the reporting period relative to the previous knowledge of the investigational drug. |
19 | Summary of Important Risks | - Concise, cumulative, issue-by-issue list of important identified and potential risks. |
20 | Conclusions | - Changes to the previous knowledge or efficacy and safety since the last DSUR. |
To summarize, DSUR is a complex and analytical document that should be utilized to analyze risk and safety profile of product in an ongoing manner.
References:
1. FDA
2. EMA
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