Organization and objectives of ICH, expedited reporting, ICSR, PSURs, post approval expedited reporting, pharmacovigilance Planning, good clinical practices
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ICH Guidelines for
Pharmacovigilance
Dr. Ramesh Bhandari
Asst. Professor,
Department of Pharmacy Practice,
KLE College of Pharmacy, Belagavi
Organization and
Objectives of ICH
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Organization and objectives of ICH
INTERNATIONAL CONFERENCE ON HARMONISATION (ICH) of Technical
Requirements for Pharmaceuticals for Human Use
◉EstablishedinApril1990
◉Initiativeforregulatorsandpharmaceuticalindustries
◉Reformedasanon-profitlegalentityunderSwissLawon23October
2015
◉Formedtoassuresafety,qualityandefficacyofmedicines,themembers
ofICHwhoincludemembersfromdrugregulatoryauthoritiesand
researchbasedindustriesofEuropeanUnion,USandJapanwilldiscuss
onthetechnicalproceduresanddocumentsrequired.
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Need for harmonization
◉Thedifferenceinthetechnicalrequirementsandthe
proceduresfollowedbydifferentcountriesmadetheglobal
marketingofdrugsastimeconsumingandexpensive
◉Toreducethecostandtimerequiredfortheglobal
marketingofdrugs
◉Harmonizationoftechnicalrequirementshastobepromoted
◉Specialguidelinestobeframedtoensurethequality,safety
andtheefficacyofthedrugs
Purpose or Objectives of ICH
◉Harmonizedinterpretationandapplicationoftechnical
guidelinesandrequirementsformarketingauthorizationto:
Reduceduplicationoftestingofthedrugsunder
investigation
Increaseeconomicaluseofresources
Eliminateunnecessarydelayinavailabilityofnew
medicines
◉Safeguardingquality,safetyandefficacy
◉AccomplishedthroughTechnicalGuidelinesthatare
implementedbytheregulatoryauthorities.
ICHMembers
ICH covers 3 regions:
◉European Union
◉United Statesof America
◉Japan
“Six Parties”
1.The European commission, (representing 28 members states of EU)
2.The European federation of pharmaceutical industries and associations (IFPMA)
3.The Ministry of Health, Labourand Welfare of Japan
4.The Japanese Pharmaceutical Manufactures Association (JPMA)
5.The US Food and drug Administration (FDA)
6.The Pharmaceutical Research and Manufacture of America (PhRMA)
ICHMembers
18 Members:
Founding Regulatory Members
◉European Union
◉FDA, United Statesof America
◉MHLW/PMDA, Japan
Founding Industry Members
◉EFPIA
◉JPMA
◉PhRMA
Standing Regulatory Members
◉Health Canada, Canada
◉Swissmedic, Switzerland
Regulatory Members
◉ANVISA, Brazil
◉HSA, Singapore
◉MFDS, Republic of Korea
◉NMPA, China
◉SFDA, Saudi Arabia
◉TFDA, Chinese Taipei
◉TITCK, Turkey
Industry Members
◉BIO
◉Global Self-Care Federation
◉IGBA
ICH Guidelines for
Pharmacovigilance -Introduction
ICH Guidelines for Pharmacovigilance
◉TheICHhaspublishedanumberofdocumentssetting
standardsforsafety,bothclinicalandpre-clinical.
◉Pre-clinicalguidelineshavean“S”designatione.g.S1,S2
etc.Itshouldbenotedthattheclinicalsafetyguidelinesare
designatedas“E”
◉Thesedocumentsprovideahighdegreeofdetailaboutthe
expectedmanner,method,timing,frequencyand
circumstancesinwhichpharmaceuticalcompaniesandother
relevantpartiesneedtoreportsuspectedadversereactions
andothervitalclinicaldatatotheregulatoryauthorities.
ICH Guidelines for Pharmacovigilance
◉Eachofthefollowingclinicalsafetyguidelinehasanidentifyingcode,and
duringthelifetimeoftheICHthecodeshavealreadybeenrevisedtoreflectthe
developmentandevolutionofthosestandardsdocuments:
E1ClinicalSafetyforDrugsIntendedforLong-TermTreatmentofNon-Life
ThreateningConditions
E2AClinicalSafetyDataManagement:DefinitionsandStandardsfor
ExpeditedReporting
E2B(R2)MaintenanceoftheClinicalSafetyDataManagementincluding
DataElementsforTransmissionofIndividualCaseSafetyReports
E2B(R3)ClinicalSafetyDataManagement:DataElementsforTransmission
ofIndividualCaseSafetyReports
ICH Guidelines for Pharmacovigilance
E2C(R1)ClinicalSafetyDataManagement:PeriodicSafetyUpdateReportsfor
MarketedDrugs
E2C(R2)PeriodicBenefit-RiskEvaluationReport
E2DPost-ApprovalSafetyDataManagement:DefinitionsandStandardsfor
ExpeditedReporting
E2EPharmacovigilancePlanning
E2FDevelopmentSafetyUpdateReport
EXPEDITED
REPORTING
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EXPEDITED REPORTING
CLINICAL SAFETY DATA MANAGEMENT: DEFINITIONS AND
STANDARDS FOR EXPEDITED REPORTING (E2A)
Itisimportanttoharmonisethewaytogatherand,ifnecessary,totake
actiononimportantclinicalsafetyinformationarisingduringclinical
development.Thus,agreeddefinitionsandterminology,aswellas
procedures,willensureuniformGoodClinicalPracticestandardsinthis
area.
Thisguidelineaddressesthefollowing:
1.thedevelopmentofstandarddefinitionsandterminologyforkey
aspectsofclinicalsafetyreporting,and
2.theappropriatemechanismforhandlingexpedited(rapid)reporting,in
theinvestigational(i.e.,pre-approval)phase.
EXPEDITED REPORTING
◉Expedited Report:SAEs which are unexpected (not labelled), be
reported in 15 Calendar days from the first notification of anyone
in the company including its agent, business partners, contractors,
distributors, and vendors. Also known as alert report, 15-day
report.
◉7-day report:Patient in question has died or had life threatening
SAE which is also unexpected and possibly related. This report
should be sent to the health authorities within 7 calendar days.
Note:All 7-day reports are also 15-day report. It must also be followed
up as a 15 day report
Elements of the specifications in the ICSR
◉Pre-Clinical:
Toxicity
General Pharmacology
Drug Interactions
Other toxicity related information
◉Clinical:
Limitations of the Human Safety Database
Populations not studied in the pre-approval phase
Adverse events/adverse drug reactions
Identified risks that require further evaluation
Potential risks that require further evaluation
Identified and potential interactions
PSUR –GENERAL PRINCIPLES
ONE REPORT FOR PRODUCTS CONTAINING ONE ACTIVE SUBSTANCE
AUTHORISED TO ONE MARKETING AUTHORISATION HOLDER
◉Ordinarily,alldosageformsandformulationsaswellas
indicationsforagivenpharmacologicallyactivesubstance
authorizedtoonemarketingauthorizationholder(MAH)maybe
coveredinonePSUR.
◉WithinthesinglePSUR,separatepresentationsofdatafor
differentdosageforms,indicationsorpopulations(e.g.children
versusadults)maybeappropriate.
PSUR Content
TITLE
◉PSURscontainproprietaryinformation,sothetitlepageshouldcontainastatement
ontheconfidentialityofthedataandconclusionsincludedinthereport.
EXECUTIVESUMMARY
◉Theexecutivesummaryshouldconsistofabriefoverviewprovidingthereaderwitha
descriptionofthemostimportantinformation.
INTRODUCTION
◉Theintroductionputsthereportincontext,describingthoseproducts/formulations
thatareincludedandexcluded,outliningthepharmacologyoftheproduct,its
indications(bothmarketedandinclinicaltrials)
WORLDWIDE MARKETINGAUTHORISATIONSTATUS
◉ThePSURshouldincludeashortsummaryoftheworldwidemarketingauthorisation
status
PSUR Content
UPDATEONREGULATORY AUTHORITYORMAHACTIONSTAKENFOR
SAFETYREASONS
◉TheupdateonregulatoryauthorityorMAHactionstakenforsafetyreasons
referstomarketingauthorization,withdrawalorsuspension;failuretoobtaina
marketingauthorizationrenewal;restrictionsondistribution;clinicaltrial
suspension;dosagemodification/formulationchangesandchangesintarget
populationorindications.
CHANGES IN REFERENCE SAFETY INFORMATION
◉The changes in reference safety information section refers to changes in the
CCSI (company core safety information). The CCDS (company core data sheet),
which incorporates the CCSI, should be included as an appendix.
SOURCES
1. Unsolicited Sources
Spontaneous reports
Literature
Internet
Other sources-such as lay press and other media
2. Solicited sources
3. Contractual Agreements
4. Regulatory Authority Sources
STANDARDS FOR EXPEDITED REPORTING
◉Serious ADRs:
Serious and unexpected cases of ADRs are subject to
expedited reporting.
For reports from studies and other solicited sources, all
cases judged by either the reporting health care
professionals or the MAH for causal relationship to the
medicinal product qualifying as ADRs.
Spontaneous reports associated with approved drugs
imply a possible causality
STANDARDS FOR EXPEDITED REPORTING
◉Other observations:
Any significant unanticipated safety findings, including in
vitro, animal, epidemiologic, or clinical studies, that
suggest a significant human risk and could change the
benefit–risk evaluation should be communicated to the
regulatory authorities as soon as possible.
Lack of efficacy observations should not be expedited but
should be discussed in PSURs unless local requirements
oblige their being expedited.
Principles of Pharmacovigilance Planning
guidelines
i.Planning of pharmacovigilance activities
throughout the product life cycle
ii.Science-based approach to risk documentation
iii.Effective collaboration between regulators and
industry
iv.Applicability of the pharmacovigilance plan across
the three ICH region
Sections of Pharmacovigilance Plan
1.Safety Specification
2.Pharmacovigilance plan
3.Annex-Pharmacovigilance methods
Sections of Pharmacovigilance Plan
1.Safety Specification:
Thesafetyspecificationisasummaryofthe
importantidentifiedrisksofadrug,important
potentialrisks,andimportantmissinginformation.
It should refer to the three safety sections in the
Common Technical Document:
Non-clinical
Clinical
Epidemiology
Sections of Pharmacovigilance Plan
2.Pharmacovigilance Plan:
The pharmacovigilance plan should be based on the safety
specification and developed by the sponsor.
This includes:
•Summary of ongoing safety issues, including the important
identified risks, potential risks, and missing information.
•Routine pharmacovigilance practice
•Summary of actions to be completed, including milestones
Sections of Pharmacovigilance Plan
3.Pharmacovigilance Methods:
The best method to address a specific situation may vary
depending on the product, indication, population treated.
Sponsors should choose the most appropriate design.
Design and conduct of observational studies
Annexure -A detailed discussion of pharmacovigilance
methods is appended to the document.
GOOD CLINICAL PRACTICES
IN PHARMACOVIGILANCE
STUDIES
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GOOD CLINICAL PRACTICES (GCP)
◉GCPs are stand alone document and its guidelines are given
in ICH E6.
◉Good Clinical Practice (GCP) is an international ethical and
scientific quality standard for designing, conducting,
recording and reporting trials that involve the participation
of human subjects.
◉Compliance with this standard provides public assurance
that the rights, safety, and well-being of trial subjects are
protected, consistent with the principles that have their
origin in the Declaration of Helsinki, and that the clinical
trial data are credible.
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GOOD CLINICAL PRACTICES (GCP)
1)Clinical trials should be conducted in accordance with the ethical principles
that have their origin in the Declaration of Helsinki, and that are consistent
with GCP and the applicable regulatory requirement(s).
2)Before a trial is initiated, foreseeable risks and inconveniences should be
weighed against the anticipated benefit for the individual trial subject and
society. A trial should be initiated and continued only if the anticipated
benefits justify the risks.
3)The rights, safety, and well-being of the trial subjects are the most
important considerations and should prevail over interests of science and
society.
4)The available nonclinical and clinical information on an investigational
product should be adequate to support the proposed clinical trial.
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GOOD CLINICAL PRACTICES (GCP)
5)Clinical trials should be scientifically sound, and described in a clear,
detailed protocol.
6)A trial should be conducted in compliance with the protocol that has
received prior institutional review board (IRB)/independent ethics
committee (IEC) approval/favourable opinion.
7)The medical care given to, and medical decisions made on behalf of,
subjects should always be the responsibility of a qualified physician or,
when appropriate, of a qualified dentist.
8)Each individual involved in conducting a trial should be qualified by
education, training, and experience to perform his or her respective
task(s).
9)Freely given informed consent should be obtained from every subject
prior to clinical trial participation.
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GOOD CLINICAL PRACTICES (GCP)
10)All clinical trial information should be recorded, handled, and
stored in a way that allows its accurate reporting, interpretation and
verification.
11)The confidentiality of records that could identify subjects should
be protected, respecting the privacy and confidentiality rules in
accordance with the applicable regulatory requirement(s).
12)Investigational products should be manufactured, handled, and
stored in accordance with applicable good manufacturing practice
(GMP). They should be used in accordance with the approved
protocol.
13)Systems with procedures that assure the quality of every aspect of
the trial should be implemented.
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GOOD CLINICAL PRACTICES (GCP)
INVESTIGATOR’S RESPONSIBILITIES:
All SAEs should be reported immediately by the investigator to the
sponsor except for those SAEs which the protocol or other document
identifies not needing immediate reporting.
Identify the subject by trial code number rather than by subject name,
personal information and/or address
Investigator should comply with the applicable regulatory requirement
while reporting unexpected SAEs to the regulatory authorities
Adverse events or laboratory abnormalities should be reported to the
Sponsor within the time periods specified by sponsor.
For reported death, the investigator should provide additional information
if requested by sponsor or IRB/IEC.
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GOOD CLINICAL PRACTICES (GCP)
INVESTIGATOR’S RESPONSIBILITIES:
If the investigator terminates or suspended trial without prior agreement of
the sponsor, the investigator should promptly inform the institute and
where applicable (such as Institutions, IRB/IEC) by providing detailed
information.
If the sponsor terminates or suspended trial, the investigator should
promptly inform the institutes and where applicable (such as Institutions,
IRB/IEC) by providing detailed information.
If IRB/IEC terminates or suspends its approval/favourable opinion of a
trial, the investigator should inform the institution where applicable.
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GOOD CLINICAL PRACTICES (GCP)
SPONSOR’S RESPONSIBILITIES:
Sponsor is responsible for the ongoing safety
evaluation of the investigational product(s).
Should notify all concerned
investigator(s)/institution(s) and the regulatory
authorities of findings that could adverse affect
the safety of subjects, impact the conduct of trial.
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GOOD CLINICAL PRACTICES (GCP)
ADR Reporting guidelines:
Sponsor should expedite the reporting to all concerned
investigator(s)/Institution(s) to the IRB/IEC, where required
to the regulatory authority of all ADRs that are both serious
and unexpected.
Expedited reports should comply with the applicable
regulatory requirement and with the ICH guidelines for
clinical safety data management.
Sponsor should submit to the regulatory authority(ies) all
safety updates and periodic reports as required by applicable
regulatory requirement(s).
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