Unit 4.3 Pharmacovigilance Flashcards

1
Q

What is defined as by WHO ‘the science and activities relating to the detection, assessment, understanding and prevention of adverse effects or any other drug related problem’?

A

Pharmacovigilance (PV)

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2
Q

What has the aim of enhancing patient care and patient safety in relation to the use of medicines and to support public health programmes by providing reliable, balanced information for the effective assessment of the risk-benefit profile of medicines?

A

Pharmacovigilance (PV)

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3
Q

What is neccessary for the protection of public health, as the full safety profile of medicinal products can only be known after they have been placed on the market?

A

Drug safety or PV rules.

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4
Q

What is it both a legal and ethical requirement for companies to do regarding the safety of their medicinal products?

A

For them to document, analyse and report information about the safety of their medicinal products.

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5
Q

Who has the responsibility to report information about the safety of the company’s medicinal products to the company’s PV department?

A

Any person employed directly by a pharmaceutical company or contracted to work for the company.

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6
Q

What must all companies provide to all employees and agents on their processes for reporting safety information, so they know what to do if they become aware of a safety concern?

A

Must provide training.

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7
Q

When should safety information be reported by the employee or agent of the company?

A

“should normally be reported immediately or at least within one business day”

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8
Q

What term is used to describe the continuous drug safety monitoring of medicinal drugs manufactured by pharmaceutical companies?

A

PV.

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9
Q

What are the underlying objectives of PV?

A
  • Prevent harm from adverse drug reactions in humans arising from the use of authorised medicinal products within or outside the terms of marketing authorisation or from occupational exposure.
  • Promote the safe and effective use of medicinal products, in particular through providing timely information about the safety of medicinal products to patients, HCPs and the public.
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10
Q

What issues is PV neccessary for the protection of patient and public health?

A

The information from PV is used to identify safety issues that might not have been previously known about before a drug was place on the market.

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11
Q

Where were international effort to address drug safety issues through the practice of PV first initiated and in response to what?

A

In 1968 in response to the thalidomide tragedy in which thousands of infants were born with congenital deformations following foetal exposure to thalidomide, a medicine that had been used to treat morning sickness in pregnancy.

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12
Q

All pharmaceutical companies have a legal and ethical obligation to document and report information about the safety of their products. What two key reasons do pharma companies collect safety information on their drugs?

A
  • To safeguard patients’ and public health and prevent such tragedies as the thalidomide disaster.
  • It is a legal requirement - national and international regulatory authorities require pharmaceutical companies to track and report safety information to help protect the public and patients who are taking medicinal products.
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13
Q

Why is it more likely that only more common AE/ ADR will have been identified when a new product is first marketed?

A

A relatively small number of patients who fit particular inclusion and exclusion criteria will have taken part in clinical trials during development of a new medicine.

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14
Q

When do less common ADRs become detected and an indication of the frequency of the more common ADRs determined?

A

Only after larger scale post marketing use of the product in normal clinical practice.

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15
Q

Monitoring and safety of a medicinal product is therefore a continuous process, which applies to which stages of the products life?

A

All stages:

  • during clinical trials when a medicine is developed
  • once a medicine is launched
  • throughout the entire period when a medicine is available for patient use.
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16
Q

What does continuous monitoring of the safety of a medicinal product enable?

A

The company and regulatory authorities to continuously monitor the benefit-risk profile of a product and identify potential new safety issues at an early stage.

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17
Q

What are limitations associated with safety data collected during clinical trials?

A
  • Small number of patients.
  • Short duration of exposure to developmental drug
  • Selected population
  • Participants with fewer complication factors e.g. concurrent illnesses/medicines.
  • No access to special populations (elderly, children, pregnant women)
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18
Q

What are the advantages with collecting safety data after post marketing?

A
  • Drug exposure to wider patient population
  • Longer duration of exposure to approved drug
  • Builds on the safety profile defined during clinical trials
  • Picks up signals of potential problems or at risk populations
  • Helps Marketing Authorisation Holder to pit in place additional risk minimisation activities for newly identified risks.
    Full established safety profile of a medicinal product allows physicians to assess benefit/risk for wider patient population and improve in general patients care and overall public health.
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19
Q

What is an untoward medical occurrence in a patient administered a pharmaceutical product, whether or not the occurrence is related to or considered to have a casual relationship with the treatment.

A

An Adverse Event (AE).

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20
Q

What can an AE be?

A

Any unfavourable and unintended sign ( abnormal lab finding, abnormal ECG, X-ray/CT scan), symptom (nausea, headache, vomiting, rash), or disease (pneumonia) temporally associated with the use of a medicinal product.

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21
Q

What is defined as a response to a drug 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 modifications of physiological function?

A

An Adverse Drug Reaction (ADR)

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22
Q

What definition implies that a casual relationship between a medicinal product and an AE is at least a reasonable possibility?

A

The ADR definition.

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23
Q

ADRs may arise form use of the products within or outside the terms of the marketing authorisation of from occupational exposure. What are examples conditions of use outside the marketing authorisation?

A

Off-label use, overdose, misuse, abuse and medication errors. - ADRs can vary from life-threatening to minor common side-effects.

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24
Q

What are the following classes as if associated with the use of a medicinal product and should be reported, whether or not there is an associated AE:

  • Inappropriate exposure during pregnancy (whether the foetus expose via mother taking product or transmission via semen following paternal exposure)
  • Inappropriate exposure during breast feeding/lactation.
  • Overdose (whether intentional, accidental or prescribed)
  • Drug abuse or misuse.
  • Medication errors or near misses (inc. dispensing errors, accidental exposure, maladministration etc)
  • Unapproved or off-label use, inc off-label use in children or elderly.
  • Reports of lack of therapeutic effect or other product complaints associated with an AE, inc suspected use of counterfeit medicines.
A

Events of Special Interest.

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25
Q

If pregnancy is associated with an event (e.g. miscarriage, induced abortion, congenital defect) what is is known as and when should it be reported?

A

It is known as a serious AE (SAE) and must be reported in the same time frame as all other SAEs: notification of pregnancy outcome should be within one business day of awareness.

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26
Q

Should the following other safety situations also be reported?

A
  • Drug-drug or drug-food interactions.
  • Suspected transmission of an infectious agent
  • Occupational exposure (as a result of one’s professional or non-professional occupation)
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27
Q

ADRs that are known about and documented within the labelling i.e. Summary of Product Characteristics for the medicinal product are considered as what?

A

Expected or listed.

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28
Q

What are events that are not consistent with the nature, severity or outcome of the events documented within the products labelling considered as?

A

Unexpected or unlisted.

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29
Q

What criteria does an AE have to meet for it to be considered as serious?

A

It has to meet one of these well-established international criteria:

  • Results in death, or is life-threatening
  • Required hospitalisation or prolongs and existing hospitalisation.
  • Results in persistent or significant disability or incapacity.
  • Results in congenital anomaly
  • Is otherwise medically significant i.e. the event would not meet the preceding criteria but is considered serious because treatment or intervention would be required to prevent one of the preceding criteria.
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30
Q

What are all companies holding innovative or generic marketing authorisation for medicinal products in the EU legally obliged to have?

A

An appropriate system of PV in place to ensure the appropriate use of their medicines and to take appropriate action when necessary.

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31
Q

Part of this system is to promptly report relevant safety information to the worldwide regulatory authorities, for example?

A

European Medicines Agency (EMA) and the US Food and Drug Administration (FDA)

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32
Q

In order to ensure compliance with this legislation ‘to promptly report relevant safety information to the worldwide regulatory authorities’ What must all companies undergo?

A

Regular PV inspections by the regulatory authorities, inc. the Medicines and Healthcare products regulatory Agency (MHRA), the UKs regulatory authority.

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33
Q

What are the reasons Regulatory Authorities mandate the collection of PV data?

A
  • To monitor medicines as they are used in every day practice and in clinical research to identify previously unrecognised adverse effects of changes in the patterns of known adverse effects.
  • Assess the risks and benefits of medicines in order to determine what action, if any, is necessary to improve the their use.
  • Provide information to prescribers and users to optimise effective use of medicines
  • Monitor the impact of any action taken.
34
Q

Safety information is entered into a database and regularly reviewed and assessed by the company’s global PV department - therefore why is it important that as much detail as possible is obtained when the initial report is received?

A

To enable a full assessment of the case - However additional follow up will generally also be sought in order to obtain any missing information.

35
Q

The information is used to build up the safety profile of a medicine so that the company in consultation with the relevant regulatory authority can advise prescribers and users of any changes, as necessary, or take any other actions, such as:

A
  • updates of product information: SmPC, patient information leaflet or package leaflet.
  • Further clinical studies to define an AE.
  • Conducting educational programmes.
  • issuing special warnings or direct HCP communications
  • Withdrawal of a medicine from the market in rare circumstances.
36
Q

Updated European PV legislation was set out in 2010 and implemented in July 2012, what was the aim?

A

To reduce the number of ADRs in the EU

37
Q

The legislation aims to streamline and improve the processes of post-marketing monitoring and surveillance of drug safety through what?

A
  • The collection of better data on medicines and their safety.
  • Rapid and robust assessment of issues related to the safety of medicines.
  • Effective regulatory action to deliver safe and effective use of meds.
  • empowerment of patients through reporting and participation
  • increased levels of transparency and better communication,
38
Q

What is the Good pharmacological practices?

A

Measures to facilitate PV in accordance with this legislation are set out in the guideline on good pharmacological practices (GVP)

39
Q

What is applicable to all MAH, the EMA and national regulatory authorities within the EU?

A

The Good Pharmacological practices.

40
Q

All companies operating within the EU must employ a qualified person responsible for PV (QPPV) A QPPV should be experiences in all aspects of PV and product safety and is responsible for ensuring that the company meets its PV legal obligations for all medicinal products for which the company holds marketing authorisations within the EU: what are they responsible for?

A
  • Establishing and maintaining a PV system.
  • Preparing PV reports as defined by regulations
  • Having an overview of the safety profiles and any emerging safety concerns for the company’s drugs
  • answering requests from regulatory authorities.
  • Providing regulatory authorities with any other information relevant to product safety.
41
Q

When should the QPPV be available as a single points of contact for the regulatory authorities?

A

Permanently and continuously available on a 24 hours basis.

42
Q

What does the benefit-risk balance of a medicinal product in the specified indications have to be judged to be for it to be authorised?

A

To be positive for the target population based on relatively limited safety information

43
Q

What must companies applying for marketing authorisation in the EU be required to submit to the EMA which details a plan of PV activities necessary to characterise the full safety profile of the medicinal product and the ways in which the company intends to minimise and monitor identified and potential risks with their medicines.

A

A risk-management plan (RMP)

44
Q

For nationally authorised medicinal products, any regulatory authority in the EU, such as the UK MHRA can request what whenever there is concern about a risk affecting the benefit-risk balance of a medicine?

A

A risk-management plan.

45
Q

What has to be submitted at the time of application for marketing authorisation and care continually modified and updates throughout the lifetime of the medicine as new information on the benefit-is profile becomes available?

A

A risk-management plan.

46
Q

Where appropriate, what should training be provided and tailored with respect to specific activities associated with what?

A

The risk-management plan.

47
Q

Companies are required to prepare and submit Periodic Safety Update Reports (PSURs) to regulatory authorities at defined time points following a medicines authorisation. - what is a PSUR?

A

It summarises and evaluates the benefit risk profile based on all safety and efficacy information collected on the product up to that time, from both its authorised uses and unauthorised uses.

48
Q

Regulatory authority uses the information in PSURs to determine if there are new risks identified for a medicine or whether its benefit-risk profile has changed - what can it then decide?

A

It can then decide if further investigations need to be carried out or can take action to protect the public from the risks identified such as updating the information provided for HCPs and patients.

49
Q

What does the inverted black triangle indicate on the SmPC and PIL?

A

EU legislation required that recently introduced medicines or other products meeting certain criteria are listed by the regulatory authorise as requiring additional safety monitoring and are identified with the triangle.

“This medicinal product is subject to additional monitoring”

50
Q

How long do the inverted black triangle and “This medicinal product is subject to additional monitoring” with a standard sentence explaining the concept remains in place for?

A

A mandatory period of 5 year which can be extended.

51
Q

What does EudraVigilance stand for?

A

European Union Drug Regulating Authorities Pharmacovigilance.

52
Q

What is EudraVigilance?

A

The European database for managing PV information during the development, and following the marketing authorisation of medicinal products in the European Economic Area (EEA).
Data for authorised medicines are analysed on a regular basis and The EMA’s Committee for Medicinal Products for Human Use and PV working part evaluate signals from EudraVigilance and may recommend regulatory action as a result.

53
Q

The database is designed to be the single point of receipt for all PV information in the EU to enable what?

A
  • Electronic exchange of suspected ADR reports, known as individual case safety reports (ICSRs), reported both pre and post authorisation, between the EMA and national regulatory authority, MAH and sponsors of clinical trials.
  • The early detection and evaluation of possible safety signals for human medicines.
  • Continuous monitoring and evaluation of potential safety issues in relation to reported ADR
  • Decision making process based on broader knowledge of the adverse reaction profile of drugs.
54
Q

Under EU legislation in order to protect public health regulatory authority are obliged to ensure compliance wit PV obligations - what happens when non-compliance is detected?

A

Action is judged on a case-by-case basis and action will depend on the potential negative public health impact of the non-compliance but any distance for non-compliance may be considered for enforcement action.

55
Q

What are the possible actions for non compliance?

A

Education and facilitation to implement corrective actions; triggered or for cause inspections; issuance of Infringement notices/warning letters; urgent safety restrictions, variation, suspension or revocation of marketing authorisations; administration penalties (fixed fines or fines based on company profits) and referral for criminal prosecution with the possibility of imprisonment. Authorities may also consider making public a list of MAHs found to be seriously or persistently non-compliant.

56
Q

What is the name for clinical studies that are carried out after a medicine has been authorised to obtain further data to clarify a medicines safety and efficacy in everyday practice.

A

Post authorisation safety studies (PASS) and post-authorisation efficacy studies (PAES)

57
Q

What is defined as any study relating to an authorised medicinal product conducted with the aim of either identifying characterising or quantifying a safety hazard, confirming the safety profile of the medicinal product or of measuring the effectiveness of risk management measures?

A

A PASS.

58
Q

What is defined as a study conducted within a medicinal product authorised therapeutic indication to complement available efficacy data in the light of well reasoned scientific uncertainties on aspects of evidence of benefits that should be or can only be address post authorisation?

A

A PAES

59
Q

What can either be interventional clinical trials or non-interventional observational studies and can either be imposed by regulators or carried out voluntarily by companies?

A

PASS or PAES

60
Q

When might a PAES be required by regulators?

A
  • At the time a marketing authorisation is recommended, when there are questions about the efficacy of the medicine the can only be answered once the medicine has been marketed.
  • After a marketing authorisation has been granted, if new data indicate that the benefits of the medicine should be further studies.
61
Q

What should the results of PASS or PAES translate into?

A

Better labelling and better use of medicines by patients and prescribers in clinical practice.

62
Q

Safety information is frequently identified through medical information enquires and consideration should be given as to whether safety is the basis of any query. Safety information my come in the form of spontaneous reports from healthcare professionals, patients or other intermediates via:

A

Direct verbal contact, phone calls, internet/websites, letters, faxes, publications/scientific literature, other media sources eg. medical meetings and conferences

Or reports may be solicited through organised data collection systems such as:
- Clinical trials, patient support programmes, medical education grant programmes, registries, PASS or PAES, observational programmes (e.g expanded access, compassionate use programmes, named patient programmes)

63
Q

What should a pharmaceutical companies PV departments carefully consider to ensure that all legal obligations are met?

A

How safety information will be handled and collected before such projects are started.

64
Q

Who does the legal obligation of PV apply to?

A

All pharmaceutical manufacturers and their employees.

Anyone employed directly by a pharmaceutical company or contracted to work for the company therefore had a responsibility to record and report information about the safety of the company’s medicinal products to the company PV department, even if they do not work in a safety related function.

65
Q

What must companies provide to all employees and agents so they know what to do if they become aware of a safety concern, as set out by the EMA Guideline on Good Pharmacovigilance Practice and the ABPI Code of Practice for the Pharmaceutical Industry?

A

Must provide training to all employees and agents on their processes for reporting safety information.

66
Q

Who especially has an important role to play in the process of collecting safety information and why?

A

Anyone who communicates with customers of the company in a promotional or non-promotional capacity has a particularly important role since they will often be the main contact for that customer with the company but it is important to understand that is also includes situations outside of work.

67
Q

Examples of scenarios which should be reported as an AE/ADR?

A
  • Started having insomnia since drug
  • swallowing opposed to chewing because it tastes weird.
  • On drug and broke leg playing football.
  • on drug and crashed car.
  • sharing drug with partner.
  • on drug, no longer need glasses.
68
Q

When should safety information normally be reported?

A

Immediately or at least within one business day of awareness by the employee or agent of the company.

69
Q

What is important to always be included in a report?

A

The awareness date.

70
Q

When do pharmaceutical companies need to report certain safety information from receipt to the regulatory authorities?

A

Within strict time frames - some must be submitted as early as seven days of the date anyone in the company is made aware of the AE.

71
Q

How should adverse events be reported to the PV department?

A

Must be sent to the company PV department via the medicinal information department or other route. each company must implement a system ideally as straightforward as possible for reporting safety information. This must be adequately documented and all employees and contractual agents must receive training in this process together with refreshers.

72
Q

What do you do if someone provides you with safety infromation?

A

Collect the information and ensure discussions are in line with ABPI CoC.
Inform reporter that the info will be passed to companies PV department who may contact them or their HCP for further information - any questions they have should be directed to the company medical information department.

73
Q

What type of safety information associated with the company’s products should be collected regardless of what?

A

Any safety information, regardless whether or not it is expected i.e. already in SmPC.
Whether the reporter is a HCP or non HCP
How serious or severe the event is
Whether or not a casual relationship to the product has been established
Whether or not the reporter has already completed a Yellow Card report to the MHRA.

74
Q

What is the minimum information required for an AE to be reported??

A

Company product

AE or event of special interest

75
Q

Ideally for the AE to be valid for scientific evaluation and submission to the regulatory authorities the following additional information should be included:

A

An identifiable patient. (one or combination of: age, DoB, gender, age group, initials.)
An identifiable reporter (one or combination of: name, occupation or title, address, tele number, email, other contact details.

76
Q

What is the minimum information required for submission of AE/ADR to a regulatory authority in the form of an ICSR? 4 main points:

A
  • company product
  • An AE or event of special interest
  • An identifiable patient.
  • An identifiable reporter.
77
Q

When is an AE case considered incomplete and does not qualify for reporting?

A

When one of the 4 minimum information required points is missing.

78
Q

What happens to incomplete AE reports?

A

Recorded within the company PV database for use in on-going safety evaluation activities.
They should also be followed up to try and obtain al 4 pieces of information required for the scientific evaluation of the cases.
If all 4 pieces of information cannot be obtained through follow up the PV department should be notified that reasonable efforts have been made to obtain the minimum required information.

79
Q

Where possible, what other information to describe the course and outcome of the event should be included?

A

-details of symptoms, severity, duration, treatment, and what medicinal attention if any was sought. Any source data that arises from the collection of safety information such as hand written notes or the company AE collection form must also be sent to the PV department.

80
Q

What if someone does not want to report safety information?

A

This is acceptable provided this is documented and notified to the PV department - employee must still report the information they have already obtained from the reporter but inform the PV department that the reporter does not wish to provide any further follow up.

81
Q

What happens if information received contains personal data?

A

The company’s internal procedures must be followed to ensure that such confidential personal data is anonymised and managed appropriately. To maintain patient confidentiality and to uphold data privacy rules.

82
Q

What are Yellow Card reports?

A

In the UK individual patients and HCPs can report an AE either to the pharma company or directly to the MHRA use the Yellow Card reporting Scheme. They can be completed using either a prepaid letter cards or online or by contacting the Yellow Card information service. Yellow cards can be downloaded from the MHRAs website or found at the back of the British national Formulary.