MHRA Inspection MetricsIn the UK, the MHRA publish pharmacovigilance inspection metrics each year. 2015-2016 has seen the number of inspections continue to fall with 34 inspections in this period compared with 47 for 2014-2015 and 56 for the period 2013 to 2014. These yearly reports, together with our own experience of MHRA pharmacovigilance audits over the years, have given us an insight on the changing focus of the inspectorate since the introduction of the revised Good Pharmacovigilance Practice in June 2012. In the April 2015 to March 2016 reporting period, the most commonly cited critical finding was ‘Supervision and oversight’ at 28%. This category includes issues in relation to the provision of complete and accurate information to national competent authorities and inspectors, maintenance of the PSMF and QPPV/ MAH oversight of the pharmacovigilance system. ‘MAH oversight’ accounted for 11% of critical findings in 2014-2015 and was not listed as a category in the 2013-2014 report. This represents an upward trend in findings in this area. The second most cited category for critical findings in 2015-2016 was both ‘Data management’ and ‘Reference safety information (RSI)’, both at 18%. RSI includes failures and significant delays to submit safety variations to update the safety sections of SPCs and PILs. RSI seems to have seen an improvement in MAH compliance in recent years, as it represented 29% and 42% of critical findings in 2014-2015 and 2013-2014, respectively. Data management was not a category in previous reports, and includes issues with collation and integrity of the global safety dataset, ICSR handling and safety database validation, configuration and control. On major findings in 2015-2016, the top two cited were signal management (24%) and ICSR management (18%). Here in Ireland, the HPRA conduct a limited number of PV inspections each year, with only 2 pharmacovigilance inspections taking place in 2015 (HPRA Annual report 2015).
Ask yourself the following questions….From our experience with the MHRA, a key focus at present is QPPV oversight and influence. The QPPV must continue to be aware of all aspects of safety related to the medicinal product(s). This is an extremely wide net and QPPVs should be able to satisfy themselves with all of the following, as outlined in GVP module 1:
- Does your QPPV have the skills for the management of the pharmacovigilance system and have adequate theoretical and practical knowledge? Simply assigning a member of staff to this position that does not have extensive experience in the area is not acceptable, and will be cited by national competent authorities.
- Is the information in the PSMF accurate and up to date at all times? Is it a true reflection of the how the pharmacovigilance system is executed on a day-to-day basis?
- Do you have sufficient oversight of all third parties, for example distributors? Have you got robust safety data exchange agreements in place? Are you performing reconciliation activities at appropriate intervals? Have you ensured all third parties have received initial and refresher pharmacovigilance training? Have all third parties been included on your audit schedule? Have you assessed risks when deciding on your audit plan for third parties?
- Do you have oversight over the functioning of the system in all relevant aspects, including its quality system (e.g. standard operating procedures, contractual arrangements, database operations, compliance data regarding quality, completeness and timeliness of expedited reporting and submission of periodic update reports, audit reports and training of personnel in relation to pharmacovigilance).