Updated: Pharmacovigilance Inspection: Read Our Guide & Be Prepared
A pharmacovigilance inspection can be a daunting prospect for many companies. Since 2002 we have worked with countless companies to guide them through their inspections. In this article, we look at the measures that your company can take to be prepared.
Editor’s Note: This article was originally written in 2017. We have since updated it with the most up to date reporting from both the HPRA and the MHRA.
Decline In Number of Inspections
In the UK, the MHRA publish pharmacovigilance inspection metrics each year. During the period of April 2017 to March 2018 the MHRA conducted 22 inspections of Marketing Authorisation Holders. There has been a trend developing, in recent years, that has seen the number of inspections fall year on year. For example: In the period April 2016 -March 2017 the MHRA conducted 36 inspections. For the 12 months prior to that they conducted 34 inspections. 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 2017-2018, the top two cited were risk management (25%) and the management of a quality system (21%). Here in Ireland, the HPRA conduct a limited number of PV inspections each year, with only 4 pharmacovigilance inspections taking place in 2017 (HPRA Annual report 2017).
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 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)
Here at Acorn Regulatory, we have an experienced pharmacovigilance team that can help you prepare for your pharmacovigilance inspection. Or why not get in touch today to see if we can help you on an on-going basis to meet your legal requirements in Europe with respect to pharmacovigilance.