Pharmacovigilance obligations of the Pharmaceutical companies in India

Dr.Sumedh M.Gaikwad

MD,DM

Clinical Pharmacology,

Director Medical Services,

Richter Themis Medicare Ltd.1

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• Introduction• Regulations Relating to PV in India• National PV program• PV activities for Generic Drugs in India• Management of Safety Database• Safety Reporting During Clinical Trials• PV obligations of Indian Companies with

Subsidiaries Abroad• Conclusion

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INTRODUCTION

Regulatory decision to approve new drug based on benefit & risk

Status of Indian Pharma Market for introduction of new drug

Change in scenario Govt. efforts PV obligations Pharma Companies

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REGULATIONS RELATING TO PV IN INDIA

Pharmaceutical company & PV System -In House -Outsourced to CROs

Schedule-Y -Define responsibilities of Pharma

company to ensure adequate compliance of PV obligations

-PMS 4

NATIONAL PV PROGRAM

• Nation-wide program (CDSCO)• Major functions: -Monitoring of spontaneous ADRs -Review of the PSURs submitted by Pharma

companies -Assessing safety information for product

label amendments, product withdrawals & suspension.

• Limited guidance in Schedule-Y & protocol by NPP

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PV ACTIVITIES FOR GENERIC DRUGS IN INDIA

PV obligations of Generic Company in India:-Collection, monitoring, & reporting of

spontaneous adverse reaction reports-Preparation of PSURs-Expectations: *To develop adequate systems & expertise

for literature searches, management of safety data, signal detection,& risk-benefit analysis of its marketed products

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SPONTANEOUS ADRS• Spontaneous reporting of ADRs-an important tool: -to gather safety information required for early

signal detection -to conduct risk-benefit analysis of new drugs• Schedule-Y specifications -SUSAR: report within 15 days of initial of

information & all available clinical information related to reaction

- Individual ADRs included in next PSUR & not in an urgent manner

Limitations: -Details regarding capture, evaluation & FU of ADRs

not addressed* Guidance doc. from ICH E2D referred to develop

detailed procedures for handling of spontaneous AEs

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Guidance doc. from ICH E2D referred to develop detailed procedures for handling of spontaneous AEs:

• Procedure includes defining minimum four criteria to validate the adverse reaction reports

• Collection of relevant info. for spontaneous adverse reactions

• Handling of the reports received from patients or their relatives

• Evaluation of the spontaneous ARs, for their seriousness & listedness/expectedness

• FU of spontaneous ARs reports, minimum FUs required, close out of the case etc.

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MANAGEMENT OF SAFETY DATABASE

No guidelines available from Indian regulators regarding management of safety data or maintenance & update of Company Core Data Sheet or Safety Information

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Current Practice : All the data collected during literature

searches, spontaneous adverse event reports, clinical & non clinical studies or from all the sources are collected & saved in the product safety file

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Signal Detection: -all the safety data collected should be evaluated -if trend becomes apparent, necessary action

should be initiated Problems: -Unique Medical Practices in India -High prevalence of polypharmacy -Pharmaceutical market in India is not well

regulated

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Problems… -lack of relevant data on spontaneous ADR

reports -unavailability of the trained staff for signal

detection -lack of the push/drive from the regulatory

agency Solution: -Generic drug companies in a country like

India should have strong system & expertise for signal detection

# Generally, Indian generic companies follow the global updates of the innovator’s label

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Periodic Safety Update Reports -Important PV tool design to include safety data on

a particular drug from all the sources & geographical regions

-DCGI recommends a single PSUR for all dosage forms, formulations & indication for one active substance.

-License holders are expected to include summary information along with the critical evaluation of the safety profile of a marketed drug in a light of a new changes during post authorization period.

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Formats & reporting in PSURs -Formats provided in Schedule-Y is similar to ICH

E2C format Reporting Cycle: - All new products, every 6 months for initial 2

years & then annually for next 2 years - Reports due for a period must be submitted within

30 calendar days from the last day of reporting period.

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SAFETY REPORTING DURING CLINICAL TRIALS

Sponsors Responsibility Investigators Responsibility Limitations of Schedule-Y : - does not specify rules regarding the reporting of

foreign cases from multinational trials -lacks further details on the procedures for

unblinding, coding etc -handling of the AEs associated with placebo or

comparator drugs

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PV OBLIGATIONS OF INDIAN COMPANIES WITH SUBSIDIARIES ABROAD

Schedule-Y: do not specify anything regarding the expedited reporting of SAR from other countries

Eudralex Volume 9A-Guidelines on PV for Medicinal Products for Human Use, clearly specifies the requirement for reporting of foreign cases & case reports from literature searches

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Solution:-Indian companies with subsidiaries in Europe; to

establish & maintain the safety databases for their products in India & centralize the PV activities such as

*literature searches *generation of CIOMS forms *signal detection * risk-benefit analysis *preparation of PSURs in India & QPPV locally in

Europe for regulatory interactions 17

CONCLUSION

In the past; never a compulsion to have a strong PV system to detect ADR of the marketed drugs

Presently; increased interest of Indian regulatory authority for PV activities

Limitations: -limited guidance available in Schedule-Y as

well as protocol published by the NPP

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CONCLUSION….

Challenges faced by the Pharma companies in India:

- Low level of reporting spontaneous ADRs - Lack of training of GPs on drug safety & ADR

reporting - Non availability of staff trained in PV - Lack of guidance from the Indian regulatory

authority due to the lack of expertise & experience.

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