Добавил:
Sekretar
kiopkiopkiop18@yandex.ru
t.me/Prokururor I Вовсе не секретарь, но почту проверяю
Опубликованный материал нарушает ваши авторские права? Сообщите нам.
Вуз:
Предмет:
Файл:Ординатура / Хирургия / Библиотека им академика М.И. Перельмана / Книга_5432_Библиотеки_им_академика_М_И_Перельмана.pdf
130 Cobert’s Manual of Drug Safety and Pharmacovigilance
cannot “talk” to each other. Rather, these cases may sit
in an electronic “holding area” and must be screened
by the triage or medical personnel for minimum valid-
ity criteria, correct drug identification, duplicates,
quality and so forth, before being uploaded into the
safety database. Uploading is normally instantaneous
when done electronically and has implications for the
“clock start date”. Some companies may allow direct
upload into their safety database from trusted, vali-
dated, and virus-free sources, such as partner compa-
nies or CROs.
Paper cases (including faxed, PDF, or other “paper
cases” that arrive “electronically” but not in files that
are directly uploadable as structured data) must be
manually entered into the database. Cases that are
identified at triage to be expedited reports are usually
prioritized for immediate data entry. Cases that are not
expedited reports are put into a queue for handling and
data entry. Serious cases that are to be manually entered
are usually “databased” within 7–15 days and non-
serious cases within 30 days. Companies’ procedures
vary widely. The EU requires non-serious cases to be
submitted electronically within 90 days.
The initially received information is entered into the
drug safety database after screening for the four mini-
mum criteria, the correct drug, and duplicates. Data
entry is usually performed by clerical personnel who
have been trained on how to enter cases into the com-
pany’s safety database and sometimes after training in
medical terminology. Some companies do manual data
entry at a single site or at multiple sites (e.g., one on
each continent). Most data, though not all, are entered
in English. Some documents may need to be translated.
Source documents may also be entered (either summa-
rized or scanned in or both), catalogued, and stored in
the database. Some data may need to be anonymized or
redacted to remove personal information. See the chap-
ter on Data Privacy.
Case Processing Unit
This unit is made up of health professionals, usu-
ally nurses and pharmacists, but occasionally also
podiatrists, dentists, and other healthcare profession-
als. This group does the initial evaluation for expedited
cases (as noted above, usually before data entry) and
then reviews and/or prepares the case medical infor-
mation. In particular, this involves the creation of the
“narrative” (which is a stand-alone chronological text
summary of the case that appears in the electronic case
[E2B] or on the MedWatch and CIOMS I forms if still
used), and the verification of drug names, dosages, past
medical history, and so on. The case-processing group
also prepares medical queries (with the assistance of the
physicians) to be sent to the reporter or investigator to
obtain further information if the initial data are incom-
plete, including the final outcome for ongoing cases.
Medical Case Review
This group is usually composed of physicians with
expertise in drug safety and case review. They generally
review the assessment, the AE coding, and the medical
content of the narrative to ensure that the medical story
is cogent and that it is a true reflection of the source
data supplied. These physicians may also handle other
work, including the preparation and review of signals,
aggregate reports, and ad hoc queries.
Transmission Unit
This group ensures that the appropriate cases are sent
to the appropriate recipients. Expedited reports either
go directly to the health agencies (usually by electronic
E2B transmission or paper) or to the regulatory depart-
ment for transmission to the health authorities. Cases
may also be sent within the company to other interested
parties (e.g., clinical research, legal) and to associated
business partners who market or study the drug. This
function may be assumed by a unit that handles all
safety “traffic” matters, including triage, routing, and
transmission. If the transmission is via E2B there may
not be a separate transmission unit, though someone
must still track what goes where and handle electronic
acknowledgement of receipt.
Organization of a Typical Drug Safety Department 131
PV Regulatory Intelligence
Usually part of Regulatory Affairs, but sometimes within
PV departments, a regulatory intelligence unit is needed
to identify new and future regulations or guidances.
(This is the responsibility of the EU QPPV in the EU).
A PV department must always be up to date on new or
updated regulations to remain compliant. In addition,
the responsibility of this team is to assess the conse-
quences for the PV team (organization, processes, tools,
goals, etc.) of a new or future regulation.
Regulatory Unit
Usually, this unit is not a part of drug safety but is a
separate division, at least in larger companies. In some
companies, expedited cases are reviewed by the regula-
tory group before transmission to the health authority
as a final quality check. Many companies prefer to have
all communications to and from the health authorities
handled by the regulatory division rather than by drug
safety and other groups to ensure tight tracking of all
governmental contacts.
Legal Unit
This unit is never a part of drug safety. The legal unit
interacts with drug safety in three primary areas.
First, in some companies, the legal department
reviews all cases that are sent to health agencies to ensure
that “troublesome” statements will not be included and,
thus, avoid statements that could inadvertently produce
difficulties for the company. (This is controversial, as
it may mean that the company cannot make a causal-
ity assessment on cases, as that might mean admitting
the drug and the company are “guilty” of causing that
ADR.)
The second area involves litigation or potential lit-
igation based on AEs. In these cases, the drug safety
and legal areas work tightly together in defending the
litigation and in obtaining any follow-up from the suing
party. Such follow-up is often done via the attorneys
rather than directly from drug safety. The legal unit may
also be a source of AEs that arise in lawsuits against the
company that first arrive in the legal department.
The third area is in negotiating agreements with
external parties for in- or out-licensing, outsourc-
ing, co-marketing, and so forth. The two groups work
together to ensure that all safety obligations to all health
authorities and business partners are met.
Signaling,
Pharmacovigilance,
Pharmacoepidemiology,
Medical Information or
Medical Affairs Unit
Although this function may be called many things, as
noted in the heading, its primary job is to look for new
safety signals. This unit is made up of physicians and
other healthcare workers. Their main function is to
review the safety data (AEs, medical errors, and prod-
uct quality complaints) collected by the company and
to evaluate whether new signals are popping up or old
ones are resolving or worsening. They may use tools
available commercially or developed in-house for data
mining When an issue is found, they begin an initial
safety investigation that includes a review of the pub-
lished literature, the company’s clinical research data-
base (if different from the safety database), external
databases, medical literature (which must be searched
weekly under EU regulatory requirements), toxicol-
ogy, pharmacology, and any other relevant information,
to prepare a summary report for presentation to the
decision-makers (e.g., the senior corporate safety com-
mittee) for resolution.
They may handle other functions, including review
of individual cases, preparation of Investigational New
Drug Application (IND) annual report, New Drug Appli-
cation (NDA) periodic reports (PADERs), Development
Safety Update Reports (DSURs), Periodic Safety Update
Reports (PSURs/PBRERs), integrated safety summaries,
132 Cobert’s Manual of Drug Safety and Pharmacovigilance
responses to queries from health authorities, pharmaco-
epidemiology studies and analyses, advertising review
for medical content, review of communications to the
public (“Dear Doctor” or “Dear Healthcare Profes-
sional” letters), review of labeling (e.g., Package Inserts
or SmPCs, etc.), medical testimony in litigation, and
consultation on drug restrictions or withdrawals. Some
of these functions may be split into separate groups,
such as a PSUR/PBRER preparation group, a pharmaco-
epidemiology group, and so forth, particularly in large
companies.
This group may also handle the preparation of risk
management documents such as REMS or RMPs.
Aggregate Report
Preparation
This unit, comprising physicians and other healthcare
professionals, sometimes separate from the PV unit,
prepares aggregate or summary reports of data derived
from ICSRs and sometimes other sources. These reports
include IND annual, NDA periodic reports, DSURs,
PSURs/PBRERs, benefit–risk assessment reports, ad hoc
and PSUR/PBRER-derived queries from health author-
ities, and other corporate departments or business
partners. They will sometimes prepare white papers or
literature reviews for internal and external scientific
requests for information.
Large and mid-sized pharma companies are
out-sourcing more and more of these tasks.
Labeling Review and Update
for Safety
This function is sometimes done within drug safety and
sometimes separately by the labeling group or regula-
tory affairs. It usually involves the clinical department
and requires the continuous monitoring of the labeling
of the company’s products to ensure that all the safety
(and other required labeling information) is fully up
to date and the transition to new labeling format and
content requirements in various countries is being
performed accurately and in a timely manner. This
includes examination of the reference safety informa-
tion (CCSI or regulator-approved professional labeling),
as well as local labeling documents (e.g., US PI, the EU
SmPC, etc.) and patient information leaflets. Areas of
interest include AE, warnings, precautions, contraindi-
cations, pregnancy and lactation, overdose, drug inter-
actions, and off-label use. This may be a very substantial
task if the company sells multiple drugs with multiple
formulations in many countries around the world.
For labeling updates, the PV department is respon-
sible for identifying and managing the safety signals,
being a part of the team making proposals for any pos-
sible labeling updates, as well as helping to deliver a
rationale supporting the proposed labeling update.
It may also require the monitoring of the safety
labeling of products of other companies’ drugs in the
same class as well as drugs that may have interactions
with the company’s drugs. For example, if company B
adds a statement to its drug’s labeling stating that there
is a drug interaction between the company B drug and a
company A drug, company A should determine whether
it should add a similar statement to its labeling. In most
jurisdictions a generic product must follow the labeling
of the innovator product.
Qualified (Responsible) Person
for Pharmacovigilance
This is a critical role for companies with marketing
authorizations in the EU and a large number of other
countries. This important role is discussed in greater
detail elsewhere in this manual. (See Specific Chapter
on EU QPPV)
Archive/File Room
Archiving involves several issues. First, there is now an
enormous amount of electronic information, including
e-mails, electronic case reports, lab data, and computer
files and programs. This is critical data that must be
backed up and archived. This is usually an IT function,
which is transparent to the drug safety group. This has
Organization of a Typical Drug Safety Department 133
become, with the advent of electronic storage and data
security and privacy rules, a very complicated matter.
Hacking may now become a problem.
In terms of paper, although there is a trend toward
the so-called paperless office, the amount of paper and
the number of photocopy machines used for drug safety
appear to be decreasing only marginally. The safety
department must make sure they have an adequate
archive/file room system (including shredders to securely
dispose of draft documents), such that all relevant safety
information is saved in the appropriate place and is read-
ily available for immediate review, whether by the com-
pany or during a health authority inspection. In terms
of electronic data, secure server parks (or “The Cloud”)
with backup and all appropriate privacy and data protec-
tion must be in place. If multinational data are stored in a
server or the Cloud then all applicable laws and require-
ments from the data’s source country must be in place.
Several logistical decisions need to be made for both
paper and electronic archiving concerning the follow-
ing things:
1. The storage of documents in a multinational
company where serious AE reports may come
in multiple languages: Should they be kept in
the country where they are received (and are
able to be read) or centrally or both? What
should be translated? And if translated, what
must be “officially” translated and what can be
translated using a fast but inaccurate computer
translation program?
2. Are the storerooms adequately protected from
fire, flood, insects, vermin, and other hazards?
Should sprinkler systems specifically not be
installed but rather an alternative system used
for fire protection?
3. Storing paper charts for tens of thousands of
cases per year (in a large company) can require
large physical storage areas. Should these cases
be kept on site or archived in a document stor-
age facility off-site?
4. What tracking system will be used? Should
bar codes or chips be used for paper files, and,
if so, for the folder jacket or for every docu-
ment inside? If a case has some parts stored as
paper and some as electronic files, should they
be merged and all stored electronically? How
should they be indexed and tracked? How will
follow-up data be stored and indexed?
5. How long should documents and electronic
files be retained? Note that retention rules differ
for various jurisdictions. In general, documents
should be retained for the longest time required
by any country whose documents are stored in
that archive. Some companies keep all safety
data forever.
6. Who has access to and control of the file room
and electronic files? Access should be for appro-
priately qualified persons and only on a need-
to-know basis.
7. What backup methods are used (e.g., in case of
fire or water damage, etc.) for paper and elec-
tronic records?
8. Are all privacy and anonymization regulations
being followed? Are the new EU requirements
in place?
9. If contract facilities (outside vendors) are used,
who supervises them and ensures the safe keep-
ing of the files and the ability to retrieve needed
files (e.g., for a health authority inspection)
within 24 hours?
10. Are paper and electronic files reconciled?
Note 1: One of the best options is to scan, or upload
and attach relevant documents to each ICSR within the
safety database. A decision must be made on whether to
retain the paper copy. Ideally, no, but there may be legal
and regulatory implications.
Note 2: Employee emails are often backed up on a
daily (or more frequent) basis and retained in an archive
according to company retention policy. The usual reten-
tion policy is ordinarily placed on indefinite hold when
litigation is involved for any given product.
Information Technology/
Informatics Liaison
Almost all drug safety departments use a commercial
database to store safety data and produce required
134 Cobert’s Manual of Drug Safety and Pharmacovigilance
output in prescribed timeframes. There is usually a
dedicated informatics/information technology (IT)
support and development group that works with drug
safety (“the business owners”) to support the database
and handle changes, bugs, new hires and access levels,
upgrades, MedDRA
®
and other dictionaries, testing, and
validation. Sometimes the IT support person(s) report
directly to the drug safety group and sometimes not.
Usually, the IT group is fully versed in the IT
aspects of the database but needs business input from a
“superuser” or drug safety expert who understands the
safety business and issues and who can speak the “IT
language” to facilitate communication. This IT liaison
function has various titles from company to company
but is found in nearly all companies because the need
to bridge the gap between the computer experts and the
safety experts is real and ongoing.
In large companies, the 24/7 maintenance of the
multiple databases involved in safety in one way or
another (clinical trial database, ePRO-electronic patient
recorded outcomes, safety database, telephone call
tracking database, product complaint database, labeling
database, etc.) requires IT departments of scores or even
hundreds of persons all around the world (wherever
someone has a computer or smart-phone, etc.). Link-
ing databases and ensuring database-to-database com-
munications (E2B), internally as well as with business
partners, and keeping up to date on other data stan-
dardization matters, is now a major operation in most
companies.
Quality Documents Creation
and Maintenance
Written formal SOPs, working documents, and guid-
ances are obligatory in drug safety departments under
Good Clinical Practices (GCP) requirements from the
International Conference on Harmonization (ICH),
the FDA, the European Medicines Agency (EMA), and
other agencies and bodies. In addition, there may be
manuals, guidances, and job aids that accompany the
SOPs (e.g., a data entry manual).
The first thing an FDA, EMA, inspector or internal
company auditor will ask for at the start of an inspection
or audit is often a copy of the organizational chart of the
safety department and list of the Quality Documents in
place. The SOPs govern the handling of everything in
PV: safety data, report preparation, training, database
and computer issues, crisis management, and so forth.
It is not uncommon for a company to have 50 or
more such SOPs and guidances. The creation, review
(yearly at least), maintenance, and updating of SOPs is
a function that must be ensured in a safety department
and must reflect any changes in regulatory require-
ments. The issue of version control of quality docu-
ments must also be addressed so that everyone has
access to and is working from the latest versions of the
SOPs and work instructions. This means controlled
distribution of electronic (or paper copies) of the latest
and applicable quality document (QD) for each partic-
ular job function.
Training
Another requirement of GCP and quality systems is
that training be done and documented before the SOP
or process is put in place or the person starts work. The
training, based on the SOPs, guidances, and working
documents, covers the following:
The concepts of drug safety, PV, and risk management;
The laws, guidances, and regulations currently in
place;
The specific procedures in that organization or
division and others, if appropriate (e.g., clinical
research);
Communication and escalation pathways for con-
cerns; and
The computers and software.
In addition, there is the more general training the
organization offers, on corporate values and workplace
behavior, equality issues, physical safety in the work-
place, and so on.
There is usually a formal training function or
department within drug safety with a dedicated trainer
(sometimes “certified” by some training body or orga-
nization either internal to the company or outside),
who develops formal curricula and courses for the
Organization of a Typical Drug Safety Department 135
various people (based on job function), who need to
be trained. This applies to both new hires and update
training for current employees. The training involves
the drug safety department workers as well as oth-
ers in the organization who might receive AEs in the
course of their own jobs (e.g., in clinical research, reg-
ulatory, legal, telephone operators, customer relations).
Each person in the safety department should have an
up-to-date and accurate training folder documenting
all training that person has had. This will often need to
be produced during a health authority inspection or a
third party or internal audit.
Much training is now done online with elegant
self-pacing and self-testing modules, allowing the indi-
vidual to do the training at his or her own pace and
timing (though by a certain due date). There are multi-
ple organizations that offer courses, both in-house and
externally.
Quality Assurance/Control
The concept of “quality assurance/control (QA/QC) and
quality systems” is relatively new to drug safety and GCP
compared with their use in the manufacturing and lab-
oratory areas. However, regulatory agencies in the US,
EU and elsewhere insist upon a formal quality function
and will inspect and audit to ensure this is in place and
functioning well. Quality is broadly broken up into two
phases.
The first is QA, which, as we refer to it in drug
safety, refers to actions taken during the process of han-
dling safety data to ensure that the work is correct and
complete. During the preparation of an ICSR for sub-
mission to a health authority by a pharmacist, the QA
might be done by his or her supervisor. This is quality
that must be built in up-front and executed during the
process. The view is that, if something bad has to be
picked up at the end of the workflow, when everything
is completed, it is too late. Corrections should be made
during the process and in real time.
The second phase is QC, which usually refers to a
review of the (final) deliverable. This is done to ensure
that the deliverables (e.g., the completed E2B file or
PSUR/PBRER) were correctly and completely prepared
and that no data are lost or changed along the way. QC
may include formal audits by third parties from outside
or inside the company or organization. Such audits/
inspections are routinely done at the end of the process.
The difference from QA is that the review is usually done
after the work product is completed. Note that confu-
sion exists since some use QA and QC interchangeably
or use QA to mean “after-process quality” and QC to
mean “in-process quality”. Others consider QA to be a
component of the overall QC system. In any case, qual-
ity must be done both during and after no matter what
we label it!
Organizations should have both quality functions in
place. During the processing and analysis of safety data,
quality checks should be performed at the appropriate
stages in the process. After the work is done, a review
or an audit may be done on selective cases routinely
or periodically (e.g., monthly) to see that the entire
process is done correctly. Key performance indicators
(KPIs) and other metrics should also be built in. With
these periodic KPIs and associated metrics, oversight
can be maintained using real-time data. These metrics
will also ensure that corrective and preventive measures
(CAPAs) are set up, sustained and are effective. Many
safety departments in companies have a yearly audit
done by their corporate quality group (separate from
the drug safety group) or by an external PV auditor/
consultant. Of course, the health agencies (the FDA,
EMA, and Medicines and Healthcare Products Regu-
latory Agency [MHRA] in particular) do periodic PV
inspections to check the quality of the safety depart-
ment’s work.
Safety (AE) Exchange
Agreement Function:
Creation and Maintenance
Many pharmaceutical companies, both large and small,
now enter into agreements with other companies to
out-source or share certain responsibilities, such as
co-marketing in the same country, marketing in other
countries, clinical trials (including development, mon-
itoring, and data analysis), manufacturing, and safety
data handling.
136 Cobert’s Manual of Drug Safety and Pharmacovigilance
As with other business arrangements, it is oblig-
atory that all parties involved have written contracts
specifying the safety functions and requirements of all
partners. The contract should set specific terms for the
exchange of all needed safety data, both individual case
safety reports and aggregate reports such as PSURs/
PBRERs and NDA periodic reports as well as labeling,
investigator brochures, advertising, and regulatory com-
munications. This must be done so that all partners are
able to stay in full compliance with all regulations and
laws. In the European Union, the QPPV must ensure
that this function is done completely and correctly.
Literature Review
United States and European Union regulations, as
well as those elsewhere, require periodic review of the
worldwide literature to ensure that published reports of
safety information on a company’s products are found
and reported to health authorities. This involves a com-
puterized literature search (weekly as required in the
European Union) of large databases that scan hundreds
to thousands of medical journals and then report on
“hits” (i.e., citations containing the drug in question or
any other keywords designated in the search).
Once a safety case is found that meets reporting cri-
teria (drug, AE, patient, reporter), the usual reporting
requirements (e.g., 15-calendar days for an expedited
report) apply. The safety department must ensure that
this function, usually done in conjunction with the cor-
porate library or an outside vendor, is performed in a
correct and timely manner. This can be a complex task
as it is required that both branded and generic cases be
included in the literature search and reported in PSURs/
PBRERs. Issues of timing, clock start, and translation
must be worked through.
In the EU, the EMA has set up a literature review
for many products that they perform and make public.
However (and unfortunately) even with this medical
literature monitoring by the EMA, pharma companies
still must check literature on a weekly basis. When a lit-
erature case report is identified, it must follow the “clas-
sical” rules for recording and reporting (same criteria
and timeframes as for spontaneous reports).
Data Dictionary Maintenance
In this sense of the word, a “dictionary” is a listing of
standardized and fixed terms that companies and regu-
lators agree to use. This is particularly important when
data are exchanged electronically. If an unknown term
is used in sending a case from one company or health
authority to another, the receiving computer system
often rejects (or at least notes, or “flags”) the case for
attention.
MedDRA is the standard dictionary used for the
coding of AE terms. Other (now largely outmoded) AE
dictionaries include COSTART, WHO-ART, and HARTS.
Dictionaries exist for the standardization of drug names
(e.g., WHO’s Drug Dictionary), abbreviations, labora-
tory measurements and units, and so forth.
A more global dictionary now being used primarily
in the United States, the United Kingdom, Canada, Aus-
tralia, Denmark, Netherland, Sweden is SNOMED CT.
SNOMED CT stands for Systematized Nomenclature of
Medicine–Clinical Terms and is claimed to be the most
comprehensive multilingual clinical healthcare termi-
nology in the world. The US Department of Health and
Human Services is using SNOMED to build “a national
electronic healthcare system that will allow patients
and their doctors to access their complete medical
records anytime and anywhere they are needed, leading
to reduced medical errors, improved patient care, and
reduced healthcare costs”. It is likely that at some point
SNOMED will be used with or instead of MedDRA. It is
also likely that a mapping of MedDRA into and out of
SNOMED will be done at some point.
Coding Unit
Again related to dictionaries, in particular to MedDRA,
the use of a standardized coding dictionary also implies
the use of this dictionary in a standardized manner.
That is, every member of the drug safety staff (and any
other unit that does coding, such as clinical research)
should be taught to code in the same manner using the
same methodology and conventions to achieve internal
consistency. This is done through a central coding unit
(within or outside of drug safety) that either does the
Organization of a Typical Drug Safety Department 137
actual coding or verifies the coding done by the drug
safety personnel. Not all companies have this function
and those that do not will often suffer through coding
reconciliation at the end of a study or at the time aggre-
gate reports are prepared.
Planning and Project
Management/Operations
Many pharmaceutical companies are now integrating
project planning directly into the drug safety unit to
oversee and facilitate the multiple and ongoing changes
that now seem to be a part of daily life in drug safety.
This includes ensuring a smooth integration of ongo-
ing safety work by introducing new procedures, soft-
ware and hardware, and dictionaries. For example,
regulations change frequently around the world and
all of them must be adhered to even though they may
sometimes be contradictory. Other usual occurrences
include MedDRA upgrades twice a year, safety database
upgrades or transfer to a new platform, and new con-
tracts signed with business partners.
To coordinate the successful implementation of
these ever-changing requirements, a solid operations
and project planning/management function must be in
place to manage contingencies, timing, personnel, and
communications. Many of these functions are being
combined with or handled by the life cycle risk man-
agement groups so that they address global planning
for all aspects of a drug’s “needs”, including drug safety
and PV.
Risk Management
Risk management throughout the entire life cycle of a
drug is now obligatory and looked at during HA inspec-
tions. Companies now form an internal (or use an
external) function to handle risk management analysis
and planning. At the early stages of a drug’s life cycle
the risk management functions may be small. However,
as the drug enters clinical testing, real-time serious
risk management must be done at all stages to ensure
that patients are protected, that the drug is developed
rationally, and that no major risks that could have been
found earlier are discovered at the last minute. Risk
management and minimization is now obligatory in the
United States, the European Union, and elsewhere. This
is discussed elsewhere in this manual.
Liaison to External
Organizations/Drug Safety
Intelligence
Many companies and health authorities regularly attend
meetings held by international organizations that exam-
ine and develop new guidances and procedures. These
include the ICH, CIOMS, Pharmaceutical Research
Manufacturers of America (PhRMA), EFPIA, CDISC,
HL-7, the International Society of Pharmacoepidemiol-
ogy, the Drug Information Association, and many others
as well as FDA, EMA and national health authorities.
Pharmaceutical companies send personnel from their
drug safety units to these meetings. Attendees are either
employees whose sole or primary function is to repre-
sent the company at external organizations or ad hoc
representatives chosen because of the duties they per-
form in their companies. The use of Zoom, webcasts and
other electronic meeting options are making attendance
at some meetings easier and less expensive by eliminat-
ing travel time and costs.
Participation in these meetings is critical for the
future of PV because these organizations continue to
spearhead the changes and advances in drug safety. ICH
has produced many guidances that now form the basis
for pharmaceutics in the United States, the European
Union, and Japan. CIOMS developed the “CIOMS I
form” and “CIOMS II line listings”, among others.
This group may also serve as a “safety intelligence
unit”, gathering information on new laws, regulations,
and guidance that touch drug safety. They then dissem-
inate this information to relevant departments in the
company. If this function is not done here, it must be
done elsewhere in the company to be sure that the com-
pany is up to date and in full compliance with all rules
and requirements.
138 Cobert’s Manual of Drug Safety and Pharmacovigilance
PV Worker Education, Skills,
and Profile
The needed PV education, skills and profile can vary
depending on the company’s products, the size of the
department, the organization, affiliate versus corporate
role, etc. The purpose of this section is to give an over-
view on the “nice to have” education, skills and pro-
files, to achieve the PV mission, but also to ensure full
control of all PV activities at both affiliate and corporate
levels. Most of the information below is applicable to
a person leading a PV team (alone or with a team of
co-workers). This topic represents one facet of a quality
system that keeps patient safety as the main priority of
the organization.
Education
More and more often, regulations ask for a medically
qualified person (i.e. physician) to head the PV depart-
ment. This means that if not medically qualified (basic
medical training at academic level which usually but
not always means a physician), this person must have
permanent access to a physician (access shall be duly
documented). Training in a specialty (internship & res-
idency) is very desirable but not obligatory.
Whether based at the local or corporate level, the
person leading the PV team must actually have expert
knowledge on the most frequent drug-induced diseases
and safety issues. In addition, he/she must ideally have
robust knowledge of Leadership, Regulatory Affairs,
QA, IT/IS project management and be able to work in
English.
Note: Within large PV organizations, specific safe-
ty-related units are set up: case assessment, data entry,
QA and PV compliance, pharmacoepidemiology, aggre-
gate/periodic report preparation and delivery, IT/IS
support, etc. For jobs within these units, PV members
should have an education which is focused on their
activities. They do not necessarily need to have an MD
or PharmD education. We are seeing many excellent
employees now with health-related training such as
nurses, nurse practitioners, physician assistants, as well
as occasional dentists, podiatrists, “biologists”, etc. The
job description for each position should carefully state
the needed and “nice to have” education, training, and
experience. These should be customized and tailored
to the specific roles and responsibilities within the PV
group.
Skills
Junior PV persons need to handle basic roles within PV
departments: answer phone calls from healthcare pro-
fessionals (HCPs) or patients, document case reports,
analyze ICSRs, record ICSRs within the PV database,
provide HCPs and patients with additional written
information on the case reports, work on safety issue
analysis, prepare safety aggregate reports, work on risk
management plans and implementation, participate
in the defense of submissions of safety dossiers and
reports in front of Health Authorities (HAs), etc. These
are very interesting tasks that personnel who are mak-
ing a career in PV should learn. With such experience,
personnel will better understand the daily tasks, mis-
sions and objectives of the PV team and provide more
accurate proposals, recommendations or requirements.
This is the way to advance in PV.
A broader training than just PV is usually a clear
positive. Employees coming from Regulatory Affairs,
Clinical Development, Medical Affairs or other func-
tions can move into PV and advance equally well. In
addition, getting people with affiliate experience when
working in a corporate environment (or vice versa) is
always useful. Achieving a high level of PV is intrin-
sically linked to the availability of an adequate num-
ber of competent and appropriately trained personnel.
In addition, to trained personnel, the organization
has an obligation to provide appropriate facilities and
equipment so the work can get done.
English: Good knowledge fluency in English is, in
practice, needed in most situations even though there
are few, if any, actual regulations or laws requiring this.
English is the de facto language used by all or almost all
PV employees, both in private and public environments.
Organization of a Typical Drug Safety Department 139
Therefore, a good English level, even if working in an
affiliate, is needed. Any exchange between affiliates
and Headquarters must usually be written in English.
If English knowledge or usage are insufficient, PV
employees should continue English language training.
Obviously, care must be taken to avoid incorrect or
unclear English. This could lead to problems or mis-
understanding in ICSR narratives or, which could neg-
atively impact or delay the conclusion, the decisions to
take and/or the measures to implement.
Crisis experience: PV employees must be
able to work under pressure and react quickly when
needed, in case of safety crisis for instance. PV crises
often have common elements but each one is different.
Each crisis can have nuanced aspects relating to the
product in question but also to the company, whether
the issue is in one or multiple countries, were there
deaths, is there a recall required, etc. Considering the
current bad image of pharmaceutical companies, hav-
ing PV employees experienced in crisis management
(by education or by experience or by both) is very
important. Many companies have employees trained in
crisis management, media communications, etc. There
should be an SOP for crisis management (though it’s
not always called this) and PV employees should be
familiar with it.
Clinical development strategy and meth-
odology: Thanks to their knowledge of overall safety
and PV, more and more pharmaceutical companies are
involving PV employees in the management of safety
during clinical development. They not only handle
the processing and analysis of serious AEs but safety
personnel also provide support in safety data analysis,
including the safety analysis plans, signal detection,
benefit–risk assessment, and project management. They
may also set up and manage Data Monitoring Commit-
tees, Safety Committees, etc. Personnel moving from
clinical development to PV can then be of added value
for the PV team.
Epidemiology and pharmacoepidemiol-
ogy: PV, epidemiology and pharmacoepidemiology are
now closely interlinked partners in the pharma world.
Considering the permanent evolution in this area, it is
illusory for a PV expert to reach a top level and think
he or she can keep it for the long term! Continuous
changes occur and one must never stop learning. Nev-
ertheless, mastering the basics of epidemiology and
pharmacoepidemiology is needed to evaluate and per-
haps challenge the proposals made by these partners.
Regulations: Most PV employees, being MDs
and PharmDs and other medical professionals, are
usually not fans of regulations and lawyers! Never-
theless, as highlighted in many chapters in this man-
ual, regulations become more and more constraining.
Often, they are contradictory or have many loopholes
or possibilities for “waivers”. Sometimes they are writ-
ten with enormous detail, e.g., the EU GVP modules,
and sometimes they are very high level, e.g., FDA
regulations compared to the EU modules. Oftentimes
they are written in arcane language. Yet they must be
known, understood, and complied with in any PV
department. Having PV employees with a previous
professional background in a regulatory environment
can help.
Profile
Availability and reactivity: In most countries,
the PV department’s head is supposed to be available
24/7 in case of major/critical safety issue occurrence.
Even if rare, an urgent safety issue can actually occur
at any time. This generates an unscheduled workload
for which people must be fully dedicated on an urgent
basis. We therefore must be available but also very reac-
tive to manage such tasks in the best possible way. If
not feasible within the company, an external group, e.g.,
CRO or poison control center, etc., must be available.
Ultimately the responsibility still falls on the company,
e.g., MAH, NDA or IND holder, etc.
Rigorousness: No matter what one’s background and
training, PV requires rigor and compulsiveness to be
sure all the appropriate data, follow-ups, analyses, etc.,
are obtained to ensure a fair and complete review of
any safety issue and a balanced benefit–risk assessment.
Note that many safety matters must be decided quickly
and a full and complete dataset is rarely available.