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Nat ional Medicines Agencies roles in Pharmacovigilance. EU legislation for VMPs Istanbul, 18 – 19 April 2011 Jiří Bureš Institute for State Control of Veterinary Biologicals and Medicines. Pharmacovigilance – legal basis. Directive 2001/82/EC, as amended by Dir. 2004/28/EC Art. 72 - 79
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National Medicines Agencies roles in Pharmacovigilance EU legislation for VMPs Istanbul, 18 – 19 April 2011 Jiří Bureš Institute for State Control of Veterinary Biologicals and Medicines
Pharmacovigilance – legal basis • Directive 2001/82/EC, as amended by Dir. 2004/28/EC • Art. 72 - 79 • Regulation (EC) 726/2004 • Art. 46 - 54 • Commission Regulation (EC) No 540/95, • arrangements for reporting suspected unexpected adverse reactions which are not serious, whether arising in the Community or in a third country, to centrally authorised medicinal products for human or veterinary use
Pharmacovigilance – guidelines (1) • European Commission Guidelines • http://ec.europa.eu/health/documents/eudralex/vol-9/index_en.htm • EU Pharmacovigilance Rules for Human and Veterinary Medicinal Products (Version June 2004) • Guideline on monitoring of compliance with pharmacovigilance regulatory obligations and pharmacovigilance inspections for veterinary medicinal products (March 2007)
Pharmacovigilance – guidelines (2) • EMA guidelines • See http://www.ema.europa.eu/ema/index.jsp?curl=pages/regulation/document_listing/document_listing_000170.jsp&murl=menus/regulations/regulations.jsp&mid=WC0b01ac058002ddca for a full list of guidelines • Guidelines dedicated to competent autrhorities: • Guideline on procedures for competent authorities for pharmacovigilance information for veterinary medicinal products • Guideline on harmonising the approach to causality assessment for adverse reactions to veterinary medicinal products
Pharmacovigilance – guidelines (3) • Guideline on a strategy for triggering pharmacovigilance investigations preceding regulatory actions by EU competent authorities • PSUR Assessment Report template for use by Member States • Note for guidance pharmacovigilance of veterinary medicinal products • Recommendation for the basic surveillance of Eudravigilance Veterinary data
Scope of veterinary pharmacovigilance (1) • Clinical safety of veterinary medicinal products • Benefit : risk for target & non-target species • Lack of expected efficacy and misuse • Human reactions to veterinary medicines • User safety • Epidemio-surveillance of resistance • Potential environmental issues • Environmental • Violation of MRLs • Consumer safety • Transmission of any infectious agents via VMPs • 3rd countries
Scope of veterinary pharmacovigilance (2) • Safety following off-label use of veterinary medicinal products • Additional information collated by the veterinary pharmacovigilance • (serious) abuse of veterinary medicinal products • medicated feeds investigation following reaction after use of a medicated pre-mix • use of human MPs in animals
Pharmacovigilance as a discipline (1) • Scientific • Data collection and analysis, signal detection • Continuous Benefit : risk of VMPs • Causality evaluation / Assessment of reports (PSURs) • Regulatory • Requirements for MAHs • Requirements for vets / health care professionals • Requirements for NCAs • Actions on VMPs due to pharmacovigilance • Art. 78 referrals • Pharmacovigilance inspections • Description of the pharmacovigilance system in the dossier submitted in support of the MA applications
Pharmacovigilance as a discipline (2) • Organisational • Promotion of pharmacovigilance • Education (vets, farmers, MAHs) • National / EU level (e.g. PSUR worksharing) • Pharmacovigilance x Marketing authorisation • Pharmacovigilance x Inspections / RAS
Pharmacovigilance in the current legislation • Directive 2004/28/EC • introduced higher importance for veterinary pharmacovigilance in the product lifecycle • One renewal of MA for VMPs • Two if justified by pharmacovigilance • Benefit : risk evaluation througout the product lifecycle • PSURs • Role • Frequency …..Current development in the area of human medicines
National authorities roles • Creation of national legal framework for veterinary pharmacovigilance • Priority area • In compliance with EU legislation • Dir. 2001/82/EC, Reg. 726/2004 • Detailed satutory requirements harmonised at the EU level for MAHs • Limited room for any national requirements • Specific national requirments – likely to introduce increased administrative burden and may impair efficiency of the system as such • Room / need for national arrangements with respect to vets / health care professionals / farmers (animal owners)
National authorities roles • Establishment of national pharmacovigilance systems • Priority area • Pharmacovigilance system – to capture as much pharmacovigilance incidents occuring in the field as possible • CZ – approx 1 ‰ of incidents reported through the official pharmacovigilance channels • Quality of reports • Rely as much as possible on science, proffession, ethics • Statutory requirements, however, necessary
National authorities roles • Establishment of national pharmacovigilance systems • All important stakeholders need to be targeted • MAHs • Vets • Animal owners • Pro-active approach by the NCA • Feed back to the reportes • Science / professional approach • Sharing of information • Transparency • Promotion, Education
National authorities roles • Electronic reporting (EV VET) • Statutory requirements as from November 2005 in the EU/EEA • Exchange, processing and evaluation of pharmacovigilance reports as required by the legislation • EU bodies (EMA) • Member States • Industry • Data analysis • EVVet DataWarehouse
National authorities roles • Electronic reporting (EV VET) • Recommendation for the basic surveillance of Eudravigilance Veterinary data (EMA/CVMP/PhVWP/471721/2006) • Mainly for centrally authorised products at the moments • Further development • EU product database • EudraPharm project
National authorities roles • Links to MA departments / authorities • Pharmacovigilance – integral part of the benefit : risk evaluation of VMPs • Training • Communication channels between the MA assessors and pharmacovigilance assessors • Description of the pharmacovigilance system (Part I) • Pre-authorisation evaluation • In general, limited information available • Post-authorisation evaluation
National authorities roles • Links to inspection departments / authorities • Pharmacovigilance reports – quality defects investigations • (Product related) inspections in MAHs / manufactures • Pharmacovigilance inspections • Planning • Methodology
National authorities roles • Pharmacovigilance inspections • Detailed guidance adopted in 2007 • Guideline on monitoring of compliance with pharmacovigilance regulatory obligations and pharmacovigilance inspections for veterinary medicinal products (ENTR/ F2 D(2007)) • Still large differences between the Member States • Difference from other type of enforcement inspections • Collaborative approach • Helping to understand role and importance of veterinary pharmacovigilance in the lifecycle of VMPs • Importance of the efficient and working systems at the MAHs
National authorities roles • Promotion of veterinary pharmacovigilance • Essential part of the daily job for the pharmacovigilance staff • Has to reflect national conditions • All stakeholders to be addressed • Explanation of importance of effective pharmacovigilance reporting • for the benefit : riks profile of VMPs • Safe and effective use of VMPs by vets / animal owners in the field
National authorities roles • Different forms may be employed • Feedback to reports • Websites • Dedicated websites • CZ – VETTOX • Assistance in investigations of the pharmacovigilance reports • ! Industry role to be considered as well • Availability of local pharmacovigilance contacts points • Language, assistance, feedback • Simple tools for pharmacovigilance reporting by vets / farmers • Articles in the scientific (professional) journals • Education (students, vets, farmers) • Others
Thank you for your attention ! bures@uskvbl.cz