Communication of Risk Changes: Benefits for Health Professionals (HCPs) and Patients are another important process of pharmacovigilance1. Awareness of product risks is essential for patient safety. One way to do this is to provide up-to-date product information (product characteristics summary (Smpc), patient brochure (PL) and packaging). In addition, according to the report of the pharmaceutical inspection Metrics (April 2016 – March 2017)3 of the British Medicines and Health Products Regulatory Authority (MHRA), the main results for maintaining reference safety information have increased significantly over the period under review. This section of the VPA should indicate whether there will be a company background sheet and who will manage it with who is responsible for updating local PMS. Another important aspect is to confirm who is responsible for communicating with regulators and how updates are shared (both within partner companies and with the public/HCPs). If the carefully defined data is not sufficiently defined, then even if the updates are completed, the information may not reach patients and HCPs in all areas where the product is marketed. If the update is motivated by the regulator that addresses one of the parties, notification deadlines should be set to the other party, as well as a dispute resolution clause regarding the reaction to the regulator. This provision should be defined so that the most appropriate party (i.e. the MAH or the company in the territory where the authority`s application was made) can communicate effectively with the Authority. With regard to the delegation of activities related to the pharmacovigilance system and its control file, the MAH retains the final responsibility for the pharmacovigilance system, the transmission of information on the PSMF site, the maintenance of the PSMF and its availability to the relevant authorities on request. Detailed written agreements should be concluded specifying the roles and responsibilities of the content, submissions and management of MSPs, as well as the implementation of pharmacovigilance in accordance with legal requirements. The pharmacovigilance system must be present and work when the product is approved and marketed.
EU legislation therefore requires any holder of marketing authorisation, the competent national authority and the EMA to set up a pharmacovigilance system. The entire European pharmacovigilance system operates through cooperation between EU Member States, the EMA and the European Commission. In some Member States, there are regional centres under the coordination of the relevant national authority. The summary of the pharmacovigilance system must be provided in module 1.8.1 of the application for marketing authorization and contains the following elements: As of February 1, 2016, any changes to the summary of the pharmacovigilance system – changes in QPPV (including contact information) and/or changes to the pharmacovigilance file (PSMF) will only be communicated to the authorities without further modification. As of this date, MAHs are not required to notify EMA or the relevant national authorities (if any) of changes to QPPV or PSMF data by submitting an IAIN-type NAINvariation. These training materials aim to develop existing knowledge about quality management systems and develop tools to support quality standards and best practices in pharmacovigilance systems. In any event, MAHs must meet the requirements of Community law. The provisions relating to Iceland, Liechtenstein and Norway under the European Economic Area Agreement are defined in the corresponding sections of the text.