Effective Preparation for Pharmacovigilance Inspections: Key Steps for MAHs

Effective Preparation for Pharmacovigilance Inspections: Key Steps for MAHs

Pharmacovigilance (PV) inspections are a crucial part of ensuring public health safety within the European Union (EU). These inspections are conducted by national competent authorities in cooperation with the European Medicines Agency (EMA) to verify that marketing authorisation holders (MAHs) are meeting their pharmacovigilance obligations.

Effective Preparation for Pharmacovigilance Inspections: Key Steps for MAHs
Effective Preparation for Pharmacovigilance Inspections: Key Steps for MAHs
Why Are Pharmacovigilance Inspections Conducted?
The primary objectives of pharmacovigilance inspections are:
  • To confirm that the MAH has the necessary personnel, systems, and infrastructure to fulfil pharmacovigilance duties.
  • To identify and address non-compliance that may pose risks to public health.
  • To enable enforcement actions where deficiencies are detected.
Types of Pharmacovigilance Inspections
    1. Based on Scope
    • System Inspections: Focus on the MAH’s overall PV system (processes, staff, facilities).
    • Product-related Inspections: Target specific products but may also review system elements relevant to them.
    1. Based on Timing or Trigger
    • Routine Inspections: Pre-scheduled, typically system-focused, sometimes using specific products as examples.
    • “For Cause” Inspections: Triggered by specific concerns (e.g., risk signals, complaints, or data irregularities).
    1. Based on Authorisation Status
    • Pre-authorisation Inspections: Conducted to review proposed PV systems before a product is approved.
    • Post-authorisation Inspections: Assess compliance after the product has been authorised for the market.
    1. Based on Notification
    • Announced Inspections: Usually notified in advance, allowing preparation.
    • Unannounced or Short-notice Inspections: May occur where notification would undermine the inspection’s purpose.
    1. Re-inspections
    • Performed when there’s a need to verify implementation of corrective actions or based on a risk-based prioritization.
    1. Remote Inspections
    • Conducted using online tools, particularly useful when key PV sites are located outside the EU or face access limitations.
Key Responsibilities of Marketing Authorisation Holders and Applicants
To be adequately prepared for PV inspections, MAHs must:
    • Be Inspection-Ready at All Times
    Unannounced inspections can occur; maintain a compliant PV system at all times.
    • Maintain the Pharmacovigilance System Master File (PSMF)
    This must be readily accessible and provided within 7 calendar days of request.
    • Facilitate Site Inspections
    Ensure any third-party sites (CROs, affiliates) agree to be inspected and are cooperative.
    • Provide Complete Documentation
    All relevant records and data must be made available promptly during preparation or on-site review.
    • Ensure Staff Availability
    Key PV personnel must be present for interviews and clarification during the inspection.
    • Data Accessibility
    PV data must be accessible from at least one location in the EU.
    • Implement CAPA (Corrective and Preventive Actions)
    Findings must be addressed with timely and prioritized corrective action plans.
How to Prepare for a Pharmacovigilance Inspection: Pro Tips
  1. Regular Internal Audits: Review compliance with GVP guidelines and address gaps proactively.
  2. Update SOPs and Training Records: Ensure procedures are current and staff training is documented.
  3. Mock Inspections: Conduct simulated inspections to test preparedness and staff responses.
  4. CAPA Follow-up: Maintain a CAPA tracker and evidence of timely implementation.
  5. Ensure PSMF Accuracy: Regularly review and update your pharmacovigilance system master file.
  6. Vendor Oversight: Monitor third parties performing PV activities and include them in inspection preparedness.
  7. Documentation Readiness: Have all essential documents (e.g., safety reports, contracts, audit trails) organized and readily retrievable.
Conclusion:

Pharmacovigilance inspections are vital to the EU’s drug safety framework, ensuring that marketing authorisation holders maintain compliant systems to protect public health. Sustained preparedness, transparency, and collaboration between regulators, industry, and partners like Masuu are essential to advancing pharmacovigilance and ensuring the safe use of medicines.”

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