PV001: SOP FOR PHARMACOVIGILANCE (PV) SYSTEM MANAGEMENT & QPPV RESPONSIBILITIES

OBJECTIVE:

  • To define the system for managing Pharmacovigilance (PV) activities and to describe the responsibilities of the Qualified Person for Pharmacovigilance (QPPV) to ensure compliance with WHO, EU-GVP, and local regulatory requirements.

SCOPE:

  • This SOP applies to all PV activities in the organization, including safety data collection, evaluation, reporting, maintenance of PV system documents, and oversight of PV partners.

RESPONSIBILITIES:

Qualified Purson for Pharmacovigilance (QPPV):

  • Ensure continuous and overall oversight of the company’s PV system.
  • Be permanently and continuously available (directly or via delegation during absence).
  • Ensure the safety profile of all company products is monitored.
  • Review, approve, and oversee:
        • Individual Case Safety Reports (ICSRs)
        • Periodic Safety Update Report (PSUR)
        • Periodic Benefit-Risk Evaluation Report (PBRER)
        • Business Continuity Plan (BCP)
        • Signals and risk minimization measures
  • Ensure timely submission of ICSRs, PSURs, RMPs, signals, and regulatory notifications.
  • Maintain the Pharmacovigilance system master file (PSMF) and ensure accuracy of its content.
  • Ensure PV training is provided to all employees (training management follows QMS training SOP).
  • Ensure safety agreements (SDEA) are in place with external partners and are properly implemented.
  • Oversee safety-related quality issues and deviations.
  • Participate in audits and regulatory inspections.
  • Ensure systems are in place for signal detection, risk communication, and crisis handling.
  • Act as the primary contact for regulatory authorities on PV matters.
  • Ensure backup QPPV or deputy is nominated, trained, and competent.
  • Provide medical assessment when required.

Backup QPPV:

  • Act in place of QPPV during absence.
  • Follow same responsibilities within delegated scope.

 Head PV:

  • Manage day-to-day PV activities.
  • Ensure AE collection and documentation.
  • Coordinate with RA, QA, production, medical, and external partners.
  • Maintain PV logs (ICSR, signal, literature).
  • Provide inputs for PSURs and PSMF.
  • Coordinate safety-related communications.

 Regulatory Affairs (RA):

  • Ensure country-wise reporting timelines are updated and available.
  • Submit PSURs, RMPs, and safety notifications to authorities.

 Quality Assurance (QA):

  • Manage deviations, CAPA, change control as per QMS.
  • Ensure PV requirements are included during supplier qualification and contracts.
  • Ensure PV documents are archived as per QMS.

Production / Warehouse / Field Staff

  • Report any Adverse Event (AE), complaint, or product issue immediately to PV.

DEFINATIONS:

  • Pharmacovigilance (PV) System: A Pharmacovigilance System is a comprehensive, legally required organizational framework established by a marketing authorization holder (MAH) to ensure ongoing monitoring of the safety of its medicinal products.
    Qualified Person for Pharmacovigilance (QPPV): A QPPV is a legally designated, highly qualified individual responsible for the overall safety oversight of the company’s medicinal products marketed in a country or region.
  •  Pharmacovigilance System Master File (PSMF): A Pharmacovigilance System Master File (PSMF) is a comprehensive, detailed, and continuously updated document that describes the entire PV system of the marketing authorization holder.
  •  Individual Case Safety Report (ICSR): An Individual Case Safety Report (ICSR) is a structured, complete, and validated report of a suspected adverse drug reaction (ADR) observed in a patient.

PROCEDURE:

PV System Establishment:

  • Establish a structured PV department with defined roles.
  • Ensure QPPV and deputy are appointed and documented via organizational chart.
  • Maintain PSMF describing the PV system, sites, responsibilities, procedures, and contracts.
  • Review and update PV SOPs periodically.
  • Maintain validated safety databases for case management.

Oversight of PV Activities:

  • QPPV performs periodic reviews of:
      • Case reporting compliance
      • Literature screening compliance
      • Signal detection activities
      • PSUR/RMP preparation status
  • QPPV conducts monthly PV review meetings with documented minutes.
  • Escalate significant safety findings to top management immediately.

Interaction with Cross-functional Units:

  • QPPV or PV manager communicates with QA for quality-linked safety issues.
  •  Regulatory Affairs (RA) provides regulatory updates to PV.
  •  All departments route AE/PQC information immediately to PV.

 Safety Agreements (SDEA) Oversight:

  • QPPV ensures all partners (CRO, distributor, CMOs) have signed SDEA.
  •  QPPV periodically reviews compliance of partners.

 Regulatory Communication:

  • QPPV ensures accurate and timely reporting of all ICSRs.
  • QPPV acts as regulatory contact for urgent safety matters.
  • Safety communications (DHCPL, field safety notices, recalls) are reviewed and approved by QPPV.

PV Documentation Management:

  • All PV documents are controlled as per QMS document control SOP.
  • Maintain PV logs and registers.
  • Archive safety data securely and retrieval-ready.

 Training:

  • All employees shall undergo initial and periodic PV training.
  • Training records shall be maintained as per QMS training SOP.

 Deviation and CAPA:

  • Deviations related to PV activities shall follow Quality Management System (QMS) deviation & CAPA SOP.
  •  QPPV must review PV-related deviations.

 Records:

The records below shall maintain:

  • Appointment letters of QPPV and backup
  • Job Responsibilities QPPV and Back up QPPV
  • Organizational chart
  • PSMF
  • PV logs (ICSR, literature, signals)
  • Review meeting minutes
  • Safety Data Exchange Agreements (SDEA)
  • Training records

 REFERENCES:

  • WHO Technical Report Series (TRS) – PV guidance
  •  EU Good Pharmacovigilance Practices (GVP)
  •  Company QMS SOPs (Document Control, Training, Audit, Risk Management, Deviation & CAPA)

RECORDS:

Sr No. Title Document No.
NA NA NA

 REVISION HISTORY.

Amendment Date: Update Summary Version No.
NA New SOP 01

 

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