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:
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- 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
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- 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:
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- Case reporting compliance
- Literature screening compliance
- Signal detection activities
- PSUR/RMP preparation status
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- 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 |