OBJECTIVE:
- To define the procedure for preparation, approval, maintenance, and control of the Pharmacovigilance Master File (PSMF) in accordance with World Health Organization (WHO) guidelines, European Union Good Pharmacovigilance Practices (EU-GVP) Module II, and applicable national PV regulations.
SCOPE:
-
- This SOP applies to all activities related to creating, updating, managing, and maintaining the PSMF for all marketed products of the company, including products under World Health Organization Prequalification (WHO-PQ), and products registered in countries requiring a PSMF or equivalent document.
RESPONSIBILITIES:
Qualified Person for Pharmacovigilance (QPPV):
- Ensure the PSMF is accurate, complete, and continuously updated.
- Approve the PSMF and major revisions.
- Maintain oversight of content provided by all departments.
- Ensure availability of PSMF to regulatory authorities upon request.
- Ensure PSMF reflects the real functioning of the PV system at all times.
- Prepare, draft, and update PSMF modules.
- Collect and verify PSMF inputs from RA, QA, Production, QC, Medical.
- Maintain PSMF Logs (version log, update log).
- Ensure timely updates to Annexures and relevant sections.
- Coordinate with back up QPPV and cross functional teams (CFTs) during audits and inspections.
Regulatory Affairs (RA):
- Provide country-specific regulatory PV requirements.
- Maintain list of product registrations and safety reporting timelines.
Quality Assurance (QA):
- Provide QA system elements relevant to PV (training compliance, deviations, CAPA).
- Ensure PSMF documents are archived as per QMS requirements.
DEFINATIONS:
- Pharmacovigilance Master File (PSMF): A detailed, complete document describing the PV system used by the company for its products.
- Qualified Person for Pharmacovigilance (QPPV): Person with legal responsibility and oversight of the PV system.
- Individual Case Safety Report (ICSR): Report of an individual patient’s adverse experience.
- Periodic Safety Update Report (PSUR): Regular report summarizing safety data.
- Periodic Benefit–Risk Evaluation Report (PBRER): Updated evaluation of benefit–risk balance of a product.
PROCEDURE:
Structure of the PSMF:
- The PSMF shall contain the following sections as per EU-GVP Module II:
-
-
-
- Main Body:
- Organizational structure of PV system
- Roles & responsibilities (including QPPV and deputy)
- System description
- Computerized systems used for PV
- Sources of safety data
- Processes for ICSRs
- Processes for Risk Management Plan (RMP)
- Periodic Safety Update Report (PSUR)
- Periodic Benefit–Risk Evaluation Report (PBRER)
- Signal management system
- Quality system description
- Performance indicators of the PV system
- Annexures such as Product list, QPPV and Back up QPPV JD and contact details, Organization chart, List of SOPs, List of partners & Safety Data Exchange Agreements (SDEA), Training records summary, PV audit schedule summary, List of computer systems and validation status, Complaint and AE reporting forms, Risk-minimization measures summary
- Main Body:
-
-
Preparation of the PSMF:
- Back up QPPV drafts the initial PSMF based on current PV system.
- QPPV reviews the draft for accuracy and completeness.
- Pharmacovigilance Head Approves PSMF.
- The approved version is stored in a controlled system with restricted access.
- PSMF must always reflect the actual functioning PV system, not planned or theoretical processes.
Updating the PSMF:
- Once in three years.
- The PSMF shall be updated when any of the following change:
- QPPV or Deputy QPPV details
- Changes in PV organizational structure
- New product authorizations or withdrawals
- Changes in safety database or IT systems
- New or revised Risk Management Plan (RMP)
- Updated processes, SOPs, or quality system elements. Periodic review of processes, SOPs, or quality system elements shall not be eligible for PSMF updation.
- Updated list of partners or Safety Data Exchange Agreements (SDEA).
- Changes in reporting timelines or regulatory safety requirements.
- Changes in PV audit outcomes affecting system performance
- Any significant safety issue requiring regulatory interaction
- Annexes shall be updated on an ongoing basis.
Version Control:
- The PSMF shall contain a version control page including:
-
-
- Version number
- Effective date
- Nature of change
- Section revised
- Approved by QPPV
- Minor updates (annex updates) may follow simplified approval process.
- Major updates require full approval per document control SOP.
-
Archiving and Retention:
- PSMF versions shall be archived for minimum 10 years after last product authorization, or as per local regulation.
- PV department ensures secure storage with controlled access.
- Retrieval shall be possible within 24 hours for regulatory inspection.
Access Control & Confidentiality:
- Access to PSMF is restricted to QPPV, PV Manager, and authorized personnel.
- External sharing is permitted only after QPPV approval.
- Confidential information must be protected as per company Confidentiality SOP.
Availability During Audit / Inspection:
- QPPV / Back up QPPV or Head PV shall present the PSMF to regulatory authorities upon request.
- PSMF must be updated and inspection-ready at all times.
- Copies provided during inspection shall be marked “Controlled Copy”.
Compliance Monitoring:
- QPPV monitors compliance indicators such as:
-
-
- Individual Case Safety Report (ICSR) submission timelines
- Literature screening compliance
- Signal detection cycle completion
- Training compliance
- PV Deviation trends
- Corrective and Preventive Actions (CAPA) are initiated through QMS if gaps are identified.
-
Training:
- All PV personnel must be trained on this SOP before implementation.
- Refresher training as per QMS Training SOP.
Deviation:
- All deviations from this SOP shall be handled through the company Deviation & Corrective and Preventive Action (CAPA) SOP.
Archiving and Retention:
- Retain PSMF versions for minimum 5 years after last product authorization or per local regulations.
- Archive in secure, access-controlled system.
PSMF document Numbering Pattern:
- PSMF / XXX – YY Where:
-
- PSMF = Document category (Pharmacovigilance System Master File)
- XXX = Sequential document number (001, 002, 003…)
- YY = Version number (00, 01, 02…)
- PSMF/001 – 00 = Initial PSMF main file, version 00
-
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. |
| 1 | Pharmacovigilance Master File (PSMF) | F/PV002/001 – 00 |
REVISION HISTORY.
| Amendment Date: | Update Summary | Version No. |
| NA | New SOP | 01 |