PV002: SOP FOR PHARMACOVIGILANCE MASTER FILE (PSMF) PREPARATION & MAINTENANCE

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

 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

 

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