Pharmacovigilace:
(ICH-E2A talks about pharmacovigilance)
Introduction:
Pharmacovigilance (PV or PhV), also known as drug safety, is the pharmacological science relating to
the
·
collection,
·
detection,
·
assessment,
·
monitoring, and
·
prevention of adverse
effects with pharmaceutical
products.
WHO says, “Pharmacovigilance (PV) is defined as the science and activities relating to the detection, assessment, understanding and prevention of adverse effects or any other drug-related problem.”
‘WHO
established its Programme for International Drug Monitoring in response to the
thalidomide disaster detected in 1961. Together with the WHO Collaborating
Centre for International Drug Monitoring, Uppsala, WHO promotes PV at the
country level. At the end of 2010, 134 countries were part of the WHO PV
Programme. The aims of PV are to enhance patient care and patient safety in
relation to the use of medicines; and to support public health programmes by
providing reliable, balanced information for the effective assessment of the
risk-benefit profile of medicines.’
The etymological roots for
the word "pharmacovigilance" are: pharmakon (Greek
for drug) and vigilare (Latin for to keep watch). As such,
pharmacovigilance heavily focuses on adverse
drug reactions, or ADRs, which are defined as any response to a drug
which is noxious and unintended, including lack of efficacy (the condition that
this definition only applies with the doses normally used for the prophylaxis, diagnosis or
therapy of disease, or for the modification of physiological disorder function
was excluded with the latest amendment of the applicable legislation). Medication errors such
as overdose, and misuse and abuse of a drug as well as drug exposure during
pregnancy and breastfeeding, are also of interest, even without an adverse
event, because they may result in an adverse drug reaction.
Information received from patients and
healthcare providers via pharmacovigilance agreements (PVAs), as well as other
sources such as the medical
literature, plays a critical role in providing the data necessary
for pharmacovigilance to take place. In fact, in order to market or to test a
pharmaceutical product in most countries, adverse event data received by the
license holder (usually a pharmaceutical company) must be submitted to the local
drug regulatory authority.
Ultimately,
pharmacovigilance is concerned with identifying the hazards associated with
pharmaceutical products and with minimizing the risk of any harm that may come
to patients. Companies must conduct a comprehensive drug safety and
pharmacovigilance audit to assess their compliance with worldwide laws,
regulations, and guidance.
Common terms used in pharmacovigilance:
Adverse drug reaction is a side effect (non
intended reaction to the drug) occurring with a drug where a positive (direct)
causal relationship between the event and the drug is thought, or has been
proven, to exist.
·
Adverse event (AE) :
Adverse event is a side effect occurring with a drug. By
definition, the causal relationship between the AE and the drug is unknown.
·
Benefits :
Benefits are commonly
expressed as the proven therapeutic good of a product but
should also include the patient's subjective assessment of its effects.
Causal relationship is said to exist when a
drug is thought to have caused or contributed to the occurrence of an adverse
drug reaction.
·
Clinical trial :
Clinical trial (or study) refers to an organised
program to determine the safety and/or efficacy of a drug (or drugs) in patients. The design of
a clinical trial will depend on the drug and the phase of its development.
·
Control group :
Control group is a group (or
cohort) of individual patients that is used as a standard of comparison within
a clinical trial. The control group may be taking a placebo (where no active
drug is given) or where a different active drug is given as a comparator.
·
Dechallenge and rechallenge :
Dechallenge and rechallenge refer to a drug being stopped and restarted in
a patient, respectively. A positive dechallenge has occurred, for example, when
an adverse event abates or resolves completely following the drug's
discontinuation. A positive rechallenge has occurred when the adverse event
re-occurs after the drug is restarted. Dechallenge and rechallenge play an
important role in determining whether a causal relationship between an event
and a drug exists.
·
Effectiveness :
Effectiveness is the extent
to which a drug works under real world circumstances, i.e., clinical practice.
·
Efficacy :
Efficacy is the extent to which a drug works under ideal circumstances,
i.e., in clinical trials.
·
Implied causality :
Implied causality refers to
spontaneously reported AE cases where the causality is always presumed to be
positive unless the reporter states otherwise.
·
Individual Case Safety Report (ICSR):
Individual Case Safety
Report (ICSR) is
an adverse event report for an individual patient.
·
Life-threatening :
Life-threatening refers to an adverse
event that places a patient at the immediate risk of death.
· Phase refers to the four phases of clinical research and
development: I – small safety trials early on in a drug's development; II – medium-sized
trials for both safety and efficacy; III – large trials, which includes key (or
so-called "pivotal") trials; IV – large, post-marketing trials,
typically for safety reasons. There are also intermediate phases designated by
an "a" or "b", e.g. Phase IIb.
·
Risk is
the probability of harm being caused, usually expressed as a percent or ratio
of the treated population.
·
Risk factor :
Risk factor is an attribute of a patient that may
predispose, or increase the risk, of that patient developing an event that may
or may not be drug-related. For instance, obesity is considered a risk factor
for a number of different diseases and, potentially, ADRs. Others would be high
blood pressure, diabetes, possessing a specific mutated gene, for example,
mutations in the BRCA1 and BRCA2 genes increase propensity
to develop breast cancer.
·
Signal :
Signal is a new safety
finding within safety data that requires further investigation. There are three
categories of signals: confirmed signals where the data
indicate that there is a causal relationship between the drug and the AE; refuted (or
false) signals where after investigation the data indicate that no causal
relationship exists; and unconfirmed signals which require
further investigation (more data) such as the conducting of a post-marketing
trial to study the issue.
·
Temporal relationship :
Temporal relationship is said to exist
when an adverse event occurs when a patient is taking a given drug. Although a
temporal relationship is absolutely necessary in order to establish a causal
relationship between the drug and the AE, a temporal relationship does not
necessarily in and of itself prove that the event was caused by the drug.
·
Triage :
Triage refers to the process of placing a potential adverse
event report into one of three categories: 1) non-serious case; 2) serious
case; or 3) no case (minimum criteria for an AE case are not fulfilled).
Adverse event reporting:
One of the fundamental principles of adverse event reporting
is the determination of what constitutes an Individual Case Safety Report
(ICSR).
Individual Case Study Report (ICSR) is an adverse event report
for an individual patient and is source of data in pharmacovigilance.
The main focus of ICSRs are reports from healthcare providers
and patients in member countries of the WHO Programme. A WHO global individual
case safety report database (VigiBase) is maintained and developed on behalf of
the WHO by the UMC.
During the triage phase of a potential
adverse event report, it is important to determine if the "four
elements" of a valid ICSR are present: (1) an identifiable patient, (2) an
identifiable reporter, (3) a suspect drug, and (4) an adverse event.
If one or more of these four elements is
missing, the case is not a valid ICSR. Although there are no exceptions to this
rule there may be circumstances that may require a judgment call. For example,
the term "identifiable" may not always be clear-cut. If a physician
reports that he/she has a patient X taking drug Y who experienced Z (an AE),
but refuses to provide any specifics about patient X, the report is still a
valid case even though the patient is not specifically identified. This is
because the reporter has first-hand information about the patient and is identifiable (i.e. a real
person) to the physician. Identifiability is important so as not only to
prevent duplicate reporting of the same case, but also to permit follow-up for
additional information.
VigiBase:
VigiBase is a World
Health Organization’s (WHO) global Individual Case Safety Report
(ICSR) database that contains ICSRs submitted by the participating member
states enrolled under WHO’s international drug monitoring programme. It is the
single largest drug safety data repository in the world. Since 1978, the Uppsala
Monitoring Centre (UMC; established in Uppsala, Sweden) on behalf of WHO,
have been maintaining VigiBase. Vigibase is used to obtain the information
about a safety profile of a medicinal product. These data are used by
pharmaceutical industries, academic institutions and regulatory authorities for
statistical signal detection, updating periodic reports, ICSR comparisons with
company databases and studying the reporting patterns. The data
(pre-dominantly post-marketing serious and non-serious cases) is collected from
each of its 110 member states which currently comprises to over 10 million ICSRs
(October 2014). About a
hundred thousand ICSRs are added each year.
Contributors:
It is
mandatory for all the participating countries (125 members states and 28
associate members) to submit ICSRs to UMC via its appointed national centre
based in the respective member states, authorized by its competent
authority or the health authority itself.
These reports are usually sent to the respective national centre by marketing
authorization holders, health care professionals (HCP), consumers or any
regional centre. Most of participating member have a well established system
for collection of ICSRs. These
submissions are in ICH E2B format and are
reported more than once a month or at least every quarter. For some member
states that lack an E2B compatible database for ICSR management, UMC in
collaboration with ‘’Swissmedic’’ has developed ‘’VigiFlow’’, a web-based ICSR
management system. VigiFlow functions as a national ICSR database management
system and analysis tool, through which cases are sent to UMC.
Beneficiaries:
Identify
the earliest possible pharmacovigilance signals,
the usage of VigiBase is permitted and accessed by the following authorities:
1. Signal review team and UMC employees have full access to
data, including narratives and laboratory values.
2. Paying customers: Pharmaceutical companies or HCPs can
request for the data by paying stipulated fees, provided the data is being used
for academic purposes or in public interest.
references:
https://www.ich.org/page/efficacy-guidelines
https://en.wikipedia.org/wiki/Pharmacovigilance
https://www.idmp1.com/wiki/icsr/
https://www.who.int/medicines/areas/quality_safety/safety_efficacy/pharmvigi/en/
http://www.vigiaccess.org/
https://www.ich.org/page/efficacy-guidelines
https://en.wikipedia.org/wiki/Pharmacovigilance
https://www.idmp1.com/wiki/icsr/
https://www.who.int/medicines/areas/quality_safety/safety_efficacy/pharmvigi/en/
http://www.vigiaccess.org/
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