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Pharmacovigilance:
Current Trends, Methods
and Challenges
Medline Pubmed
Embase Quosa
CINAHL Scopus
Accessibility
Not all free; costs can be
high
Coverage
Worldwide or not
Focus
Orientated towards particular
medical discipline
Overlap
Considerations when choosing
Literature Search Engines
Costs
Free or has access costs associated with it.
Is the user interface easy to navigate or complex?
How dependable and reliable are the outputs?
Can the search engine return de-duplicated
results?
Can the user make selections for the most relevant
articles and store your selected citations?
Can the user be notified when certain articles of
interest are available?
Methods and Search
Strategies
Setting up an effective search strategy that can increase
the potential for detecting a safety concern early.
Methods and Signal Search
Strategies
Database/search engine selection
Approach to record retrieval
Establishing a search strategy
Creating a search string
Selection of relevant terms or text
Application of limits
Use of automated methods
LITERATURE:
Search Strategy
Recommendations from CIOMS V & EMA
Target the search to publications that appear in
internationally recognized databases
Search at least two suitable databases
Constuct search string with terms likely to solicit
relevant information
Utilize consistent and balanced search strategies
(INN as keyword for retrieval)
Searches should be scheduled with a frequency
appropriate to the drug [& as required by the local
RA]
Review search results for ICSRs and non ICSR
safety data. Consider separate searches for each.
Make sure local database searches are being
conducted
Non-ICSR relevant data
Exposure during pregnancy or lactation (including pregnancies
with no adverse outcomes)
Use of the product in pediatric populations, elderly or organ-
impaired individuals
Occupational exposure
Lack of therapeutic efficacy
Asymptomatic overdose, abuse, or misuse
Medication error where no adverse events occurred (near
misses)
Off-label use
Suspected transmission of infectious agents
Compassionate supply, named-patient use
Clinical trial results/conclusions
Important non-clinical safety results (including in vitro/in vivo
laboratory studies)
Information on the risk-benefit
Counterfeit product
Potential Diversion
Other data of interest
Choice of the Search
Construction and Search Terms:
Precision and Recall
The success of a search can be measured
according to precision and recall (also called
sensitivity)
Recall is the proportion of records retrieved ("hits")
when considering the total number of relevant
records that are present in the database.
Precision is the proportion of "hits" that are
relevant when considering the number of records
that were retrieved.
Good search construction should result in an
output with low recall and high precision.
Representative list of possible terms
for adverse
http://www.ema.europa.eu/docs/en_GB/document_library/Other/2
015/08/WC500191377.pdf
ICSR Workflow for MLM
http://www.ema.europa.eu/ema/index.jsp?curl=
pages/regulation/general/general_content_000
633.jsp
MLM : Pharmacovigilance
Dream or Nightmare?
MAH is fully responsible for executing literature
screening for ICSRs (Yellow and Green area).
Reference:
http://www.ema.eu
ropa.eu/docs/en_G
B/document_librar
y/Other/2015/07/W
C500190190.pdf
MLM final thoughts..
The burden seems to be on the companies now to go the
site, probably every working day, as it would not be
advisable to have serious ICSRs available to the public
before the company.
Non-indexed local journals are excluded from the
Agency's monitoring activities and remain under the
responsibility of the MAHs.
What about disagreements on causal or expectedness?
Its not clear how the company will handle those cases
where they disagree with the causality and/or
expectedness.
It is also not clear whether the company can or should do
follow up on their own even if the EMA has already done
so.
Will the EMA update its database (EudraVigilance) with a
companys version?
It is possible two or more companies may do follow up in
addition to the EMA if both market the drug.
Challenges and Common
Inspection Findings
Of Literature Search and Review
LITERATURE:
Challenges in Screening &
Review of Articles
Ensuring that the search string is robust enough to
capture all relevant hits and not so overly inclusive
that you capture irrelevant information.
Data is often presented in tables, without identifiable
MSI (% of patients experienced [adverse event])
Case reports present the suspicion of the reporter;
often opinion based, not a proven association
Drug reactions may have confounding factors
(comorbid illness, patient population, concomitant
medications)
Drug reactions may be the result of patient non-
compliance, medication error, or other factors
LITERATURE:
Challenges in Screening &
Review of Articles
Lack of population exposure data
Social Media Bias
Authors may have or not reported the case to the MAH or the
regulatory authority
Authors may have first published the single case report
followed by the publication of a case series
Authors may have presented the case in conferences and
thus the case was published as proceedings of the
conference followed by publications in a peer reviewed
journal
Authors may have published in local journals followed by
publication in a peer reviewed journal
Drug safety reviews may cross refer to the publications of
ICSRs or the same case may have been indexed in many
databases in a slightly different manner.
LITERATURE:
Challenges in Screening &
Review of Articles
Published reports have been submitted to a third-
party and might lack clarity with respect to drug-
event attribution (especially with study reports)
Published papers may not specifically describe or
discuss attribution- adverse events are mentioned
without much discussion
Spontaneous reports are prompted by a suspicion
of drug-related harm/injury (implied causality),
while publications containing adverse event data
cannot necessarily be categorized as having
presumed drug-causality
Reference: CIOMS V:
Common Regulatory Inspection
Findings Related to Literature
Inadequacies in the construction of, or process used for,
literature searching (sources used, adequacy of scope of
search with respect to search objective, local literature
scanning, language restrictions, lack of QC).
Not all relevant articles that had been newly distributed in
the database in the week of search had been identified
therefore articles were omitted from literature review
(MHRA finding).
Waiting to search the literature at data lock for PSUR
instead of searching proactively.
Failure to discuss in PSURs significant safety findings
(non-ICSRs) reported in published literature.
Lack of training to personnel involved in literature
searching.
Results of searches are not reproducible and tracked
Major audit findings by MHRA
(Apr 2014 Mar 2015)
In Summary.
Ensure you select the most relevant publication databases for
your product
Systematically monitor publications at a frequency consistent with
regulatory obligations.
Systemically monitor all active substances for which you hold MA
within the EU (where not listed by the EMA)
Monitor articles published locally in each territory where your
product is marketed
Route the results of this activity to the appropriate departments
within your company
Understand and comply with the time deadlines that apply to
ICSR Literature Screening even if a third party is completing
your screening
Avoid reporting duplicate ICSRs within literature
Describe and analyze any new and significant safety findings in
the medicinal products PSUR
Understand and comply with the requirement to immediately
notify regulators of new safety information from screening
Further Suggestions:
Anyone involved in literature searches for pharma
companies must pay careful attention to this as it evolves.
Study the relevant documents, read the SOPs, get into
EudraVigilance and understand what is happening.
See which of your drugs are covered and which are not. It is
not totally clear how/when they will add products. Check the
website every day!
Do not stop doing literature searches even if they seem to be
duplicative of the EMAs searches. See how this plays out
and see if both searches pick up the same cases or whether
some are missed. Compare your search strings to the
EMAs .
New SOPs and Work Instructions will be needed.
Figure out whether you need to keep doing searches for
other HAs (e.g. FDA).
Figure out your follow up strategy with the authors. Are you
willing to wait weeks or more for EMAs revised ICSRs after
follow up?
Elizabeth Garrard, PharmD
Garrard Safety Solutions
eegarrard@gmail.com
References
Regulation (EU) No 658/2014 of the European Parliament and of
the Council of 15 May 2014 on fees payable to the European
Medicines Agency for the conduct of pharmacovigilance activities
in respect of medicinal products for human use:
http://ec.europa.eu/health/files/eudralex/vol-
1/reg_2014_658/reg_2014_658_en.pdf
Regulation (EC) No 726/2004 of the European Parliament and of
the Council of 31 March 2004 laying down Community procedures
for the authorisation and supervision of medicinal products for
human and veterinary use and establishing a European Medicines
Agency:
http://ec.europa.eu/health/files/eudralex/vol-
1/reg_2004_726/reg_2004_726_en.pdf
Directive 2001/83/EC of the European Parliament and of the
Council 6 November 2001 on the community code relating to
medicinal products for human use:
http://ec.europa.eu/health/files/eudralex/vol-
1/dir_2001_83_consol_2012/dir_2001_83_cons_2012_en.pdf
References:
European Medicines Agency, Heads of Medicines Agencies.
Guideline on good pharmacovigilance practices (GVP): module
VImanagement and reporting of adverse reactions to
medicinal products.
European Medicines Agency, Heads of Medicines Agencies.
DRAFT detailed guide regarding the monitoring of medical
literature and the entry of relevant information into the
EudraVigilance database by the European Medicines Agency.
May 2014
US Food and Drug Administration. 21CFR314.80- Postmarketing
reporting of adverse drug experiences.
US Food and Drug Administration. DRAFT Guidance for
Industry: Postmarketing Safety Reporting for Human Drug and
Biological Products Including Vaccines, March 2001
Council for International Organizations of Medical Sciences
(CIOMS), Working Group V:Current Challenges in
Pharmacovigilance: Pragmatic Approaches
Health Canada. Guidance Document for Industry- Reporting
Adverse Reactions to Marketed Health Products.
References:
Pontes H, Clement M, Rollason V. Safety signal
detection: the relevance of literature review. Drug
Saf. 2014 Jul;37(7):471-9.
PVblog.elsevier.com