Commission Implementing Regulation (EU) 2021/1281 of 2 August 2021 laying down rules for the application of Regulation (EU) 2019/6 of the European Parliament and of the Council as regards good pharmacovigilance practice and on the format, content and summary of the pharmacovigilance system master file for veterinary medicinal products (Text with EEA relevance)
THE EUROPEAN COMMISSION,
Having regard to the Treaty on the Functioning of the European Union,
Having regard to Regulation (EU) 2019/6 of the European Parliament and of the Council of 11 December 2018 laying down Community Regulation on veterinary medicinal products and repealing Directive 2001/82/EC (1), and in particular Article 77(6) thereof,
Whereas:
(1) Good pharmacovigilance practice should cover all activities across the full life-cycle management of veterinary medicinal products in relation to safety authorised in accordance with Article 5 of Regulation (EU) 2019/6 or registered in accordance with Article 86 of that Regulation. Non-compliance with pharmacovigilance obligations could have a potentially serious impact on public and animal health and on the environment.
(2) Marketing authorisation holders should respect good pharmacovigilance practice by implementing a robust and efficient pharmacovigilance system, supported by a quality management system covering all pharmacovigilance activities, including a risk management system covering all procedures and processes necessary to optimise safe use of their veterinary medicinal products. The quality management system should be updated regularly and checked by audits at risk-based intervals, and should include provisions to identify corrective and preventive actions and manage and document corresponding changes to those actions.
(3) In order to facilitate the enforcement of pharmacovigilance obligations, the marketing authorisation holder should retain full responsibility for all pharmacovigilance obligations subcontracted to third parties.
(4) As an important part of a marketing authorisation holder’s quality management system, all information on pharmacovigilance data, including standard procedures, should be saved and preserved in a document management system. The document management system should include a record management system to process safety data.
(5) Adverse event reporting remains the primary information source for post-authorisation safety monitoring and provides most of the data for the evaluation of the benefit-risk balance of a product. Marketing authorisation holders should, within 30 days, record all adverse event reports collected for all their veterinary medicinal products in the Union pharmacovigilance database in order to enable analysis of information received over the full life-cycle of a product.
(6) Standard terminology in the field of medical science should be used in harmonising the exchange of pharmacovigilance information to improve consistency of data related to adverse event reporting.
(7) The calculation of incidence of adverse events should allow for the comparison of different products, product groups or different time periods for the same product.
(8) The signal management process should enable continuous monitoring of the benefit-risk balance of a veterinary medicinal product. It should therefore be a core element of the pharmacovigilance system, allowing appropriate measures to be taken, in accordance with Article 77(4) of Regulation (EU) 2019/6.
(9) Communication of information about the safe and effective use of veterinary medicinal products should support appropriate use and should be considered throughout the risk management process.
(10) The pharmacovigilance system master file should contain all relevant information and documents concerning pharmacovigilance activities, including information on tasks that have been subcontracted to third parties. That information should contribute to the appropriate planning and conduct of audits by marketing authorisation holders and the supervision of pharmacovigilance activities by the qualified person responsible for pharmacovigilance. Furthermore, that information should enable competent authorities to verify compliance concerning all aspects of the system.
(11) Marketing authorisation holders should ensure that they and any third party carrying out pharmacovigilance activities in relation to their veterinary medicinal products make the necessary preparations in order to facilitate controls or inspections by the national competent authorities or the European Medicines Agency.
(12) This Regulation should apply from 28 January 2022 in accordance with Article 153(1) of Regulation (EU) 2019/6.
(13) The measures provided for in this Decision are in accordance with the opinion of the Standing Committee on Veterinary Medicinal Products,
HAS ADOPTED THIS REGULATION:
CHAPTER 1
GENERAL PROVISIONS AND PHARMACOVIGILANCE SYSTEM
Article 1
Definitions
For the purposes of this Regulation, the following definitions shall apply:
(a) ‘quality management system’ means a formalised system that provides for comprehensive processes, procedures, and responsibilities for achieving quality policies and objectives to coordinate and direct an organisation’s activities and improve its effectiveness and efficiency in this regard on a continuous basis;
(b) ‘performance indicator’ means an item of information collected at regular intervals to monitor the performance of a system;
(c) ‘signal’ means information that arises from one or multiple sources, including observations and experiments, which suggests a potentially new causal association, or a new aspect of a known causal association between an intervention and an adverse event or a set of related adverse events, that is judged likely to justify further investigation of possible causality.
Article 2
Pharmacovigilance system
The marketing authorisation holder’s pharmacovigilance system established and maintained in accordance with Article 77(1) of Regulation (EU) 2019/6 shall meet the requirements laid down in this Regulation.
The marketing authorisation holder shall ensure that the pharmacovigilance system:
(a) is fully functional;
(b) is covered by a comprehensive quality management system as provided for in Articles 4 to 9 of this Regulation;
(c) includes a risk management system covering all procedures and processes necessary to optimise safe use and monitor benefit-risk balance of their veterinary medicinal products;
(d) sets out clearly the roles, responsibilities and required tasks for all parties involved in operating the system;
(e) provides for proper control over the system and ensures that, when needed, the necessary changes to the system to improve its operation can be carried out;
(f) is clearly and unambiguously documented in the pharmacovigilance system master file.
Marketing authorisation holders shall ensure that the qualified person responsible for pharmacovigilance referred to in Article 77(8) of Regulation (EU) 2019/6 has sufficient control over the pharmacovigilance system in order to promote, maintain and improve compliance with Article 78 of that Regulation. They shall ensure that there is an appropriate procedure in place to identify and deal with any conflicts of interest of the qualified person responsible for pharmacovigilance.
Marketing authorisation holders shall have a sufficient number of competent and appropriately qualified and trained personnel working for them in the performance of pharmacovigilance activities.
All persons involved in the procedures and processes of the pharmacovigilance system established for the performance of pharmacovigilance activities shall ensure the proper functioning of the system when fulfilling their role for the marketing authorisation holder.
Marketing authorisation holders shall establish and document back-up procedures to ensure business continuity with regard to the fulfilment of pharmacovigilance obligations.
Marketing authorisation holders shall retain full responsibility for all pharmacovigilance obligations subcontracted to third parties as laid down in Regulation (EU) 2019/6 and in this Regulation.
Article 3
Qualified person responsible for pharmacovigilance
The qualifications and training of the qualified person responsible for pharmacovigilance referred to in Article 77(8) of Regulation (EU) 2019/6 shall include documented experience in pharmacovigilance.
The qualified person responsible for pharmacovigilance shall have completed veterinary surgeon training in accordance with Article 38 of Directive 2005/36/EC of the European Parliament and of the Council (2). Where such training has not been completed, marketing authorisation holders shall make arrangements to ensure that the qualified person responsible for pharmacovigilance is assisted by a veterinary surgeon on a continuous basis. That assistance shall be duly documented.
CHAPTER 2
QUALITY MANAGEMENT SYSTEM
Article 4
Quality management system for pharmacovigilance
Marketing authorisation holders shall establish and implement an adequate and effective quality management system for the performance of their pharmacovigilance activities.
The quality management system shall be described in the pharmacovigilance system master file.
Marketing authorisation holders shall ensure that the quality management system includes detailed policies, processes and procedures on document management, training, audits, and change management covering the activities in accordance with Articles 5 to 9. Those policies, processes and procedures shall provide for a review of the quality management system at regular risk-based intervals, based on pre-defined criteria.
Marketing authorisation holders shall ensure that the quality management system includes detailed policies, processes and procedures for the record management system and data collection in accordance with Articles 10 to 15, for the following pharmacovigilance activities:
(a) initial recording of any suspected adverse event;
(b) collection of additional data;
(c) collation of reports of suspected adverse events and additional data;
(d) data handling other than mentioned in points (a) to (c);
(e) evaluation of data;
(f) monitoring of quality, integrity and completeness of all information registered in the pharmacovigilance system including information reported to the Union pharmacovigilance database and management of duplicates;
(g) recording of any adverse event in the Union pharmacovigilance database;
(h) archiving of all relevant documents.
Marketing authorisation holders shall ensure that the quality management system includes detailed policies, processes and procedures for risk management, monitoring of the benefit-risk balance, signal management and communication to all relevant stakeholders in accordance with Articles 16 to 20.
Marketing authorisation holders shall ensure that the quality management system includes detailed policies, processes and procedures for the maintenance and availability of the pharmacovigilance system master file in accordance with Articles 24 and 25.
Marketing authorisation holders shall clearly define the roles and responsibilities of those persons involved in pharmacovigilance activities and in documentation in accordance with paragraphs 3 to 6 of this Article.
Marketing authorisation holders shall set up a quality management system using the following:
(a) quality planning: establishing structures, integrated planning and consistent processes;
(b) quality adherence: carrying out tasks and responsibilities in accordance with quality requirements;
(c) quality control and assurance: monitoring and evaluating how effectively the structures and processes have been established and how effectively the processes are implemented;
(d) quality improvements: correcting and improving the structures and processes where necessary.
Article 5
Document management system
Marketing authorisation holders shall set up and maintain a document management system to keep all documents related to pharmacovigilance activities. Those documents shall be archived and indexed to enable accurate and easy accessibility throughout the period of record-keeping.
Documents shall be subject to version control, as appropriate.
Documents and pharmacovigilance data relating to individual authorised veterinary medicinal products shall be retained as long as the product is authorised and for 5 years after the marketing authorisation ceases to be valid.
Article 6
Training
All personnel involved in the performance of pharmacovigilance activities shall receive initial and continuous training for their role and responsibilities in relation to the activities mentioned in Article 4, paragraphs 3 to 6, also including activities related to clinical trials, technical product complaints, standards, sales and marketing.
Marketing authorisation holders shall have a training management system in place for maintaining and developing the competences of their personnel. Information on training plans and records for pharmacovigilance activities and a reference to their location shall be kept in Annex IV, point (iv) to the pharmacovigilance system master file.
Article 7
Performance indicators
Marketing authorisation holders shall use relevant performance indicators to continuously monitor the performance of pharmacovigilance activities and the outcome of risk minimisation measures. They shall keep a list of those performance indicators including the reason why they have been chosen and a description on how to use them in Annex IV, point (iii) to the pharmacovigilance system master file.
Article 8
Audits
Marketing authorisation holders shall perform audits of the pharmacovigilance system at regular risk-based intervals to ensure that it complies with the requirements set out in this Regulation and to determine its effectiveness. The audits shall be planned to cover all pharmacovigilance activities for a defined period and verify their conformity with the policies, processes and procedures of the quality management system. They shall be conducted by individuals who have no direct involvement in or responsibility for the matters or processes audited.
Any third party contracted to carry out pharmacovigilance activities in whole or in part, on behalf of or in conjunction with marketing authorisation holders, shall accept to be audited by or on behalf of marketing authorisation holders.
Marketing authorisation holders shall draw up a risk-based schedule for auditing. The process for risk-based planning shall be described and the rationale for the risk-based schedule shall be documented. A list of scheduled and completed audits, including outstanding critical and major findings, shall be documented in Annex IV, point (ii) to the pharmacovigilance system master file.
Article 9
Corrective and preventive action and change management
Marketing authorisation holders shall have a process in place for managing corrective and preventive actions, to mitigate any deviations detected in audits, daily operational work and findings from inspections. Associated corrective and preventative actions shall be documented for the last 5 years.
Corrective and preventive action plans requested by the competent authority shall document in writing an effective process, systematically addressing and minimising identified risk or defects. It shall include root cause analysis, address clear possible corrective and preventive measures, address timelines for action, and communication to relevant stakeholders.
Marketing authorisation holders shall monitor and assess the effectiveness of corrective and preventive actions. Any changes associated with those actions shall be evaluated.
Change management shall provide for a controlled process of change, including monitoring and documenting the effectiveness of the corrective or preventive actions and communication to relevant stakeholders.
CHAPTER 3
RECORD MANAGEMENT SYSTEM, DATA COLLECTION AND MONITORING
Article 10
Record management system
The document management system referred to in Article 5 shall include a record management system for receiving, recording, collating and assessing information on adverse events and for recording safety information.
The description of the record management system for recording adverse events and safety information in Section D of the pharmacovigilance system master file shall include the following information:
(a) type of record management system used for adverse event reports, including the name of the database used, if applicable;
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