Analysis of Noncompliances with Legislative Requirements in Pharmacovigilance Materials of Registration Dossiers

Since 1 January 2021 the authorisation of medicines in the Russian Federation has to be performed according to the Eurasian Economic Union (EAEU) procedure. The Pharmacovigilance System Master File (PSMF) is the main document describing the pharmacovigilance system of the marketing authorisation holder (MAH) or its authorised representative.  The aim of the study was to analyse noncompliances with the EAEU requirements, which were revealed during PSMF assessment.Materials and methods: the authors analysed 687 pharmacovigilance documents included in registration dossiers that were submitted for assessment from 1 January to 30 June, 2021.  Results: the authors identified and systematised the main noncompliances with the EAEU requirements in terms of presentation, content, completeness of each PSMF section. They analysed the frequency of noncompliances in PSMFs and identified the most frequent flaws of MAHs’ pharmacovigilance systems.Conclusions: the authors give recommendations for elimination of significant noncompliances identified during PSMF assessment, which may include: timely updating, maintenance, and revision of the documents in accordance with changes in legislation and any other significant changes, regular training of pharmacovigilance staff, etc. The results of this review will be useful for MAHs as the main participants of the marketing authorisation process who are directly involved in the pharmacovigilance system management at the pre- and post-authorisation stages, and will help them prevent potential mistakes when drawing up pharmacovigilance system documents

Pharmacovigilance System Master File: An Overview of Changes in the EAEU Good Pharmacovigilance Practice

The development of international regulatory practices and the accumulation of new experience in pharmacovigi­lance prompted the need to amend the Rules of Good Pharmacovigilance Practice of the Eurasian Economic Union (EAEU GVP Guideline), first adopted in 2016.The aim of the study was to review, from a regulatory expert’s perspective, the changes to the structure and presentation of the pharmacovigilance system master file (PSMF) introduced with the amendment of the EAEU GVP Guideline effective since December 6, 2022.The authors compared the requirements for the PSMF outlined in the new edition of the EAEU GVP Guideline adopted by Decision No.81 of the Council of the Eurasian Economic Commission of 19.06.2022 “On Amendments to the Rules of Good Pharmacovigilance Practice of the Eurasian Economic Union” with the requirements described in the previous version of this document.The structure and content of Module III, Pharmacovigilance System Master File, have been significantly amended in the new version of the EAEU GVP Guideline; this will require marketing authorisation holders (MAHs) to revise the PSMFs describing pharmacovigilance system data. The most significant editorial changes have been made to the paragraphs concerning the PSMF format, the pharmacovigilance quality system, and the presentation of information in the Annexes. The amendment has strengthened the control of records and documentation related to the pharmacovigilance system. Electronic PSMFs are acceptable; electronic book-marking and searchable text make working with the PSMF more convenient for representatives of MAHs and experts of regulatory authorities. Aligning of the PSMF with the requirements of the new edition of the EAEU GVP Guideline will contribute to improving the pharmacovigilance system operation and performance

Safety of Antibacterial and Antiprotozoal Medicinal Products

The experts of the Scientific Centre for Expert Evaluation of Medicinal Products analysed administrative decisions of foreign regulatory authorities on the recalls of antibacterial and antiprotozoal medicinal products and/or the need for labelling updates due to changes in the safety profile. The analysis revealed 16 decisions containing information on the following medicines registered in Russia: ertapenem, сeftriaxone, cefazolin, аmoxicillin, сefoperazone+sulbactam, piperacillin+tazobactam, сlindamycin, teicoplanin, rifampin, co-trimoxazole, hydroxychloroquine

Analysis of the Causes for Renal Dysfunction during Antibiotic Therapy in a Patient with Lyme Disease

Adverse drug reactions (ADRs) are recorded throughout the lifecycle of a medicinal product. In the post-marketing period, new ADRs are primarily identified via drug safety signals. In order to assess a signal and establish causality between an adverse drug reaction and a suspected medicinal product, it is necessary to evaluate the signal strength and quality.The aim of the study was to analyse the information submitted to Russian regulatory authorities by a patient and check it for a potential causal association of acute tubulointerstitial nephritis (ATIN) with the use of ceftriaxone and with the patient’s principal diagnosis, Lyme disease.Materials and methods: the authors analysed the patient’s submission received by the Ministry of Health of the Russian Federation in 2022 with a complaint that the treatment of Lyme disease with ceftriaxone had caused ATIN. The probability of a causal relationship between the medicinal product and the ADR was evaluated using the Naranjo algorithm.Results: according to the review of literature and the spontaneous reports collected in Pharmacovigilance 2.0, the database in the Automated Information System of the Russian Federal Service for Surveillance in Healthcare, both ceftriaxone and the underlying condition (Lyme disease) may cause renal abnormalities. Ceftriaxone is potentially nephrotoxic; it mainly affects the tubular system of the kidneys. Borreliosis may cause kidney damage as well; such damage manifests clinically as rapidly progressing and fatal damage to the glomeruli.Conclusions: the probability of a causal relationship between the development of ATIN in the complainant and the use of ceftriaxone was categorised as “possible”. However, the information available did not allow for establishing a definite relationship between kidney damage and the use of the medicinal product. Further monitoring of similar cases is necessary to minimise the risks of developing this pathology during treatment with ceftriaxone

Expert Evaluation of Pharmacovigilance System Documents Included in the Registration Dossier

The Russian Federation and the member states of the Eurasian Economic Union (EAEU) are working on the creation of a common pharmaceutical market. EAEU marketing authorisation may be granted to those pharmaceutical companies whose activities comply with the Good Pharmacovigilance Practice (GVP). The aim of the study was to analyse pharmacovigilance system documents submitted as part of registration dossiers of medicines and to identify problems that may arise during preparation of the pharmacovigilance system master file (PSMF). The authors analysed the PSMF, which makes part of the registration dossier, for compliance with the EAEU GVP requirements for submission, content, and completeness of all sections of the document. They identified the most common types of errors in PSMF preparation and analysed conditions when a PSMF is required or, alternatively, when a brief summary of the pharmacovigilance system of the marketing authorisation holder will suffice. The paper summarises specific aspects of incorporating pharmacovigilance system documents in regulatory submissions, as well as aspects of presenting pharmacovigilance system data when bringing the registration dossier in line with the EAEU requirements. This information may be useful for marketing authorisation holders who are the main stakeholders in the medicine authorisation process and who are directly involved in the pharmacovigilance system management during the authorisation and post-authorisation stages of the drug life-cycle

Rules of good laboratory practice: analysis of changes in the legislation

New rules of good laboratory practice in the Russian Federation and the Eurasian Economic Union were adopted in 2016. The rules of good laboratory practice of the Eurasian Economic Union in the field of drugs is a document that will allow for a coordinated policy in the field of pre-clinical studies and to establish common principles and rules for the evaluation of medicinal products in the Member States of the Union with a view to forming a common medical devices market circulation. Creating uniform rules and approaches to the drugs market regulation based on international experience will increase the safety of drugs available on the market and their accessibility to the population of states - members of the EAEU

Limits for the Content of Heavy Metals and Arsenic as a Means of Ensuring Safe Use of Herbal Medicinal Products

Herbal medicinal products (HMPs) are widely used in medical practice due to their availability, ease of use, and relatively safe pharmacological profile. However, medicinal plants are capable of accumulating heavy metals and arsenic which can have toxic effect on the human body when found in HMPs. The aim of the study was to summarise and analyse requirements of the Russian and foreign pharmacopoeias for the limits of heavy metals and arsenic in HMPs. National and regional pharmacopoeias have limits for the content of the major toxic elements (lead, cadmium, mercury, chromium, and arsenic) in HMPs. The study showed that the Indian and Japanese pharmacopoeias include only semi-quantitative methods for determination of heavy metals and arsenic, while the Russian and Chinese pharmacopoeias allow for the use of both quantitative and semi-quantitative methods. It was demonstrated that the limits for heavy metals and arsenic are the same for herbal substances and HMPs. The development of consistent approaches to determination of heavy metals and arsenic content, a systematic transition to quantitative methods of analysis, and establishment of individual limits for toxic elements in different HMP dosage forms, will make it possible to achieve the so-called consistent harmonisation, ensure reliable assessment of the content of heavy metals and arsenic, and minimize the risk of their entering human body with HMPs

Safety of apremilast: risk of psychical disorders

Apremilast is a new selective inhibitor of phosphodiesterase 4 (PDE4) of the class of small molecules, approved for treatment of psoriatic arthritis and psoriasis. The efficacy and safety of apremilast in the treatment of moderate to severe plaque psoriasis have been demonstrated in multicenter, randomized, double-blind, placebo-controlled clinical trials of ESTEEM 1 and ESTEEM 2 (Efficacy and Safety Trial Evaluating the Effects of Apremilast in Psoriasis). These studies describe adverse reactions such as mental disorders: depression, suicidal thoughts, suicidal behavior. However, data on the increase in the incidence of these adverse reactions during longer treatment with apremilast were not obtained. The article presents the reports from the UK regulator (MHRA) and international database VigiBase on the increased risk of developing suicidal thoughts, suicide attempts, completed suicides and suicidal behavior during treatment with apremilast

Nonsteroidal anti-inflammatory drugs: problems of safe use

The article is devoted to the problems of safety of non-steroidal anti-inflammatory drugs. The analysis of 3,963 spontaneous reports to the Russian database for the period from December 7, 2008 to August 31, 2017, with the aim of identifying information on adverse reactions that have occurred during the application of NSAIDs is presented. Most often unwanted reactions were registered for preparations of acetylsalicylic acid, diclofenac, ibuprofen, ketorolac. A total of 6,257 adverse reactions were recorded. The greatest specific weight among all cases of undesirable reactions were disorders of the immune system, skin, subcutaneous tissues and gastrointestinal tract. The lack of therapeutic effectiveness of drugs was recorded in 280 cases. Most often, such ADR on NSAIDs were angioedema, urticaria, erosive gastritis, skin rash, increased blood pressure. In case of using of the over-the-counter drugs and self-medication it is necessary to work with the population to form a responsible attitude to the use of medicines, warn of possible complications of self-medication and conditions requiring compulsory medical attention

The rules of good laboratory practice

With the aim to harmonize the legislation between the Eurasian Economic Union countries and the European Union in the field of medicines circulation and taking into account the requirements of the European Union and the Organization for Economic Cooperation and Development (OECD) in 2015 were developed the Rules of Good Laboratory Practice EAEC. The article presents the results of a comparative analysis of good laboratory practice. Order of the Ministry of Health of the Russian Federation on the Rules of good laboratory practice will allow to provide the most objective study of the safety of new drugs at the preclinical stage and to identify and prevent using of unsafe drugs. Ultimately, it will protect the interests of patients and the healthcare system as a whole