Good Pharmacovigilance Planning in Japan: Proposals from the “Task Force for Good Pharmacovigilance Planning in Japan” of Japanese Society for Pharmacoepidemiology (JSPE)
10.3820/jjpe.20.73
- VernacularTitle:より良い Pharmacovigilance Plan 策定に向けての提言
- Author:
Osamu KOMIYAMA
;
Kotonari AOKI
;
Akira KOKAN
;
Kiyoshi KUBOTA
- Publication Type:Journal Article
- Keywords:
Risk Management Plan;
Pharmacovigilance Plan;
Good Post-marketing Study Practice;
Good Vigilance Practice
- From:Japanese Journal of Pharmacoepidemiology
2015;20(2):73-83
- CountryJapan
- Language:Japanese
-
Abstract:
The reform of regulation is proposed to implement the Pharmacovigilance Planning (PVP) based on the ICH E2E guidelines as indicated in the notification of Risk Management Plan (J-RMP). Even after the J-RMP is enforced, the pharmacovigilance method still heavily depends on the traditional methods like “drug use results surveys”. The “Good Post-marketing Study Practice (GPSP)” ordinance and related notifications are the root causes of the malfunctioned operation of the system. Specifically, 1) the GPSP ordinance does not encourage the investigations according to the ICH E2E notification and 2) it is believed that the pharmacovigilance method should be limited to one of the three options only, namely, “drug use results surveys”, “specific use surveys” and “post-marketing clinical studies”. The followings are proposed:
• The GPSP ordinance should be revised to encourage referring the annex “pharmacovigilance methods” in “Pharmacovigilance planning”.
• The use of the early post-marketing phase vigilance (EPPV) should be restricted to the drugs marketed at the same time in the world or marketed for the first time in Japan.
• The notification connecting the “Good Vigilance Practice (GVP)” and GPSP ordinances (March 11, 2013, No 0311-7) should be revised to include a prescription that the “Safety Control Manager encourage the Post-marketing Surveillance Control Manager to develop a pharmacovigilance plan according to the ICH-E2E guidelines”.
• Forms attached to the individual RMP submissions should be revised according to the J-RMP notification.
• The notification on the RMP development (No.0426-1 and No.0426-2, on April 26, 2012) should be revised to indicate that the study design is acceptable to the health professionals.
• It should be clarified that the additional pharmacovigilance activities may be conducted by the divisional cooperation in the world or may be conducted as a non-clinical study, if appropriate.
