Clinical Pharmacovigilance (PV) in China
CDE – Regulatory Authority Responsible for China Clinical
Pharmacovigilance Activities
The Clinical Trials Management Office, which is subordinated to China
Center for Drug Evaluation (CDE), is specifically responsible for the
reception, analysis and evaluation of suspected and unexpected serious
adverse reactions (SUSAR) during clinical trials conducted in China, as
well as development safety update reports (DSURs) during the research and
development of relevant drugs. Following the guidelines of ICH E2A, E2B
and E2F, among others, China CDE has published a series of technical
standards and normative documents based on the actual situation in China
which includes an electronic reporting system for SUSAR cases during
clinical trials.
Pharmacovigilance in clinical trials is the process of monitoring and
assessing the safety of investigational drugs or therapies during the
clinical trial. This is essential to ensure that the benefits of the
treatment outweigh any potential risks or adverse effects. The principle
goal of China pharmacovigilance systems in clinical trials is to identify
and prevent any adverse reactions or unexpected events related to the
investigational product.
China Clinical Pharmacovigilance activities typically include the
following:
- Design and implementation of a China pharmacovigilance plan: This plan
outlines the strategies for collecting and reporting adverse events
(AEs) and serious adverse events (SAEs) during the clinical trial.
- China pharmacovigilance adverse event reporting and management: All
AEs and SAEs that occur during the clinical trial must be reported and
managed according to regulatory requirements.
- Safety monitoring: Regular safety monitoring is conducted to identify
any potential safety issues that may arise during the clinical trial.
- Risk management: Strategies are implemented to mitigate the risks
associated with the investigational product and to ensure the safety
of the trial participants.
- Safety reporting in China: All safety data and analyses are compiled
and reported to regulatory authorities, ethics committees, and other
relevant stakeholders.
China pharmacovigilance in clinical trials plays a crucial role in
ensuring the safety of study participants and in providing reliable safety
data for regulatory approval of new drugs or therapies. It also helps to
build trust between the pharmaceutical industry, regulatory agencies, and
the general public.
Navigating SUSAR Reporting in China
China CDE began to receive SUSAR reports from drug registration sponsors
on May 1, 2018. In China SUSAR reporting stands for “Suspected Unexpected
Serious Adverse Reaction” reporting. It refers to the requirement for
sponsors of clinical trials to report any serious adverse reactions that
occur during the trial to the relevant regulatory authorities.
In China serious adverse reaction is defined as any untoward medical
occurrence that results in death, is life-threatening, requires
hospitalization or prolongation of existing hospitalization, results in
persistent or significant disability or incapacity, or is a congenital
anomaly/birth defect.
If such an adverse reaction is considered to be unexpected (i.e. not
consistent with the product’s known safety profile), the sponsor is
required to report it to the China regulatory authorities as a SUSAR. The
purpose of SUSAR reporting is to ensure that the safety of trial
participants is monitored and that any potential risks associated with the
investigational product are identified and communicated to the relevant
authorities.
China SUSAR Reporting
The specific guideline for China SUSAR reporting is “The Standards And Procedures for Expedited Reporting of Safety Data
during Clinical Trials” which serves as the official guidline document published on 27 Apr
2018, Effective date 1st May 2018.
The applicant must report any unexpected and serious adverse reactions
that are assessed as certain or suspected to be related to the
investigational drug. If the applicant and investigator cannot come to an
agreement on the causality assessment between the adverse event and the
drug, and neither party can rule out a relationship to the investigational
drug, then a expediated reporting should proceed.
The following scenarios generally do not need to be reported as expediated
reporting:
- non-serious adverse events,
- serious adverse events that are not related to the investigational
drug
- serious adverse reactions that are expected, and
- when the primary efficacy endpoint is a serious adverse event, the
applicant is not advised to report it as a case safety report (ICSR)
to the national drug regulatory agency.
The applicant is responsible for determining whether to report serious
adverse reactions related to a positive control drug to other drug
manufacturers and/or directly to the China drug regulatory agency. The
applicant must report such events to the drug manufacturer or directly to
the regulatory agency. Adverse events related to a placebo generally do
not meet the criteria for an adverse reaction and do not need to be
reported.
Adaptation to ICH-E2B(R3)
The content of case safety reports for unexpected serious adverse
reactions should follow the requirements outlined in the ICH “E2B(R3):
Management of Clinical Safety Data – Data Elements for Transmission of
Individual Case Safety Reports” and use the ICH “M1: MedDRA” to code
relevant terms.
The applicant is responsible for monitoring the safety information of
clinical trials and reporting serious adverse events. The applicant must
appoint a dedicated person to be responsible for clinical trial safety
information monitoring and serious adverse event report management,
establish standard operating procedures for clinical trial safety
information monitoring and serious adverse event reporting, and train all
relevant personnel. The applicant must also be aware of the latest safety
information during the clinical trial process, conduct timely safety risk
assessments, inform relevant trial stakeholders of relevant information,
and be responsible for reporting unexpected serious adverse reactions in a
timely manner.
China SUSAR Reporting Deadlines
After learning of a serious adverse event, the applicant should
immediately conduct a comprehensive analysis, evaluation, and judgment of
the event. According to the nature (category) of the serious adverse
event, the applicant should report it to the Center for Drug Evaluation
(CDE), NMPA quickly within the following time limits:
- For unexpected serious adverse reactions that cause death or endanger
life, the applicant should report as soon as possible after learning of
it, but no later than 7 days, and report and improve follow-up
information within the following 8 days.
Note: The day the applicant first learns of the event is Day 0.
- For unexpected serious adverse reactions that do not cause death or
endanger life, the applicant should report as soon as possible after
learning of it, but no later than 15 days.
The start time for quick reporting is the approval date of the clinical
trial/national drug regulatory authority’s implicit permission start date,
and the end time is the date of the last follow-up of the last subject in
the country. Serious adverse events that occur between the end of the
clinical trial or follow-up and obtaining the evaluation and approval
conclusion should be reported by the investigator to the applicant, and if
they are unexpected serious adverse reactions, quick reporting should also
be conducted.
After the first report, the applicant should continue to track serious
adverse reactions and report new information or changes to the previous
report in a timely manner in the form of follow-up reports. The reporting
time limit is 15 days from obtaining new information.
Fatal or life-threatening SUSAR for China
In China for fatal or life-threatening SUSAR, the applicant should report
as soon as possible but no later than 7 days after the first report is
made and submit a follow-up report with as much information as possible
within 8 days of the first report. For subsequent reporting of new
information in the form of a follow-up report or changes to the previous
report, the time limit for reporting is 15 days from the date the new
information was obtained.
The Center for Drug Evaluation (CDE), NMPA receives the individual case
safety reports submitted by the applicant during the drug clinical trial
period in an e-submission format that complies with ICH E2B (R3), and
conducts analysis and evaluation. When necessary, opinions on modifying
the trial plan, suspending or terminating the drug clinical trial, etc.
will be put forward according to relevant standards.
In addition to individual safety reports of unexpected serious adverse
reactions, the applicant should also report other potential serious safety
risk information to the national drug regulatory authority as soon as
possible, and make medical and scientific judgments on each situation.
Generally speaking, information that obviously affects the drug
risk-benefit assessment or may consider changing the drug use, or affects
the overall drug development process, belongs to this category, such as:
- The occurrence rate of known serious adverse reactions has increased,
and it is judged to be clinically important;
- There is a significant harm to the exposed population, such as the
drug being ineffective in treating life-threatening diseases;
- Significant safety findings (such as carcinogenicity) in recently
completed animal experiments.
The applicant should also report unexpected serious adverse reactions
related to the trial drug and other potential serious safety risk
information obtained from other sources to the Chinese drug regulatory
authority quickly.
SUSAR Report in Chinese Language
Both domestic and foreign individual safety reports and reports of other
potential serious safety risks should be reported in Chinese.
The acceptance number of the drug application clinical trial should be
clearly marked in both individual safety reports and reports of other
potential serious safety risks.
Reference:
1.The Standards And Procedures for Expedited Reporting of Safety Data
during Clinical Trials Announcement of the publication of the Standards
and Procedures for Expedited Reporting of Safety Data during Drug Clinical
Trials
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China DSUR Reporting
In China, DSUR also stands for Development Safety Update Report. China CDE
opened the DSUR reporting submission channel on its official website to
receive DSUR reports from drug registration sponsors on April 26, 2019,.
In 2020, overall 1775 copies of DSUR reports were submitted to CDE by the
sponsors.
DSUR in China is a required regulatory document that provides a
comprehensive summary of the safety profile of a drug under investigation
during a clinical trial. The DSUR is submitted at regular intervals to the
CDE and is intended to be a tool for ensuring that the safety of trial
subjects is being appropriately monitored and that any emerging safety
concerns are being addressed.
The China DSUR includes a description of any adverse events or safety
issues that have been identified during the reporting period, along with
an assessment of their severity and potential impact on the study or the
overall safety profile of the drug. It also includes information on any
changes that have been made to the trial protocol or study design, as well
as any actions taken to address safety concerns or manage risks to study
participants.
The DSUR is typically required for all clinical trials of investigational
drugs, and may be requested by regulatory authorities at any stage of the
clinical trial process. The contents are reviewed by the Chinese
authorities as part of their ongoing assessment of the safety and efficacy
of the drug, and may be used to inform decisions about whether to allow
the clinical trial to continue or whether to require additional safety
measures.
RMP (Risk Identification, Evaluation & Control) in China
RMP outlines the potential risks associated with a medicinal product and
the measures that are in place to minimize or manage those risks. The
purpose of an RMP is to identify, characterize, and assess the known and
potential risks of a medicinal product, and to determine whether
additional measures are necessary to mitigate these risks.
The Origin and Implementation of Pharmacovigilance Planning in China
As early as 12 November, 2019, the NMPA published a notice on 15 ICH
guidelines (No. 88 of 2019), requiring that new drug marketing
applications (NDAs) accepted three months after the date of publication,
and new drug marketing applications approved six months after the date of
publication starting to implement the ICH E2E: Pharmacovigilance Planning.
The ICH E2E Guidelines focus on the submission of a Safety Specification
and Pharmacovigilance Planning by the Regulatory Authority at the time of
application for marketing authorization.
Safety Specification
The safety specification for China should be “a synopsis of important
identified risks, important potential risks, and important missing
information about the drug” and should begin with a summary of
epidemiological information about the target indication.
Regardless of the indication and target population, a risk should be
classified as important if it has the following characteristics:
- The risk leads to serious consequences when it occurs. such as death,
disability or a serious impact on the quality of life of the person
using the drug.
- requires a high proportion of clinical 1000 precautions.
- presents a significant challenge to current clinical practice.
Significant risks may not affect all drug-using populations but are
only highly prevalent in drug-users with certain characteristics.
Applicants are advised to assess the risk causation scale,
preventability and its impact on the benefit-risk balance and as an
important reference for the development of risk control measures.
On July 1, 2020, the CDE published the “M4 Module 1 Administrative
Document and Drug Information”, which explicitly requires applicants to
submit NDA information “1.8.3 Risk Management Plan (RMP)”, including
Pharmacovigilance Plan and Risk minimization Measures.
In the ICH E2E Guidelines and relevant Chinese laws, regulations, and
guidelines, the terms “Pharmacovigilance Plan”, “Risk Management Plan”,
and “Risk Analysis and Management Plan” are considered as one concept due
to the refinement of laws and translation.
Pharmacovigilance Plan
Pharmacovigilance plans should include both:
- Routine pharmacovigilance activities
- Additional pharmacovigilance activities
If not specifically requested by the CDE, it is recommended that the first
post-marketing evaluation of the pharmacovigilance programme/RMP be
conducted approximately 2 years after the product is launched and may
include, but is not limited to:
- The implementation of the pharmacovigilance plan and RMP.
- Whether the cumulative post-marketing data obtained influenced the
judgement of product risk
- Whether the pharmacovigilance activities undertaken are adequate or no
longer applicable
- The evaluation of the effectiveness of risk minimisation measures;
- Whether the pharmacovigilance plan and RMP affects the accessibility
of the product or places an unnecessary burden on the healthcare
system.
China Pharmacovigilance Plan China referencing ICH E2E as follows:
Routine Pharmacovigilance Practices
Routine pharmacovigilance should be conducted for all medicinal products,
regardless of whether or not additional actions are appropriate as part of
a Pharmacovigilance Plan. This routine pharmacovigilance should include
the following:
- Systems and processes that ensure that information about all suspected
adverse reactions that are reported to the personnel of the company
are collected and collated in an accessible manner;
- The preparation of reports for Chinese regulatory authorities:
Expedited adverse drug reaction (ADR) reports
Periodic Safety Update Reports (PSURs)
- Continuous monitoring of the safety profile of approved products
including signal detection, issue evaluation, updating of labeling,
and liaison with regulatory authorities;
- Other requirements, as defined by local regulations.
Action Plan for Safety Issues
The Plan for each important safety issue should be presented and justified
according to the following structure:
- Safety issue;
- Objective of proposed action(s);
- Action(s) proposed;
- Rationale for proposed action(s);
- Monitoring by the sponsor for safety issue and proposed action(s);
- Milestones for evaluation and reporting.
Summary of Actions to be Completed, Including Milestones
An overall Pharmacovigilance Plan for the product bringing together the
actions for all individual safety issues should be presented. Whereas
section 3.1.3 suggests presenting an action plan by ongoing safety issue,
for this section the Pharmacovigilance Plan for the product should be
organised in terms of the actions to be undertaken and their milestones.
The reason for this is that one proposed action (e.g., a prospective
safety cohort study) could address more than one of the identified issues.
It is recommended that milestones for completion of studies and other
evaluations, and for submission of safety results, be included in the
Pharmacovigilance Plan. In developing these milestones one should
consider when:
- Exposure to the product will have reached a level sufficient to
allow potential identification/characterisation of the AEs/ADRs of
concern or resolution of a particular concern; and/or
- The results of ongoing or proposed safety studies are expected to be
available.
These milestones might be aligned with regulatory milestones (e.g.,
PSURs, annual reassessment and license renewals) and used to revise the
Pharmacovigilance Plan.