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Author: Bart Cobert

  • Back to the Basics in PV

    Since starting these postings we’ve had a lot of questions about some of the basics of drug safety.  So our thought is that this would be a good time to review what you need to have and what is nice to have to do drug safety and pharmacovigilance (PV). So here is a review of…

  • FDA’s Internal SOP on How To Do An NDA Safety Review Part 3

    We are continuing and finishing the review of one of the FDA’s critical internal SOPs:  MOPP 6010.3R: Attachment B: Clinical Safety Review of an NDA or BLA (Issued 12/14/2010; Posted 12/14/2010) available at: https://www.fda.gov/downloads/AboutFDA/CentersOffices/OfficeofMedicalProductsandTobacco/CDER/ManualofPoliciesProcedures/UCM236905.pdf We are now going to examine the FDA reviewer’s handling of AEs.  As in the previous parts of this review, all…

  • FDA’s Internal SOP On How To Do An NDA Safety Review Part 2

    We are continuing the review of one of the FDA’s critical internal SOPs:  MOPP 6010.3R: Attachment B: Clinical Safety Review of an NDA or BLA (Issued 12/14/2010; Posted 12/14/2010). We have covered the introductory sections and now are looking at the methodology and other sections.  As in the previous part of this review, all sentences…

  • The FDA’s Internal SOP On How To Do An NDA Safety Review Part 1

    One of the lesser known aspects of the FDA is that their SOPs are in the public domain and are available on-line.  They are found in the Manual of Policies & Procedures (MOPPs) of CDER. Although some are as routine and mundane as anyone else’s SOPs a few are gems and are well worth reading…

  • What Is The Right Size For A Safety Database?

    An often asked question.  The answer depends on whom you ask. Ask the Chief Financial Officer (money does matter of course) and the likely answer is the smallest number of patients possible particularly before launch and particularly before the drug is on the market and bringing in money from sales. Ask the Statistician (numbers do…

  • The Wave – EMA’s New PSUR-PBRER

    What is this about?: The EMA has released (June 2012) the new “Guideline on Good Pharmacovigilance Practices (GVP) – Module VII – Periodic Safety Update Reports”   which covers the new requirements for the submission of post-approval (post-authorization) aggregate reports. Why do I need to know this?: If your company, partner, vendor, client etc. handles adverse…

  • New EU Draft Guideline on Pharmacovigilance Inspections “We are here to help you…”

    What is this about?: In late June 2012 the EMA released its “Module III” on PV inspections.  This is a draft guideline due to be finalized by year end with public consultation from June 27 to August 24. It describes how the EU and member states (MS)will do drug safety/PV inspections. Why do I need…