Latest / DDReg Knowledge Capsule / The Blueprint for Effective Pharmacovigilance SOPs
Transcript
- 0:00Speaker 1: Welcome to DDRAG Knowledge Capsule. And you know, right now,
- 0:04Speaker 1: literally as we speak, there are just millions of safety
- 0:07Speaker 1: data points bouncing all across the globe.
- 0:09Speaker 2: Oh absolutely millions.
- 0:10Speaker 1: Right, like from a rural clinic in Tokyo straight to
- 0:13Speaker 1: some massive server farm in Frankfort. And I think what's
- 0:16Speaker 1: fascinating is that every single time you pop an aspirin
- 0:19Speaker 1: for a headache, or you know, you start a brand
- 0:21Speaker 1: new prescription, you are actually interacting with one of the
- 0:24Speaker 1: most intense, unforgiving administrative machines on planet Earth.
- 0:29Speaker 2: Yeah, it really is just an absolute juggernaut of a system.
- 0:32Speaker 2: I mean, I think most people assume that drug safety
- 0:35Speaker 2: sort of well, that it ends when the clinical trials
- 0:37Speaker 2: are over, you.
- 0:38Speaker 1: Know, right, you get the FDA stamp of approval and everyone.
- 0:40Speaker 2: Just goes home exactly. But in reality, the exact moment
- 0:44Speaker 2: a drug hits the open market, an entirely new, incredibly
- 0:48Speaker 2: massive surveillance operation just boots right up.
- 0:51Speaker 1: And today's deep dive is really getting into the blueprint
- 0:54Speaker 1: of that specific surveillance operation. We're looking at a pretty
- 0:57Speaker 1: comprehensive guide by d DRAG Pharma. It's called Writing Effective
- 1:02Speaker 1: Pharmacovigilance Standard operating procedures.
- 1:05Speaker 2: Or pv SOPs as you'll hear them called constantly pvsops.
- 1:09Speaker 1: Right, So our mission today is to unpack how these
- 1:13Speaker 1: and let's be honest, very dense, behind the scenes documents
- 1:17Speaker 1: actually encode heavy global legal obligations into the daily routines
- 1:22Speaker 1: of thousands of employees. We want to really understand how
- 1:25Speaker 1: the pharmaceutical industry manages this absolute river of data to
- 1:31Speaker 1: keep you the patient safe.
- 1:33Speaker 2: Because to really grasp the stakes here, you have to
- 1:36Speaker 2: look at pv SOPs as the literal backbone of a
- 1:39Speaker 2: pharmaceutical company's right to exist. I mean, they're licensed to operate.
- 1:43Speaker 1: They aren't just like standard HR manuals about how to
- 1:46Speaker 1: request time off.
- 1:47Speaker 2: No, not at all. If a global health regulator, say
- 1:49Speaker 2: the European Medicines Agency, if they just walk into a
- 1:52Speaker 2: corporate office for a surprise inspection and they find that
- 1:54Speaker 2: the SOPs are vague or maybe they're just outdated, the
- 1:57Speaker 2: company doesn't just get a slap on the wrist of
- 1:58Speaker 2: a fine.
- 1:59Speaker 1: Oh wow, it's more severe than that, way more severe.
- 2:01Speaker 2: They can actually lose their authorization to sell the drug entirely.
- 2:05Speaker 2: I mean, without a well written SOP, you have no
- 2:06Speaker 2: traceability or have no operational consistency, and honestly, you have
- 2:09Speaker 2: absolutely zero defense.
- 2:11Speaker 1: Okay, so before we really get bogged down in the
- 2:14Speaker 1: heavy global regulations, let's just make sure we understand the
- 2:17Speaker 1: fundamental purpose of this specific tool good idea, because we
- 2:20Speaker 1: need to move from this sort of abstract idea of
- 2:23Speaker 1: safety to the physical document itself. Yeah, and you know,
- 2:27Speaker 1: the way I visualize a really effective pv SOP is
- 2:31Speaker 1: it's like a commercial airline pilot's emergency flight manual.
- 2:34Speaker 2: I like that analogy.
- 2:35Speaker 1: Right. Imagine you are at thirty thousand feet and suddenly
- 2:39Speaker 1: an engine warning light just starts flashing red.
- 2:41Speaker 2: Well, the pilot definitely doesn't pull out a blank piece
- 2:43Speaker 2: of paper to just, you know, brainstorm some creative solutions exactly.
- 2:47Speaker 1: That is really not the time to trust your gut.
- 2:50Speaker 1: You want that pilot pulling out a heavily tested, rigorous,
- 2:53Speaker 1: step by step protocol. Right. And in pharmaco vigilance, when
- 2:56Speaker 1: a company suddenly detects, say, a huge spike in severe
- 3:00Speaker 1: adverse reactions to a drug, they need that exact same
- 3:03Speaker 1: level of mechanical precision, a protocol that just entirely eliminates guesswork.
- 3:07Speaker 2: Yeah, the flight manual analogy works perfectly, but I'd add
- 3:09Speaker 2: one major caveat to it. What's that a pilot is
- 3:12Speaker 2: usually flying one plane at a time, right, but a
- 3:15Speaker 2: pharmacovigilance department is effectively monitoring thousands of flights simultaneously.
- 3:20Speaker 1: Oh wow.
- 3:21Speaker 2: Yeah, and they're doing it in different weather conditions across
- 3:23Speaker 2: different continents. So that is why well written is just
- 3:27Speaker 2: the critical metric here. These documents have a monumental translation task.
- 3:33Speaker 1: What do you mean by translation task like literally translating languages?
- 3:36Speaker 2: Well, sometimes yes, but mostly I mean translating massive, incredibly
- 3:40Speaker 2: dense legislation from governments all around the world. The SOP
- 3:44Speaker 2: has to distill all of that legal jargon down into
- 3:47Speaker 2: a very clear, actionable workflow for say, a data entry
- 3:52Speaker 2: clerk working on a Tuesday morning.
- 3:54Speaker 1: I see, because the person who's actually typing the patient's
- 3:56Speaker 1: symptoms into the database. Yeah, they aren't spending their weekend
- 4:01Speaker 1: reading parliamentary legislation from the EU.
- 4:03Speaker 2: No, and they shouldn't have to. The SOP takes that
- 4:05Speaker 2: massive legal burden entirely off the everyday employee. And you know,
- 4:09Speaker 2: it's also the ultimate safety net for the heavy hitters
- 4:12Speaker 2: in the industry too. The dd RED guide talks extensively
- 4:15Speaker 2: about roles like the mah yeah, the marketing authorization holder,
- 4:19Speaker 2: which is essentially just the company that owns the drug,
- 4:22Speaker 2: and it also talks about the qppvs.
- 4:24Speaker 1: Let's pause on QPPV for a second for the listener,
- 4:27Speaker 1: who isn't you know, deep in the weeds of European
- 4:30Speaker 1: drug regulations, who exactly is that person?
- 4:33Speaker 2: So QPPVV stands for the qualified person for pharmacovigilance In
- 4:38Speaker 2: the European Union, the law actually requires every single pharmaceutical
- 4:42Speaker 2: company to have one specific human being who is personally
- 4:46Speaker 2: and legally responsible for the entire safety profile of all
- 4:50Speaker 2: the company's products one person.
- 4:52Speaker 1: That is a massive burden to put on one individual.
- 4:54Speaker 2: It's a huge burden. And you know, India has a
- 4:56Speaker 2: very similar concept in their recently updated twenty twenty four
- 5:00Speaker 2: PVPI guidelines. They call it a Pharmacovigilance Officer in Charge
- 5:04Speaker 2: or PVOI. And for these leaders writing an airtight sop,
- 5:07Speaker 2: it isn't just administrative busy work. It is literally their arbor.
- 5:11Speaker 1: Okay, So let's talk about pressure testing that armor then,
- 5:14Speaker 1: because the internal company documents they are entirely driven by
- 5:18Speaker 1: these external global watchdogs, and the source material actually outlines
- 5:23Speaker 1: the regulatory timelines these companies have to hit, and frankly,
- 5:26Speaker 1: looking at these numbers, it sounds like an absolute administrative nightmare.
- 5:30Speaker 2: Well, the timelines are definitely designed to be unforgiving, because
- 5:35Speaker 2: patient risks doesn't really wait for a convenient time to strike.
- 5:37Speaker 1: Let's actually walk through the numbers so people understand. For
- 5:40Speaker 1: the USFDA, a company has fifteen calendar days to report
- 5:43Speaker 1: a serious and unexpected adverse event, and then the EU
- 5:47Speaker 1: requires serious individual case safety reports or icsrs to be
- 5:52Speaker 1: submitted within fifteen calendar days as well, though they do
- 5:55Speaker 1: give ninety days for non serious events. But I really
- 5:58Speaker 1: have to push back on them. Cans of this here
- 6:00Speaker 1: before fifteen calendar days explicitly includes weekends and bank holidays.
- 6:05Speaker 1: It does so if a doctor emails a drug company
- 6:07Speaker 1: about some life threatening patient reaction at I don't know,
- 6:10Speaker 1: eleven pm on Christmas Eve, the clock is actually ticking
- 6:13Speaker 1: while the entire office is closed for the holidays. How
- 6:16Speaker 1: does a massive corporate bureaucracy process a complex medical event
- 6:19Speaker 1: in a few days without just descending into complete chaos?
- 6:23Speaker 2: Yeah, that specific scenario. The Christmas Eve email. That is
- 6:27Speaker 2: precisely why the concept of day zero is the beating
- 6:30Speaker 2: heart of any modern sop. Day zero, day zero because regulators,
- 6:35Speaker 2: they just do not care about your company holiday schedule.
- 6:38Speaker 2: Patient safety does not take weekends off, so your SOP
- 6:41Speaker 2: has to legally define the exact millisecond the clock starts.
- 6:44Speaker 1: Ah. So day zero is basically the starting gun.
- 6:47Speaker 2: Yes, it is the documented moment that anyone in the
- 6:50Speaker 2: company or even any third party vendor working for the company,
- 6:53Speaker 2: becomes aware of a minimum set of safety data.
- 6:56Speaker 1: Wait, so, even if it's not a medical professional.
- 6:58Speaker 2: Exactly farharmaceutical sales rep just casually hears about an adverse
- 7:03Speaker 2: reaction at a dinner party on a Saturday night, day
- 7:05Speaker 2: zero might start right then and there.
- 7:08Speaker 1: Wow.
- 7:08Speaker 2: And if your SOP is even slightly vague about how
- 7:10Speaker 2: day zero is captured, routed, and recorded and inspector will
- 7:13Speaker 2: tear your entire system apart.
- 7:15Speaker 1: I can imagine.
- 7:16Speaker 2: Yeah, the emma's Good Pharmacovigilance Practices or GVP. They explicitly
- 7:21Speaker 2: demand a highly controlled, fully documented system just for case management.
- 7:26Speaker 2: And over in the US, the FDA mandates under regulations
- 7:29Speaker 2: like twenty one CFR three fourteen point eight zero that
- 7:32Speaker 2: these expedited reports have to hit their fares database sorry fares,
- 7:36Speaker 2: Oh right, the FDA Adverse Event Reporting system. The reports
- 7:40Speaker 2: have to hit fares within that tight window, and they
- 7:42Speaker 2: have to be formatted perfectly.
- 7:43Speaker 1: Okay, So because at fifteen day clock is ticking so relentlessly,
- 7:47Speaker 1: the documents governing the work just have to be flawless,
- 7:50Speaker 1: because I mean, a single ambiguity could cost a company
- 7:53Speaker 1: a day, which results in a late submission, which then
- 7:56Speaker 1: triggers a massive regulatory violation.
- 7:58Speaker 2: Exactly every hour count.
- 8:00Speaker 1: So if we move away from the airplane analogy for
- 8:02Speaker 1: a minute, I kind of visualize the structure of an
- 8:04Speaker 1: sop more like a high end Michelin star kitchen brigade.
- 8:08Speaker 2: Oh, a kitchen brigade. Let's explore that. How does that
- 8:10Speaker 2: map to a drug safety protocol?
- 8:12Speaker 1: Well, think about it. In a high end kitchen that's
- 8:14Speaker 1: serving hundreds of people a night, chaos is totally fatal.
- 8:17Speaker 1: Every single person needs to know exactly what their station is.
- 8:20Speaker 1: The head chef doesn't wash the dishes, and the pastry
- 8:23Speaker 1: chef definitely doesn't cook the steak. And in an sop,
- 8:27Speaker 1: that is your roles and responsibility.
- 8:28Speaker 2: Section it's a great comparison.
- 8:30Speaker 1: The guide specifically mentioned something called RCI assignments, defining exactly
- 8:35Speaker 1: who is responsible, accountable, consulted and informed for every single task,
- 8:40Speaker 1: because you really can't have two case processors just assuming
- 8:44Speaker 1: the other one is handling that Christmas Eve adverse event report.
- 8:46Speaker 2: No, you definitely can't. The classic oh I thought you
- 8:49Speaker 2: were doing an excuse really doesn't fly with a federal
- 8:52Speaker 2: health regulator. If the SOP doesn't explicitly state the exact
- 8:56Speaker 2: job title responsible for triage, the whole system fails, right,
- 9:00Speaker 2: But the structure actually goes much deeper than just assigning roles.
- 9:03Speaker 2: You also need a clearly defined scope like what specific
- 9:06Speaker 2: products in geographical regions does this document actually cover? And
- 9:10Speaker 2: you need the process flow, which is basically the step
- 9:13Speaker 2: by step chronological workflow mapping out all the decision trees and.
- 9:17Speaker 1: Crucially, going back to the kitchen. The chef doesn't just say, hey,
- 9:20Speaker 1: chop the vegetables. They say, use this specific Japanese knife
- 9:25Speaker 1: and cut them to exactly this millimeter.
- 9:28Speaker 2: Nice and in the.
- 9:29Speaker 1: SOP, those are the data standards. The guide talks a
- 9:33Speaker 1: lot about the need for precise controlled terminology. It brings
- 9:37Speaker 1: up terms like mid dry and E two BR three.
- 9:40Speaker 2: And here's where your kitchen analogy really shines. Imagine you
- 9:45Speaker 2: have a French chef asking for an aubergine and an
- 9:48Speaker 2: American sioux chef is just running around looking for an
- 9:51Speaker 2: egg plant. The whole kitchen just halts exactly. Now apply
- 9:54Speaker 2: that to global pharmacovigilance. You might have a doctor in
- 9:58Speaker 2: Japan reporting a rapid heartbeat and a doctor in Brazil
- 10:01Speaker 2: reporting techacardia.
- 10:02Speaker 1: Oh I see, they mean the same thing, but the words.
- 10:04Speaker 2: Are different exactly. That is where MANDERA comes in. It
- 10:07Speaker 2: stands for the Medical Dictionary for Regulatory Activities. It's essentially
- 10:11Speaker 2: the universal standardized language that ensures every single regulator and
- 10:15Speaker 2: data processor on Earth is talking about the exact same
- 10:18Speaker 2: medical concept.
- 10:20Speaker 1: That makes a ton of sense. It removes all the ambiguity.
- 10:22Speaker 1: And what about that other one E two BR three
- 10:24Speaker 1: E two b R three.
- 10:25Speaker 2: Yeah, that is essentially the universal digital envelope. Okay, it's
- 10:28Speaker 2: a highly specific data architecture standard used to electronically transmit
- 10:33Speaker 2: these safety reports between the pharma companies and the government regulators.
- 10:37Speaker 2: Your SOP must dictate exactly how the data is coded
- 10:40Speaker 2: into MedDRA and then mapped directly into that E TWOBR
- 10:44Speaker 2: three format.
- 10:45Speaker 1: And if you don't use that format.
- 10:46Speaker 2: If you format the digital envelope wrong, the regulator's computer
- 10:50Speaker 2: system just automatically rejects it. It won't even go through.
- 10:53Speaker 1: Wow. And you know, the part of the SOP structure
- 10:56Speaker 1: that really caught my eye and the dd RED guide
- 10:59Speaker 1: wasn't actually the body of the text. It was the annexes.
- 11:02Speaker 2: Yes, the annexes are where the theory actually meets the
- 11:04Speaker 2: reality on the ground.
- 11:06Speaker 1: Right, because the main SOP provides the overarching rules of
- 11:08Speaker 1: the kitchen, but the annexes provide the actual physical tools
- 11:12Speaker 1: the worker uses at their station.
- 11:13Speaker 2: Precisely, we are talking about step by step checklists, email templates,
- 11:17Speaker 2: complex flow charts, and standardized case handling forms. Actually, including
- 11:21Speaker 2: a visual timeline table right there in the SOPNFS is
- 11:25Speaker 2: one of the most effective ways to boost operational clarity.
- 11:28Speaker 1: So, if this is our kitchen, what are the core recipes?
- 11:31Speaker 1: Because the guide mentions several mandatory SOP that every single
- 11:35Speaker 1: PV system is required to have in its cookbook.
- 11:37Speaker 2: Yeah, there is a very specific suite of core procedures.
- 11:41Speaker 2: The heaviest lift for most companies is usually ICSR.
- 11:44Speaker 1: Case management, and ICSR is the individual patient reports, correct.
- 11:48Speaker 2: It handles the daily intake, the triage, the narrative writing
- 11:51Speaker 2: of those individual patient adverse events. But then you also
- 11:55Speaker 2: have signal management.
- 11:56Speaker 1: Let's dig into signal management for a second, because just
- 11:59Speaker 1: from the name it sounds like looking for a needle
- 12:01Speaker 1: in a haystack.
- 12:02Speaker 2: It absolutely is. A signal is essentially just a new
- 12:05Speaker 2: potential risk. So maybe a drug has been on the
- 12:08Speaker 2: market safely for five years, but suddenly the system detects
- 12:12Speaker 2: the subtle pattern of patients reporting, say, liver enzyme changes. Okay,
- 12:17Speaker 2: the signal management SOP, which by the way, has to
- 12:19Speaker 2: align with GVP Module IX in Europe. That document dictates
- 12:23Speaker 2: exactly how data analysts query the database, how they validate
- 12:27Speaker 2: whether this pattern is actually real or just a statistical anomaly,
- 12:31Speaker 2: and ultimately how they decide if they need to warn
- 12:33Speaker 2: the public.
- 12:34Speaker 1: Wow, So it's really the detective work of the whole operation,
- 12:36Speaker 1: it is. The guide also mentioned something called aggregate safety reporting.
- 12:40Speaker 2: What's that, Well, regulators don't just want those one off
- 12:44Speaker 2: emergency alerts. They want comprehensive periodic summaries of a drug's
- 12:49Speaker 2: entire safety profile, looking back over months or even years.
- 12:53Speaker 2: These are called pbr ears or p sears, and they're
- 12:57Speaker 2: guided by international standards like ICCHE two c R two.
- 13:01Speaker 1: That is a lot of acronyms.
- 13:03Speaker 2: It is an alphabet soup, I know. But you also
- 13:06Speaker 2: absolutely need an SOP outlining your pharmacovigilance agreements or PVAs.
- 13:11Speaker 1: In PVAs, those the contracts you have when you're working
- 13:13Speaker 1: with other partner companies.
- 13:14Speaker 2: Correct If two different pharmaceutical companies are co marketing a drug,
- 13:19Speaker 2: the PDA dictates exactly who processes the safety data and
- 13:23Speaker 2: who submits it to the government. You can't have both
- 13:25Speaker 2: doing it or neither, right.
- 13:27Speaker 1: That goes back to the RCI assignments exactly.
- 13:30Speaker 2: And finally, you have the crown jewel of the whole thing,
- 13:33Speaker 2: the SOP for compiling the PSMF or the pharmaco Vigilance
- 13:36Speaker 2: System Masterfile. The PSMF is literally the master blueprint of
- 13:41Speaker 2: your entire safety system. If a government inspector arrives at
- 13:45Speaker 2: your lobby, the PSMF is the very first document they
- 13:48Speaker 2: ask for.
- 13:49Speaker 1: Okay, So these core recipes and this highly standardized language,
- 13:53Speaker 1: I mean it makes perfect sense for traditional operations, but
- 13:55Speaker 1: this industry is moving incredibly.
- 13:57Speaker 2: Fast, at lightning speed.
- 13:59Speaker 1: So how do these rigid, highly structured SOPs handle massive
- 14:04Speaker 1: modern complexities. I'm thinking about things like global data privacy
- 14:08Speaker 1: laws or the sudden explosion of artificial intelligence. If our
- 14:12Speaker 1: kitchen is serving the whole world, how do they keep
- 14:14Speaker 1: up with entirely new ingredients.
- 14:16Speaker 2: Well, you've just hit on the ultimate challenge of modernizing
- 14:18Speaker 2: this machinery, because the static sop is actually a dangerous sop.
- 14:23Speaker 2: Today's procedures have to deeply fundamentally integrate global data privacy
- 14:27Speaker 2: like GDPR exactly. You have the GDPR in Europe, which
- 14:31Speaker 2: requires rigorous protocols just for masking personal data. A patient's
- 14:35Speaker 2: name or any direct identifiers absolutely cannot accidentally end up
- 14:39Speaker 2: in a narrative that gets submitted to a foreign government.
- 14:42Speaker 1: And reading the source material on modernizing these systems, I
- 14:45Speaker 1: noticed a detail that really made me scratch my head.
- 14:47Speaker 2: What was it?
- 14:48Speaker 1: Well, we talked earlier about monitoring medical literature for adverse events, right,
- 14:53Speaker 1: the guide explicitly states that SOPs must document literature monitoring methods,
- 14:58Speaker 1: including tracking. And this is a quote zero result searches.
- 15:02Speaker 2: Ah, yes, zero result searches.
- 15:05Speaker 1: So I totally understand tracking bad reactions. If a medical
- 15:08Speaker 1: journal publishes a study saying a drug caused a severe rash,
- 15:13Speaker 1: obviously you log it. But why on earth would an
- 15:16Speaker 1: sop legally mandate that an analyst spend time documenting a
- 15:19Speaker 1: search that found absolutely nothing. Is that just pure administrative
- 15:23Speaker 1: busy work.
- 15:23Speaker 2: I can completely understand why it looks like dizzywork from
- 15:26Speaker 2: the outside, but this actually hits on a foundational philosophy
- 15:29Speaker 2: of pharmacovigilance. The absence of data is still data.
- 15:33Speaker 1: Wait, how can nothing be something.
- 15:36Speaker 2: Because it proves the surveillance system is actually running. Consider
- 15:39Speaker 2: this from the regulator's point of view. If an inspector
- 15:42Speaker 2: sits down and asks, hey, did you check the global
- 15:45Speaker 2: medical literature for new risks regarding this heart medication this
- 15:49Speaker 2: week and you just say yes, and we didn't find anything,
- 15:51Speaker 2: They're gonna want proof exactly. The regulator will immediately say,
- 15:54Speaker 2: show me the proof. So a documented zero result search
- 15:58Speaker 2: showing the exact are strings used in the database, the
- 16:02Speaker 2: exact date, and the analysts signature that proves that your
- 16:05Speaker 2: safety out was actually cast, your methodology was sound, and
- 16:08Speaker 2: it simply came back empty.
- 16:10Speaker 1: Oh wow.
- 16:10Speaker 2: If you don't document the zero results in the eyes
- 16:13Speaker 2: of the law. You didn't even look.
- 16:15Speaker 1: That is wild. If it isn't documented, it literally.
- 16:17Speaker 2: Didn't happen exactly.
- 16:20Speaker 1: Now. The guide also brings up data integrity frameworks. Its
- 16:24Speaker 1: specifically mentioned something called l CoA plus principles. And I
- 16:27Speaker 1: have to stop you there because LCA just sounds like
- 16:29Speaker 1: I don't know, a giant aluminum manufacturing company. What does
- 16:33Speaker 1: l CoA plus mean for a data processor?
- 16:36Speaker 2: Yeah, it does sound like a factory. But licaplus is
- 16:39Speaker 2: actually a gold standard acronym for a data integrity in
- 16:42Speaker 2: this space. It means data must be attributable to the
- 16:46Speaker 2: person who created it, legible, contemporaneous meaning it was recorded
- 16:50Speaker 2: at the exact time it happened, Original, and accurate.
- 16:54Speaker 1: Okay, what about the plus?
- 16:56Speaker 2: The plus stands for complete, consistent, enduring and available.
- 17:00Speaker 1: Got it?
- 17:01Speaker 2: And here is where it ties back to your question
- 17:03Speaker 2: about new technology. If a company is using modern tools
- 17:07Speaker 2: like machine learning or AI to sort through thousands of
- 17:10Speaker 2: literature articles automatically, the SOP has to govern exactly how
- 17:14Speaker 2: that AI aligns with LAOAA plus SEV. You have to
- 17:18Speaker 2: scientifically prove the algorithm isn't hallucinating data or silently dropping cases.
- 17:22Speaker 1: But governing AI sounds incredibly difficult when every single country
- 17:26Speaker 1: has completely different roles. How do you write an sop
- 17:28Speaker 1: for that?
- 17:29Speaker 2: It is really tough, which is why DDRE highlights this
- 17:31Speaker 2: brilliant best practice of using regional annexes.
- 17:35Speaker 1: How does that work?
- 17:35Speaker 2: You basically maintain one core global sop, the Master recipe,
- 17:40Speaker 2: if you will, but you attach regional annexes to it.
- 17:44Speaker 2: So if India's CDSO requires a highly specific local reporting
- 17:48Speaker 2: form that literally no one else uses, you just put
- 17:51Speaker 2: that in the India annex. You don't rewrite the global
- 17:53Speaker 2: core document and confuse the rest of the.
- 17:54Speaker 1: World, Which brings us to the final hurdle here right,
- 17:57Speaker 1: Because it is one thing to sit in the corporate
- 17:59Speaker 1: board draft this flawless master recipe with perfect regional annexes
- 18:04Speaker 1: and account for AI governance, it is entirely another thing
- 18:08Speaker 1: to prove to a government inspector that your thousands of
- 18:11Speaker 1: global employees actually follow the manual. The source material refers
- 18:15Speaker 1: to PV audits in a really poetic way. Actually, it
- 18:18Speaker 1: calls them the quiet guardians of drug safety.
- 18:20Speaker 2: I love that phrasing. They really are the quiet guardians.
- 18:22Speaker 2: I mean, audits don't grab the front page headlines like
- 18:25Speaker 2: a breakthrough clinical trial or a massive new FDA approval,
- 18:28Speaker 2: But these rigorous internal stress tests, they are the invisible
- 18:32Speaker 2: shield that keeps medicines on the market.
- 18:35Speaker 1: And regulators don't just read your sop, pat you on
- 18:38Speaker 1: the back, is a hey, good job. They want to
- 18:40Speaker 1: see hard, cold metrics proving the machine is actually under control.
- 18:44Speaker 1: What kind of numbers are they looking for?
- 18:46Speaker 2: Well, for starters, regulators expect to see a minimum of
- 18:49Speaker 2: ninety eight percent compliance on timely expedited reporting.
- 18:53Speaker 1: Okay, I have to interject here because ninety eight percent
- 18:56Speaker 1: sounds like an A plus on a high school math test.
- 18:58Speaker 1: It does, but in this context we really have to
- 19:01Speaker 1: ground that number in the human stakes. That missing two
- 19:05Speaker 1: percent isn't just some harmless rounding error. That two percent
- 19:08Speaker 1: could represent a severe allergic reaction that slipped through the
- 19:11Speaker 1: cracks and wasn't reported to the government in time.
- 19:13Speaker 2: Exactly the paperwork is directly tied to human lives, right,
- 19:17Speaker 2: which is exactly why anything less than ninety eight percent
- 19:20Speaker 2: is an immediate, massive red flag that triggers an investigation.
- 19:24Speaker 2: Regulators also look for very low E two B R
- 19:27Speaker 2: three rejection rates. They measure the medical accuracy of your
- 19:31Speaker 2: meddary coding, and crucially, they look really closely at your
- 19:35Speaker 2: kPa effectiveness.
- 19:36Speaker 1: CAPA being corrective and preventive actions, which basically means when
- 19:42Speaker 1: a process inevitably breaks down, did you actually fix the
- 19:45Speaker 1: root cause so it never happens again?
- 19:47Speaker 2: Exactly. Let's say a technical glitch caused three adverse event
- 19:50Speaker 2: emails to get stuck in a server, and you missed
- 19:53Speaker 2: the fifteen day reporting window. Okay, A kPa isn't just
- 19:57Speaker 2: saying oh well, we submitted them late.
- 19:58Speaker 1: Sorry.
- 19:59Speaker 2: A here requires you to investigate the server completely, fix
- 20:03Speaker 2: the IT architecture, train your entire staff on a new
- 20:06Speaker 2: backup protocol, and then audit the system a month later
- 20:10Speaker 2: just to prove the fix. Actually.
- 20:11Speaker 1: Hell, that is rigorous. And the guide actually makes a
- 20:14Speaker 1: very important point about vendor oversight and all of this
- 20:17Speaker 1: because a massive portion of pharmaceutical companies just outsource this
- 20:21Speaker 1: routine data entry in literature monitoring to specialized vendors. They do,
- 20:25Speaker 1: it's very common, but the MAH, the marketing authorization holder,
- 20:30Speaker 1: they remain ultimately responsible for all regulatory outcomes. Basically, you
- 20:34Speaker 1: can outsource the labor, but you absolutely cannot outsource the
- 20:37Speaker 1: legal liability.
- 20:38Speaker 2: That is a foundational rule of pharmacal vigilance. If you're
- 20:42Speaker 2: a third party vendor fails the audit, your company loses
- 20:45Speaker 2: the license, no exceptions. And this is exactly where partners
- 20:49Speaker 2: like d d REG come into play. How So, they
- 20:52Speaker 2: partner directly with pharma and biotech companies to build these
- 20:55Speaker 2: inspection ready systems from the ground up. They conduct the
- 20:58Speaker 2: GAP analyzes, the AFT to the core SOPs and the
- 21:01Speaker 2: regional annexes we talked about, and they provide global PV
- 21:05Speaker 2: operations support.
- 21:06Speaker 1: Yeah, the guide details some really impressive technological platforms they
- 21:09Speaker 1: offer for this. There's Vitalic, which manages product registrations and submissions,
- 21:14Speaker 1: and then there's Regentel.
- 21:15Speaker 2: Right. Regentell is fascinating.
- 21:17Speaker 1: It's an AI powered regulatory intelligence platform that literally tracks
- 21:22Speaker 1: changing legislation across more than one hundred and twenty global agencies, which, honestly,
- 21:27Speaker 1: trying to manually track the daily legislative changes of one
- 21:30Speaker 1: hundred and twenty different countries sounds mathematically impossible for a
- 21:33Speaker 1: human team.
- 21:34Speaker 2: It is impossible. You absolutely need technology to scale compliance
- 21:37Speaker 2: at that level, and dd REGs capabilities they aren't just
- 21:40Speaker 2: theoretical frameworks. The source text actually includes this massive case
- 21:44Speaker 2: study of a large US based pharmaceutical company.
- 21:48Speaker 1: Tell them about that.
- 21:49Speaker 2: So this company had a huge global footprint, multiple manufacturing sites,
- 21:53Speaker 2: and over thirty marketed products with incredibly high consumer demand.
- 21:57Speaker 1: Managing the incoming safety data for thirty as active products
- 22:00Speaker 1: globally is just a staggering volume of information.
- 22:03Speaker 2: It is, and DDREG stepped in and managed a QPPV
- 22:07Speaker 2: deployment across eleven different countries simultaneously.
- 22:10Speaker 1: Wow.
- 22:11Speaker 2: Yeah, they bit the local literature monitoring systems, they harmonized
- 22:14Speaker 2: all the SOPs, and they ensured local PV compliance across
- 22:18Speaker 2: wildly varying regulatory environments. That is just the sheer scale
- 22:22Speaker 2: of the operation required to keep a major drug portfolio
- 22:25Speaker 2: compliant and most importantly, to ensure the safety net actually
- 22:29Speaker 2: holds for the patients taking those thirty products.
- 22:31Speaker 1: So what does this all mean for us, the people
- 22:33Speaker 1: actually taking the medication? Today, we've taken a deep dive
- 22:37Speaker 1: into the hidden, highly structured world of drug safety. We
- 22:41Speaker 1: started by realizing that taking a simple pill actually requires
- 22:44Speaker 1: a massive flight manual of protocols just to monitor its effects.
- 22:50Speaker 1: We looked at the unforgiving ticking clock of global regulations,
- 22:54Speaker 1: where day zero is the starting gun. We broke down
- 22:58Speaker 1: the kitchen Brigade, anatomy of a PERF SOP translating really
- 23:02Speaker 1: complex data into universal languages like meddare.
- 23:04Speaker 2: A, and we explored how metrics zero result searches, LCOA
- 23:09Speaker 2: plus data integrity and modern tools keep this incredibly complex
- 23:13Speaker 2: system running smoothly, all.
- 23:15Speaker 1: Guarded quietly by rigorous audits.
- 23:17Speaker 2: It really is a massive invisible infrastructure. Thousands of professionals
- 23:21Speaker 2: are working globally every single day just to protect public health.
- 23:24Speaker 1: It is truly remarkable. But before we wrap up, I
- 23:26Speaker 1: want to leave you, our listener with a specific sort
- 23:28Speaker 1: of provocative thought to mollover or explore on your own.
- 23:31Speaker 1: Let's hear it well, we talked about how pharmaceutical companies
- 23:33Speaker 1: are increasingly being forced to write AI and machine learning
- 23:36Speaker 1: governance into their modern pharmacovigilance SOPs.
- 23:40Speaker 2: Right because of all the new tools.
- 23:42Speaker 1: So imagine this near future scenario if an automated algorithm
- 23:47Speaker 1: is given the primary responsibility for validating adverse events and
- 23:51Speaker 1: that AI just hallucinates, or maybe it fails to detect
- 23:55Speaker 1: a really critical safety signal hidden in the data. Who
- 23:59Speaker 1: is ultimately held with reponsible by the regulators. Oh that's a
- 24:01Speaker 1: tough one, right, Is it the third party software vendor
- 24:05Speaker 1: who actually built the AI? Is the AI itself somehow
- 24:09Speaker 1: or does the full crushing weight of the law fall
- 24:12Speaker 1: squarely on the pharmaceutical company that signed the sop.
- 24:15Speaker 2: That is the multimillion dollar question that the global industry
- 24:18Speaker 2: is going to have to answer very very soon.
- 24:20Speaker 1: It really makes you think differently about all the automated
- 24:23Speaker 1: systems running behind the scenes. Well, thank you for joining
- 24:25Speaker 1: us on this deep dive. The next time you open
- 24:27Speaker 1: a medicine cabinet, remember that you are not just trusting
- 24:30Speaker 1: the chemistry in the bottle, You are trusting the flight manual.
- 24:33Speaker 1: Keep questioning those hidden systems that keep our world safe.