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Table 3 Summary of changes in the Guideline on Good Pharmacovigilance Practices Module V (Revision 2) (including Guidance on the format of the Risk Management Plan in the European Union—in integrated format) [3, 4, 13, 14]

From: Risk Management Plans: reassessment of safety concerns based on Good Pharmacovigilance Practices Module V (Revision 2)—a company experience

Safety Concern

Summary

IIRs

Impact on RMP Planning

The RMP should address only those IIRs which are undesirable clinical outcomes. An IIR to be included in the RMP would usually require:

 • Further evaluation/characterization as part of the PV Plan

 • RMMs: such as product information advising on specific clinical actions to be taken to minimize the risk or additional RMMs)

Considerations for Removal

An IIR may be removed from the RMP where:

 • Fully characterized, with no outstanding additional PV activities

 • Appropriately managed, with no ongoing additional RMMs and where any RMMs recommending specific clinical measures have become fully integrated into standard clinical practice

IPRs

Impact on RMP Planning

The RMP should address only those IPRs which are undesirable clinical outcomes. An undesirable clinical outcome associated with off-label use or an area of MI may be included as an IPR if deemed important and supported by a scientific rationale

An IPR to be included in the RMP would usually require:

 • Further evaluation/characterization as part of the PV Plan

Considerations for Removal

An IPR may be reclassified or removed from the RMP where:

 • Scientific and clinical data strengthen evidence of a causal association with the product [reclassification to IIR]

 • Accumulating scientific and clinical data do not support a causal association with the product

 • There is no reasonable expectation that any PV activity could further characterize the risk)

MI

Impact on RMP Planning

Areas of MI included in the RMP should:

 • Be within the approved indication

 • Focus on areas where there are gaps in knowledge about the safety for certain anticipated utilization/patient populations

 • Be based upon a scientific rationale that anticipates the areas of MI might differ from the known safety profile

 MI in the RMP would usually requirea:

 • Further evaluation/characterization as part of the PV Plan

Considerations for Removal

An area of MI may be removed from the RMP where:

 • Adequate safety data are available with respect to the area of MI

 • There is no reasonable expectation that any PV activities could further characterize the safety profile with respect to the areas of MI

  1. B-R Benefit-Risk, EU European Union, GVP Good Pharmacovigilance Practices, IIRs Important Identified Risks, IPRs Important Potential Risks, MI Missing Information, PV Pharmacovigilance, RMMs Risk Minimization Measures, RMP Risk Management Plan
  2. aNot specifically described in GVP Module V (rev 2), but based on information provided during the EMA information day