New digital service for MAHs to report safety data
MAHs are encouraged to transition to the new digital service for all pharmacovigilance reporting and utilize the feedback function during the beta phase to improve the service.
EMA clarifies the submission timelines and protocol requirements for non-interventional imposed PASS, focusing on draft protocols and the assessment process.
MAHs must ensure draft protocols are placed correctly in the CTD and that submission planning considers the clarified assessment timelines, with RMP updates contingent upon PRAC endorsement.
Regulatory Intelligence Lead
Review in the next regulatory intelligence cycle.
Updated Question 11 clarifies that the assessment of a non-interventional imposed PASS final study report by the PRAC takes up to 74 days, followed by 67 days for the European Commission decision-making process. Updated Question 12 specifies that draft protocols for these studies should be submitted in Module 1.8.2 of the CTD and only included in the RMP once endorsed by the PRAC.
MAHs must align their submission planning for non-interventional imposed PASS with the clarified assessment timelines. Draft protocols must be correctly placed in the CTD (Module 1.8.2) and RMP updates should only occur after PRAC endorsement.
Need for marketing authorisation holders to adapt to updated submission timelines and protocols
Change in submission requirements for PASS
EMA established that draft protocols for non-interventional imposed PASS should now be submitted in Module 1.8.2 and aligned submission timelines for assessments are defined as 74 days for PRAC review and 67 days for EC decision.
MAHs need to adjust their planning and submission processes to comply with these updated timelines and requirements, which could significantly impact the speed of study implementation and monitoring of safety signals.
MAHs must ensure draft protocols are placed correctly in the CTD and that submission planning considers the clarified assessment timelines, with RMP updates contingent upon PRAC endorsement.
MAHs are encouraged to transition to the new digital service for all pharmacovigilance reporting and utilize the feedback function during the beta phase to improve the service.
Clinical safety and pharmacovigilance teams must implement new safety monitoring protocols and ensure adequate assessment of abuse potential as stipulated in the guidance.
Sponsors must adhere to defined meeting types (Type X, Y, Z) and submit meeting packages at least 3 months before planned submissions for OTC monograph drugs, ensuring FDA engagement occurs within set timelines.
MAHs must execute safety communication plans, update Risk Management Plans (RMPs), and revise product information including the Summary of Product Characteristics (SmPC) and Package Leaflet.