Sop Medicinal Product Recall and Restrictions
Sop Medicinal Product Recall and Restrictions
I. PURPOSE
This Standard Operating Procedure (SOP) describes the procedure of immediate interaction between
PharmExpert LLC (Pharmex) and Marketing Authorization Holder (MAH) when receiving from
Regulatory Authority (RA) regulatory decisions about recall and restrictions for the medicinal product
(MP).
II. SCOPE
This procedure shall apply to Pharmex’s staff who can get regulatory decisions about recall and restrictions
for the MP.
III. RESPONSIBILITIES
Role Responsibility
IV. DEFINITIONS
Abbreviations used in the text are spelled out on its first mention.
Causality assessment – a method used for estimating the strength of relationship between drug(s) exposure
and occurrence of adverse reaction(s).
For terms and definitions refer to the SOP-QA-003 «Pharmacovigilance Glossary».
V. PROCEDURE
CONFIDENTIAL
Standard Operating Procedure
Product Recall and Restrictions
SOP-PV-009_09-Jan-2023_v.00
Page 2 of 4
A. General Specification
RAs shall take all appropriate steps to ensure that the supply of the MP is prohibited and the MP withdrawn
from the market, if the view is taken that:
• the MP is harmful;
• it lacks therapeutic efficacy;
• the risk-benefit balance is not favorable;
• its qualitative and quantitative composition is not as declared;
• the controls on the MP and/or on the ingredients and the controls at an intermediate stage of the
manufacturing process have not been carried out;
• if some other requirement or obligation relating to the grant of the manufacturing authorization has
not been fulfilled.
MAH as responsible side for safety and efficacy of MPs in authorized country is obligated to follow RA’s
decisions about recall and restrictions.
The RA may limit the prohibition to supply the MP, or its withdrawal from the market, to those batches
which are the subject of dispute.
The RA may, for a MP for which the supply has been prohibited or which has been withdrawn from the
market, in exceptional circumstances during a transitional period allow the supply of the MP to patients
who are already being treated with the MP.
B. Process
a) When Pharmex’s any employee receives information or notification letter from the RAs of the
countries of activity about regulatory decision of recall and restrictions for the MP, he/she shall
immediately inform the Director/HPVD/SPVS, not later than 2 hours.
b) HPVD/SPVS shall inform MAH’s QPPV about the regulatory decisions of recall and restrictions
for the MP via email or phone call within 24 hours providing necessary documents.
2. Causality Assessment
a) HPVD/SPVS shall perform causality assessment according to the SOP-PV-003 «Case Assessment»
and send the results to MAH’s QPPV within 1 business day.
• Analytical summary
• Recommendation for action
CONFIDENTIAL