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Sop Medicinal Product Recall and Restrictions

Medicinal Product Recall and Restrictions: Ensuring Patient Safety and Regulatory Compliance Medicinal product recalls and restrictions are vital tools in pharmacovigilance that protect public health by ensuring the safety, efficacy, and quality of pharmaceutical products. When safety concerns, manufacturing defects, or regulatory violations are identified, the recall or restriction process is initiated to prevent harm to patients and to comply with national and international regulatory standards. This process is a critical aspect of the pharmaceutical industry’s responsibility in safeguarding public health and maintaining trust in medicinal products. What is a Medicinal Product Recall? A medicinal product recall refers to the action taken by a pharmaceutical company, often in cooperation with regulatory authorities, to remove a product from the market due to safety concerns. These concerns may arise from adverse events (AEs), new safety data, manufacturing issues, contamination, or labeling errors. The recall process is a precautionary measure aimed at preventing potential harm to patients, ensuring that faulty or unsafe products are removed from circulation, and protecting the integrity of the healthcare system. There are several types of product recalls, typically categorized based on the severity of the potential risk posed by the product: Class I Recall: This is the most serious type of recall, indicating that there is a reasonable probability that the use of or exposure to the product will cause serious adverse health consequences or death. Examples include contaminated or incorrectly manufactured products that pose an immediate health risk. Class II Recall: This type of recall indicates that the product may cause temporary or reversible adverse health consequences, but the risk of serious harm is remote. Class II recalls often involve situations where the product does not meet quality standards, such as improper labeling or minor contamination. Class III Recall: This recall involves products that are unlikely to cause any adverse health consequences but do not meet the regulatory requirements or quality standards, such as minor defects or non-compliance with labeling regulations. These products are typically recalled as a precaution. The decision to initiate a recall is usually made by the marketing authorization holder (MAH) of the product, often in consultation with regulatory bodies like the European Medicines Agency (EMA), U.S. Food and Drug Administration (FDA), or national health authorities. The recall process typically involves notifying healthcare professionals, distributors, and consumers, and may require the destruction or return of the affected products. What are Medicinal Product Restrictions? Medicinal product restrictions refer to the imposition of limitations on the distribution, use, or availability of a medicinal product due to safety concerns. These restrictions can include limiting the use of a product to specific populations, recommending changes in dosage, restricting the use of a product to healthcare professionals with special training, or even suspending the sale of the product in certain geographic areas or markets. Restrictions can be imposed for various reasons, such as: Newly identified risks: After new safety data emerges, restrictions may be imposed to minimize patient exposure to potential risks. Manufacturing defects: If a defect is discovered in the production process that could affect product safety or quality, distribution may be limited to specific batches or geographic locations. Regulatory non-compliance: When a product does not meet regulatory standards for safety, quality, or efficacy, restrictions may be imposed until the issue is resolved. Labeling errors: If incorrect or incomplete labeling is found to be a risk factor, regulatory authorities may demand revisions to product labeling and impose restrictions on the product’s distribution. Rest

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49 views2 pages

Sop Medicinal Product Recall and Restrictions

Medicinal Product Recall and Restrictions: Ensuring Patient Safety and Regulatory Compliance Medicinal product recalls and restrictions are vital tools in pharmacovigilance that protect public health by ensuring the safety, efficacy, and quality of pharmaceutical products. When safety concerns, manufacturing defects, or regulatory violations are identified, the recall or restriction process is initiated to prevent harm to patients and to comply with national and international regulatory standards. This process is a critical aspect of the pharmaceutical industry’s responsibility in safeguarding public health and maintaining trust in medicinal products. What is a Medicinal Product Recall? A medicinal product recall refers to the action taken by a pharmaceutical company, often in cooperation with regulatory authorities, to remove a product from the market due to safety concerns. These concerns may arise from adverse events (AEs), new safety data, manufacturing issues, contamination, or labeling errors. The recall process is a precautionary measure aimed at preventing potential harm to patients, ensuring that faulty or unsafe products are removed from circulation, and protecting the integrity of the healthcare system. There are several types of product recalls, typically categorized based on the severity of the potential risk posed by the product: Class I Recall: This is the most serious type of recall, indicating that there is a reasonable probability that the use of or exposure to the product will cause serious adverse health consequences or death. Examples include contaminated or incorrectly manufactured products that pose an immediate health risk. Class II Recall: This type of recall indicates that the product may cause temporary or reversible adverse health consequences, but the risk of serious harm is remote. Class II recalls often involve situations where the product does not meet quality standards, such as improper labeling or minor contamination. Class III Recall: This recall involves products that are unlikely to cause any adverse health consequences but do not meet the regulatory requirements or quality standards, such as minor defects or non-compliance with labeling regulations. These products are typically recalled as a precaution. The decision to initiate a recall is usually made by the marketing authorization holder (MAH) of the product, often in consultation with regulatory bodies like the European Medicines Agency (EMA), U.S. Food and Drug Administration (FDA), or national health authorities. The recall process typically involves notifying healthcare professionals, distributors, and consumers, and may require the destruction or return of the affected products. What are Medicinal Product Restrictions? Medicinal product restrictions refer to the imposition of limitations on the distribution, use, or availability of a medicinal product due to safety concerns. These restrictions can include limiting the use of a product to specific populations, recommending changes in dosage, restricting the use of a product to healthcare professionals with special training, or even suspending the sale of the product in certain geographic areas or markets. Restrictions can be imposed for various reasons, such as: Newly identified risks: After new safety data emerges, restrictions may be imposed to minimize patient exposure to potential risks. Manufacturing defects: If a defect is discovered in the production process that could affect product safety or quality, distribution may be limited to specific batches or geographic locations. Regulatory non-compliance: When a product does not meet regulatory standards for safety, quality, or efficacy, restrictions may be imposed until the issue is resolved. Labeling errors: If incorrect or incomplete labeling is found to be a risk factor, regulatory authorities may demand revisions to product labeling and impose restrictions on the product’s distribution. Rest

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Standard Operating Procedure

Product Recall and Restrictions


SOP-PV-009_09-Jan-2023_v.00
Page 1 of 4

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

Pharmex’s any employee who may receive


regulatory decisions about recall and • Immediately informing Director/HPVD/SPVS
restrictions for the MPs

Head of Pharmacovigilance Department • Informing MAH’s QPPV


(HPVD)
• Performing causality assessment, sending
Senior Pharmacovigilance Specialist results to MAH’s QPPV
(SPVS) • Storage of the documents

• Verifying causality assessment


MAH’s Qualified Person responsible for • Preparing analytical summary and
pharmacovigilance (MAH’s QPPV) recommendation for action
• Participating in the recall/restrictions process

Quality Assurance Manager (QAM) • Compliance monitoring

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

1. Informing the Stakeholders

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.

b) MAH’s QPPV shall verify the results within 5 hours.

c) In case of rejection/comments, HPVD/SPVS shall revise the results.

d) MAH’s QPPV shall prepare within 1 business day:

• Analytical summary
• Recommendation for action

CONFIDENTIAL

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