Comprehensive reference covering PV fundamentals, E2B R2/R3, ICSR, GAMP 5, regulatory frameworks and real-world interview Q&A.
Pharmacovigilance (PV) is the science and activities relating to the detection, assessment, understanding and prevention of adverse effects or any other drug-related problem.
| Region | Authority | Key Regulation | Database / System |
|---|---|---|---|
| USA | FDA | 21 CFR Part 312, 314, 600 / FAERS | MedWatch, FAERS, FDA Adverse Event Reporting |
| EU | EMA | EC Regulation 726/2004; DIR 2010/84/EU | EudraVigilance (EVDAS) |
| Global | ICH | E2A, E2B, E2C, E2D, E2E, E2F | VigiBase (WHO-UMC) |
| Japan | PMDA | ICH E2B(R3) since 2019 | EPPIC-Net / PMDA system |
| India | CDSCO | Schedule Y / PvPI guidelines | VigiFlow |
| UK | MHRA | Human Medicines Regs 2012 | Yellow Card Scheme |
ICH E2B is the international standard for electronic transmission of Individual Case Safety Reports (ICSRs). It defines the data elements, structure, and format for submitting adverse event reports to regulatory authorities electronically.
| Section | Content | Key Fields |
|---|---|---|
| C.1 | Safety Report Identification | Report ID, type, date of creation, sender/receiver |
| C.2 | Primary Source | Reporter name, address, qualification (HCP/Consumer/MAH) |
| C.3 | Sender & Receiver | Organization ID, country, type |
| C.4 | Literature Reference | Publication details, authors, journal |
| C.5 | Study Information | Study number, name, type (clinical trial etc.) |
| D | Patient Characteristics | Age, sex, weight, height, relevant medical history |
| E | Reaction/Event | MedDRA PT/LLT, onset date, outcome, seriousness |
| F | Results of Tests | Lab values, dates, normal ranges |
| G | Drug Information | Drug name, dose, route, dates, indication, role code |
| H | Narrative / Summary | Case narrative, reporter's comments, MAH assessment |
An ICSR is a report describing one or more suspected adverse reactions in a single patient at a specific point in time. It is the fundamental unit of pharmacovigilance data collection and reporting worldwide.
An AE is serious if it results in any of the following:
| Report | Full Name | Who Submits | Frequency | Guideline |
|---|---|---|---|---|
| PSUR / PBRER | Periodic Safety Update Report / Periodic Benefit-Risk Evaluation Report | MAH (post-approval) | 6-monthly, annually, or per EURD list | ICH E2C(R2) |
| DSUR | Development Safety Update Report | Sponsor (pre-approval / clinical trials) | Annual | ICH E2F |
| SUSAR | Suspected Unexpected Serious Adverse Reaction | Sponsor / Investigator | Expedited (7/15 days) | ICH E2A / GCP |
| ASR | Annual Safety Report | MAH (US-specific) | Annual | FDA 21 CFR 312.33 |
| RMP | Risk Management Plan | MAH (EU) | Updated with MAA/variation | GVP Module V |
| REMS | Risk Evaluation and Mitigation Strategy | MAH (US) | Per FDA requirement | FDAAA 2007 |
GAMP 5 (published by ISPE) provides a practical framework for the validation of computerized systems used in regulated life sciences environments. In PV, it governs how safety databases (e.g., Oracle Argus, Veeva Vault Safety, ARISg) must be validated.
| Category | Type | Example in PV | Validation Level |
|---|---|---|---|
| Cat 1 | Infrastructure Software | OS, middleware, SQL Server | Vendor qualification only |
| Cat 3 | Non-configured products | Standard office software, basic COTS | Testing of standard functions |
| Cat 4 | Configured products | Oracle Argus, Safety Reporter, ARISg | Configuration testing, IQ/OQ/PQ |
| Cat 5 | Custom / Bespoke software | In-house built PV tools, custom reports | Full lifecycle validation (IQ/OQ/PQ + code review) |
Governs electronic records and electronic signatures in FDA-regulated systems. Key requirements:
Information that arises from one or multiple sources (including observations and experiments) which suggests a new potentially causal association, or a new aspect of a known association, between an intervention and an event or set of related events, either adverse or beneficial.
(ICH E2C R2 / GVP Module IX definition)
| Term | Full Form | Definition |
|---|---|---|
| ADR | Adverse Drug Reaction | A response to a medicine which is noxious and unintended and occurs at doses normally used. Causality implied. |
| AE | Adverse Event | Any untoward medical occurrence in a patient. Does NOT imply causality with the drug. |
| SAE | Serious Adverse Event | Any AE meeting one of the 6 seriousness criteria (death, LT, hosp, disability, congenital, medically significant) |
| SADR | Serious Adverse Drug Reaction | Serious + causally related to the drug |
| SUSAR | Suspected Unexpected Serious Adverse Reaction | Serious + unexpected (not in IB/SmPC) + causal relationship cannot be ruled out |
| MedDRA | Medical Dictionary for Regulatory Activities | Standardized medical terminology used globally for AE coding. Hierarchy: SOC → HLGT → HLT → PT → LLT |
| SmPC | Summary of Product Characteristics | EU label / prescribing information for a medicinal product |
| IB | Investigator's Brochure | Pre-marketing reference document for clinical trials (defines expectedness) |
| MAH | Marketing Authorization Holder | Company that holds the license to market a drug |
| QPPV | Qualified Person for PV | EU-mandated individual responsible for PV system at MAH |
| PSMF | Pharmacovigilance System Master File | EU required document describing the MAH's PV system |
| GVP | Good Vigilance Practice | EMA's guidelines (Modules I–XVI) governing PV operations in EU |
| CIOMS | Council for Intl Organizations of Medical Sciences | Provides CIOMS I form — alternative to MedWatch for expedited reporting |
| DLP | Data Lock Point | The date after which no new data is included in an aggregate report period |
| IBD | International Birth Date | Date of first marketing authorization for a drug anywhere in the world. Anchors PSUR cycle. |
Click any question to reveal the answer.
| Question | Answer |
|---|---|
| What does IBD stand for? | International Birth Date — first global marketing authorization date |
| What is a DLP? | Data Lock Point — cutoff date for data included in an aggregate report |
| What is a DHPC? | Direct Healthcare Professional Communication — urgent safety letter to HCPs |
| What is GVP? | Good Vigilance Practice — EMA's 16-module PV guideline for the EU |
| What are SOC and PT in MedDRA? | System Organ Class (top level) and Preferred Term (used for regulatory reporting) |
| What is a CIOMS form? | Standardized paper form for reporting serious ADRs (alternative to MedWatch for non-US) |
| What triggers a SUSAR? | Serious + Unexpected + Causal relationship cannot be ruled out (in clinical trials) |
| Who is responsible for PV in EU? | QPPV — Qualified Person for Pharmacovigilance (mandatory EU designation) |
| What is an SMQ? | Standardized MedDRA Query — predefined PT groupings for signal searches |
| What is EudraVigilance? | EMA's central EU database for ICSRs on authorized medicines in the EEA |
Medical Dictionary for Regulatory Activities (MedDRA) is the international standard medical terminology used across the entire regulatory cycle — from pre-clinical to post-market. It is owned and maintained by ICH and managed operationally by MSSO (Maintenance and Support Services Organization). Every adverse event, indication, and medical history entry in an ICSR must be MedDRA-coded.
SMQs are validated, pre-defined groupings of MedDRA terms (PTs and LLTs) used to retrieve cases related to a specific medical condition or area of concern. They are critical tools in signal detection, aggregate reporting, and regulatory responses.
While MedDRA codes adverse events, the WHO Drug Dictionary (WHO-DD) is the international standard for coding medicinal products in safety databases. Maintained by WHO-UMC (Uppsala Monitoring Centre).
In clinical trials (study cases), blinding protects the integrity of the trial. Participants and/or investigators do not know which treatment (active drug or placebo) a patient received. PV must handle adverse event reporting while preserving this blind — which creates specific rules for how drug information appears in ICSRs, SUSARs, and aggregate reports like the DSUR.
The same case — same patient, same event — looks different depending on blinding status:
| Aspect | Study / Clinical Trial Case | Post-Marketing (PM) Case |
|---|---|---|
| Source | Clinical trial investigators, CRO, sponsor | HCPs, patients, literature, regulatory authorities |
| Drug disclosure | Blinded (study medication / protocol code) or unblinded if SAE unblinded | Always unblinded — full drug name and details |
| Term used | SAE (Serious Adverse Event) or SUSAR | ADR / SADR (post-market terminology) |
| Reference document | Investigator's Brochure (IB) — defines expectedness | SmPC / CCDS — defines expectedness |
| Reporting timeline trigger | SUSAR = 7/15 days (unexpected serious) | Serious unexpected ADR = 15 days |
| Submitted to | Competent authorities + Ethics Committees; also DSUR | EudraVigilance, FAERS, PMDA; also PSUR/PBRER |
| Aggregate report | DSUR (Development Safety Update Report) | PSUR / PBRER (Periodic Benefit-Risk Evaluation) |
| Drug in narrative | "Patient received study medication per protocol" — no name disclosed | Full product name, brand name, batch number included |
| Unblinding event | If SUSAR — unblinding by sponsor/DSMB; blinded version still sent to sites | Not applicable — always unblinded |
| Causality assessment | Investigator + Sponsor both provide separate assessments | Reporter's assessment + MAH assessment |
Unblinding of a clinical trial case is a critical decision. It should only happen when strictly necessary to protect patient safety or meet regulatory requirements.
| E2B Field | Blinded (Study) | Unblinded / PM |
|---|---|---|
| G.k.2.2 — Drug Name | Study medication / Protocol code (e.g., "XYZ-001-IMP") | Full INN or brand name (e.g., "Atorvastatin") |
| G.k.2.3 — WHO Drug Dictionary | Not populated (unknown/blinded) | WHO-DD coded entry with MPID |
| C.5 — Study Info | Populated: study number, study type, study phase | Populated only if study-related; often blank for PM |
| G.k.1 — Drug Role | Suspect (suspected study medication) | Suspect / Concomitant / Interacting |
| H — Narrative | Describes event without revealing treatment; uses protocol language | Full drug name, dose, and regimen stated explicitly |
| G.k.8 — Action taken | Study drug discontinued / dose reduced (no name) | Drug name + action fully stated |
Oracle Argus Safety is the world's most widely used pharmacovigilance safety database. It is a web-based enterprise system used by MAHs and CROs (including IQVIA) to manage the complete ICSR lifecycle — from intake and triage through medical review, regulatory submission, and aggregate reporting. It is a GAMP 5 Category 4 configured product and must be fully validated under 21 CFR Part 11.
These are scenario-based interview questions — the kind where the interviewer describes a real situation and asks how you would handle it. Read each scenario, think through your answer, then reveal the model response. These test practical knowledge, not just definitions.
| Question | Expected Answer |
|---|---|
| What Argus module generates E2B XML? | Argus Interchange |
| What is Day 0 in case processing? | Date MAH first receives valid case information |
| Name 3 Argus workflow states | Data Entry → Medical Review → QC → Submission |
| What is a locked case in Argus? | A case where no further changes are expected; reopening requires Change Request + audit trail |
| How does Argus detect duplicates? | Via worldwide unique case safety report ID (UUID in E2B R3) |
| What validation category is Oracle Argus? | GAMP 5 Category 4 — Configured Product |
| What does UAT stand for in validation? | User Acceptance Testing — business user sign-off before go-live |
| What is a traceability matrix? | Document mapping URS requirements → test scripts → test results |
| What triggers a new 15-day clock? | Significant new information on an existing case |
| Can you edit a submitted case in Argus? | Only via a new version (follow-up case) — original submission is immutable in audit trail |