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RMP template 2.0.1 draft - European Medicines Agency - marijuana detection time calculator

31 October 2018
EMA/164014/2018 "Error*"EMA/164014/2018 \* MERGEFORMAT EMA/164014/2018 Rev.2.0.1 accompanying GVP Module V Rev.2
Human Medicines Evaluation

Guidance on the format of the risk management plan (RMP) in the EU – in integrated format

General consideration and guidance

This guidance should be read in conjunction with GVP module V.

According to GVP module V, the aim of a risk management plan (RMP) is to document the risk management system considered necessary to identify, characterise and minimise the important risks of a medicinal product. To this end, the RMP contains:

• the identification or characterisation of the safety profile of the medicinal product, with emphasis on important identified and important potential risks and missing information, and also on which safety concerns need to be managed proactively or further studied (the ‘safety specification’);

• the planning of pharmacovigilance activities to characterise and quantify clinically relevant risks and to identify new adverse reactions (the ‘pharmacovigilance plan’);

• the planning and implementation of risk minimisation measures, including the evaluation of the effectiveness of these activities (the ‘risk minimisation plan’).

Throughout this document, please be as concise as possible and ensure the content is scientifically based and that it does not include any element of a promotional nature. Consider which information will add value to the readers’ understanding of the safety profile of the medicinal product and how best to interpret and manage the important identified and potential risks as well as the uncertainties surrounding the information available. Please focus the document accordingly. Tabulation of any data is encouraged if it aids the presentation.

The applicant/marketing authorisation holder should include links or references to the relevant part of the eCTD dossier of the supporting documents or PSURs, when applicable. Throughout the RMP template, eCTD data/submissions should be read as eCTD or CTD data/submission, corresponding to the type of submission to the competent authority. Specific requirements for different types of initial marketing authorisation applications are described within each section of the template.

The examples provided in each Module/Section represent only guidance for writing the RMP and should not be regarded as directions in a defined scenario. Each RMP should be based on the safety data of the medicinal product.

Checklist for writing or assessing an RMP

The following general points need to be considered when writing or reviewing an RMP for a medicinal product. The checklist is meant to provide further guidance and is not part of the RMP; therefore, it should not be included in the documents submitted for assessment:

Part II: Safety specification

✓ Have all appropriate parts of the safety specification been included?

✓ Have all appropriate data been reviewed when compiling the safety specification, e.g. are there important (outstanding) issues which have not been discussed in the safety specification?

✓ If parts of the target population have not been studied, have appropriate safety concerns in relation to potential risks and missing information been included?

✓ Have limitations in the safety database (e.g. related to the size of the study population, study inclusion and exclusion criteria) been considered and what are the implications of such limitations on the safety profile of the medicinal product? Has reference been made to populations likely to be exposed during the intended or expected use of the medicinal product in the medical practice? Does the safety specification provide a true reflection of the safety concerns (e.g. important identified risks, important potential risks and/or missing information) with the medicinal product?

✓ For generic or hybrid applications, have all safety concerns from the latest version of the RMP for the reference medicinal product or from a list of safety concerns published on the CMDh website been included in the safety specification? If not, has appropriate justification been provided and has the applicant proposed a list of safety concerns? If no information on the safety profile of the reference medicinal product is available (no RMP or no CMDh list for the substance), has the safety profile been drafted considering all available relevant information (e.g. public assessment documents for the reference medicinal product, literature, applicant’s own trial data)?

Part III: Pharmacovigilance plan

✓ Are all safety concerns from the safety specification covered in the pharmacovigilance plan?

✓ Are routine pharmacovigilance activities adequate or are additional pharmacovigilance activities necessary?

✓ Are the activities in the pharmacovigilance plan clearly defined, described and suitable for identifying or characterising risks or providing missing information?

✓ Are the safety studies that have been imposed by a competent authority as conditions clearly identified?

✓ If there are safety concerns derived from medication errors, does the RMP include appropriate proposals to monitor the correct use of the product?

✓ Are the proposed additional studies necessary, feasible, non-promotional and able to provide the required further characterisation of the risk(s) and address the scientific questions?

✓ Are timelines and milestones appropriate and feasible for the proposed actions, including those for the submission of results?

Part IV: Plans for post-authorisation efficacy studies

✓ Have all post-authorisation safety studies (PAES), either as conditions of the marketing authorisation or as specific obligations, been included?

Part V: Risk minimisation measures

✓ Are routine risk minimisation measures sufficient or is there a need identified for additional risk minimisation activities?

✓ Have additional risk minimisation activities been suggested and, if so, are these sufficiently justified and risk-proportionate? Is implementation feasible in all Member States?

✓ Have criteria for effectiveness of additional risk minimisation activities been defined a priori?

✓ Are the methods for evaluating the effectiveness of risk minimisation activities well described and appropriate?

Part VI: Summary of the risk management plan

✓ Is it a true representation of the RMP?

✓ Have the facts been presented appropriately without any elements of promotional nature?

EU Risk Management Plan for (INN or common name)

RMP version to be assessed as part of this application:

RMP Version number:

An RMP should be assigned a new RMP version number and a date each time the RMP is updated and submitted for assessment (e.g. versions 0.1, 0.2, 0.3 etc. for an initial submission of an RMP; versions 1.1, 1.2, etc. and 2.1, 2.2 etc. for RMP updates post-authorisation).

The version number of the RMP version agreed at the time of the competent authority opinion should be the same as the one provided with the last eCTD submission in the procedure (most often with the closing sequence). It is advisable to use major version numbers for final approved RMP versions (e.g. version 1.0 at the end of the initial marketing authorisation application; 2.0, 3.0, etc. for post-authorisation updates).

Data lock point for this RMP:

It is recommended that the Data Lock Point (DLP) should not be more than 6 months before the RMP sign-off date.

For initial marketing authorisation applications it usually reflects the DLP of the Clinical Safety Summary.

Date of final sign-off:

The date of sign-off is the date when the draft RMP was considered finalised and ready for submission to the regulatory agency.

Rationale for submitting an updated RMP:

Summary of significant changes in this RMP:

This section is applicable for post-authorisation RMP updates when a different RMP version is still under assessment with another procedure.

If two or more parallel procedures contain RMP submissions, to facilitate assessment, it is usually advised to submit a common consolidated version of the RMP; the supporting Word version of the RMP included with the submission should include track changes (colour coded for each procedure), so that changes related to each procedure can be easily identified. This will also facilitate the finalisation of the RMP for each procedure.

Where the submission of a common, consolidated RMP version is not practical, distinct RMP documents may be submitted with each procedure (Word versions should also include tracked changes, per procedure). For further guidance please refer to European Medicines Agency post-authorisation procedural advice for users of the centralised procedure[1]. The best regulatory path for the RMP update in case of multiple procedures potentially impacting on the RMP content should be discussed with the competent authority before submissions.

RMP Version number:

Submitted on:

Procedure number: ,

This section is not required for initial marketing authorisation applications.

There can only be ONE currently approved RMP for a product(s).

If several updates to the RMP are submitted during the course of a procedure, the version considered as the “current” approved RMP for future updates and track-changes purposes shall be the one mentioned in the Opinion documents (most often same version is submitted with the closing sequence of the procedure).

Version number:

Approved with procedure:

Date of approval (opinion date):

QPPV name[2]:

The QPPV´s actual signature or the evidence that the RMP was reviewed and approved by the QPPV should be included in the finalised approved version of RMP.

In the case the option of oversight declaration has been selected and no signature has been submitted, the MAH should have the actual signature in their system, either in pen on paper, digital signature attached to the RMP document or any other electronic system of document management. For eCTD submission, this would be the RMP with the last eCTD sequence of the procedure (usually the closing sequence).

Select one of the options:

QPPV signature:


QPPV oversight declaration:

Table of content

Table of content 6

Part I: Product(s) Overview 8

Part II: Module SI - Epidemiology of the indication(s) and target population(s) 10

Part II: Module SII - Non-clinical part of the safety specification 12

Part II: Module SIII - Clinical trial exposure 13

Part II: Module SIV - Populations not studied in clinical trials 15
SIV.1 Exclusion criteria in pivotal clinical studies within the development programme 16
SIV.2 Limitations to detect adverse reactions in clinical trial development programmes 16
SIV.3 Limitations in respect to populations typically under-represented in clinical trial development programmes 16

Part II: Module SV - Post-authorisation experience 17
SV.1 Post-authorisation exposure 18

Part II: Module SVI - Additional EU requirements for the safety specification 19

Part II: Module SVII - Identified and potential risks 19
SVII.1 Identification of safety concerns in the initial RMP submission 21
SVII.2 New safety concerns and reclassification with a submission of an updated RMP 26
SVII.3 Details of important identified risks, important potential risks, and missing information 27

Part II: Module SVIII - Summary of the safety concerns 28

Part III: Pharmacovigilance Plan (including post-authorisation safety studies) 29
III.1 Routine pharmacovigilance activities 29
III.2 Additional pharmacovigilance activities 30
III.3 Summary Table of additional Pharmacovigilance activities 31

Part IV: Plans for post-authorisation efficacy studies 33

Part V: Risk minimisation measures (including evaluation of the effectiveness of risk minimisation activities) 34
V.1. Routine Risk Minimisation Measures 35
V.2. Additional Risk Minimisation Measures 36
V.3 Summary of risk minimisation measures 38

Part VI: Summary of the risk management plan 40
II.A List of important risks and missing information 42
II.B Summary of important risks 43
II.C Post-authorisation development plan 44
II.C.1 Studies which are conditions of the marketing authorisation 44
II.C.2 Other studies in post-authorisation development plan 44

Part VII: Annexes 45
Annex 1 – EudraVigilance Interface 45
Annex 2 – Tabulated summary of planned, ongoing, and completed pharmacovigilance study programme 45
Annex 3 - Protocols for proposed, on-going and completed studies in the pharmacovigilance plan 46
Annex 4 - Specific adverse drug reaction follow-up forms 47
Annex 5 - Protocols for proposed and on-going studies in RMP part IV 47
Annex 6 - Details of proposed additional risk minimisation activities (if applicable) 47
Annex 7 - Other supporting data (including referenced material) 51
Annex 8 – Summary of changes to the risk management plan over time 51

Part I: Product(s) Overview

Table Part I.1 – Product(s) Overview

Unless significantly different for each product, the following table is expected to be completed only once for each substance.

|Active substance(s) | |
|(INN or common name) | |
|Pharmacotherapeutic group(s) (ATC Code) | |
|Marketing Authorisation |Name of the marketing authorisation applicant for initial marketing authorisation applications.|
| |For mutual recognition/ decentralised procedures applications include also information on |
| |expected future marketing authorisation holders in the reference member state, if this |
| |information is known at the time of the application. |
|Medicinal products to which this RMP refers |Indicate total number of products to which the RMP refers |
| | |
|Invented name(s) in the European Economic |For decentralised/mutual recognition products include only the invented name(s) in the |
|Area (EEA) |reference member state. |
|Marketing authorisation procedure | |
|Brief description of the product |Chemical class |
| |Summary of mode of action |
| |Important information about its composition (e.g. origin of active substance for biologicals, |
| |relevant adjuvants or residues for vaccines) |
|Hyperlink to the Product Information |Include a link or reference to the proposed PI in the eCTD sequence. |
| |If no updated PI is submitted with the procedure, the link should direct to the latest approved|
| |PI. |
|Indication(s) in the EEA |Current: |
| |For initial marketing authorisation applications, this section refers to the indication |
| |proposed by the applicant. For post-authorisation procedures, it refers to the indication that |
| |is currently approved. |
| |Proposed (if applicable): |
| |For post-authorisation procedures, e.g. if the RMP is submitted with an extension/restriction |
| |of indication |
|Dosage in the EEA |Current: |
| |For initial marketing authorisation applications, this section refers to the posology proposed |
| |by the applicant. For post-authorisation procedures, it refers to the posology currently |
| |approved. |
| |Summarise information only related to the main population; not a duplication of all |
| |dosages/dosage adjustments for the sub-populations listed in SmPC section 4.2. |
| |Proposed (if applicable): |
| |Summarise information only related to the main population; not a duplication of all |
| |dosages/dosage adjustments for the sub-populations listed in SmPC section 4.2. |
|Pharmaceutical form(s) and strengths |Current (if applicable): |
| |Proposed (if applicable): |
|Is/will the product be subject to additional |Yes/No |
|monitoring in the EU? |At initial marketing authorisation application conclusion or with RMP updates |

Part II: Safety specification

For full initial marketing authorisation applications, all modules in Part II should be submitted. The requirements for other types of initial marketing authorisation applications are provided in section V.C.1.1 of the GVP – Module V.

If a reference medicinal product is authorised, please check if it has an RMP/summary for the RMP published on the EMA[3] and/or national competent authorities’ website or whether the safety concerns for a substance/reference product are published on the CMDh[4] website. If the Applicant considers that the available evidence justifies the reclassification or removal of a safety concern, this should be discussed. Similarly, if the Applicant has identified a new safety concern specific to the product (e.g. risks associated with a new formulation, route of administration or new excipient; or a new safety concern raised from any clinical data generated), this should be also discussed and the new safety concern detailed in Module SVII.

Article 14(2) of Regulation (EC) No 1394/2007 provides for a specific framework for RMP for advanced therapy medicinal products (ATMP). The marketing authorisation applicants/holders should adapt the risk management plans of ATMP, considering and discussing the anticipated post-authorisation follow-up needs, focusing on particularities of these medicinal products. The specific RMP content requirements for ATMP should be discussed with the competent authority before the submission.

Part II: Module SI - Epidemiology of the indication(s) and target population(s)

This section should only contain data relevant for the identification of the safety concerns (see module SVII).

Information on inter-regional (e.g. EU, US, Asia, Africa etc.) variations may be provided when relevant, but the focus should be on the European population. A brief summary of epidemiology is expected to be provided. This summary should provide an interpretive, high level overview of the information avoiding detailed discussion on specific epidemiology studies or published articles.

When the medicinal product has/is expected to have several authorised indications, the data for the different indications should be integrated where this is sensible from a clinical perspective. When there are clinically relevant differences in user characteristics between the authorised indications, separate sections are, however, expected for each authorised indication (e.g. Crohn’s disease and rheumatoid arthritis; multiple sclerosis and hairy cell leukaemia).

This module may not be applicable or have a reduced content for RMPs submitted with initial marketing authorisation applications involving:

o Generic medicinal products;

o Fixed combination medicinal products which do not contain a new active substance;

o “Well established medicinal use” medicinal products;

o Biosimilar medicinal products.

For hybrid medicinal products, the requirements are based on risk proportionality principle, addressing the differences with the “originator” product.



Demographics of the population in the indication – (when relevant for assessment of safety and risk management) and risk factors for the disease:

The main existing treatment options: summarise the standard of care, with the view of the expected safety profile and outcome in the absence of treatment with the medicinal product

Natural history of the indicated condition in the population, including mortality and morbidity:

Discuss the possible stages of disease progression to be treated and applied to the natural history of the indication in the (untreated) population. This section should also describe concisely the relevant adverse events to be anticipated in the (untreated) targeted population in EU, their frequency and their characteristics.

Important co-morbidities:

The risks of the medicinal product are evaluated based on the characteristics of the medicinal product (e.g. documented in clinical trials) and the context of use: expected co-morbidities and co-medications in the target population.

This section should include, where clinically relevant, diseases distinct from the indication that occur frequently in patients with the indicated condition (e.g. hypertension is a co-morbidity for hyperlipidaemia); a simple list is sufficient.

For guidance on when information should be provided on co-morbidities in the target population, please consider the following examples:

• If the target population for a medicinal product is men with prostate cancer, the target population is likely to be men over the age of 50 years, and they have an increased risk for myocardial infarction.

• Patients with psoriasis are at an increased risk of depression and suicidal ideation and behaviour.

Part II: Module SII - Non-clinical part of the safety specification

This module should present a high-level summary of the significant non-clinical safety findings. The topics should normally include, but do not need to be limited to:

Key safety findings from non-clinical studies and relevance to human usage: (for each safety finding)

• key issues identified from acute or repeat-dose toxicity studies
• reproductive/developmental toxicity
• genotoxicity
• carcinogenicity
Safety pharmacology as applicable
• cardiovascular system, including potential effect on the QT interval
• nervous system
• etc.
Other toxicity-related information or data as applicable

What constitutes an important non-clinical safety finding will depend upon the medicinal product, the target population and experience with other similar compounds or therapies in the same class. Normally, significant areas of toxicity (by target organ system) and the relevance of the findings to the use in humans should be discussed. Also, quality aspects, if relevant to safety (e.g. genotoxic impurities), should be discussed. If a medicinal product is intended for use in women of childbearing age, data on the reproductive/developmental toxicity should be explicitly mentioned and the implications for use in this population should be discussed. Based on these discussions, the applicant should comment if there are any findings in the non-clinical testing warrant inclusion among the summary of safety concerns; i.e. being an important identified risk, important potential risk, or if a non-clinical study is missing information.

Where studies do not raise concerns in relation to human safety, these should be mentioned, if relevant, to the target population (e.g. no signs of reproductive or developmental toxicity if the medicinal product is intended for use in women of childbearing age).

For full initial marketing authorisation applications where the Applicant generated no non-clinical data, relevant data available from bibliographical sources should be presented.

Where the non-clinical safety finding is not considered relevant for human beings, the provision of a brief explanation is required, and the safety finding is not expected to be carried forward to SVII and SVIII as a risk.

If, based on the assessment of the non-clinical or clinical data, additional non-clinical studies are considered warranted, this should be briefly discussed here.

In the Post-authorisation phase, this section would only be expected to be updated when new non-clinical data impact the list of safety concerns. Safety concerns identified on the basis of non-clinical data which are no longer relevant and/or have not been confirmed when sufficient relevant post-marketing experience and evidence are gathered can be removed from the list of safety concerns.

This module may not be applicable or have a reduced content for RMPs submitted with initial marketing authorisation applications involving:

o Generic medicinal products;

o Hybrid medicinal products;

o “Well established medicinal use” medicinal products.

For fixed combination medicinal products with a new active substance, the focus of this module should be on the data generated for the new active substance. For fixed combination medicinal products with no new active substance, the module should contain information on the new non-clinical data generated, if any.

Part II: Module SIII - Clinical trial exposure

In this module, in order to assess the limitations of the human safety database, summary information on the clinical trial exposure should be provided in an appropriate format (e.g. tables/graphs) at time of submission of the initial RMP or when there is a major update due to new exposure data from clinical studies (e.g. in a new indication). The content of this section should be assessed for relevance over time and, in the absence of new significant clinical trial exposure data, this section does not need to be updated.

Data should be pooled and not shown per individual trial unless there are clearly relevant and duly justified reasons why some data cannot be pooled or combined.

If the RMP includes more than one medicinal product, the total population table should be provided for each medicinal product as well as a table that combines the information on total patients exposed for all medicinal products, as appropriate.

The cumulative exposure data in this module (including cumulative data per indication, treatment duration, patient population, formulation), when presented in an aggregated form, would not be deemed to be commercially confidential and thus would not be redacted in case of an access to document request (unless a detailed justification is provided which demonstrate how the release of the data would undermine the commercial interests or competitive position of the company)[5].

The categories below are suggestions; tables/graphs should be tailored to the product according to the availability of data:

Table SIII.1: Duration of exposure

|Cumulative for all indications (person time) |
|Duration of exposure |Patients |Person time |

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