.png)
PSURs (Periodic safety update reports)
The PSUR (Periodic Safety Update Report) is a periodic evaluation of the risk-benefit balance of a medicinal product and provides an analysis of its safety and efficacy profiles throughout the medicine life cycle. The submission of a PSUR for a medicinal product to the competent authorities is regulated bi Law and shall follow relevant procedures and timelines established at European level in accordance with Community rules.
Submission of the PSUR for a medicine
The PSUR shall be sumbitted for all approved medicinal products unless they are covered by the derogation given in Directive 2001/83, Article 107b.3, regardless of the marketing status of the product.
The presentation of PSURs does not exempt the MAH from the obligation to report any important new information related to the safety and efficacy of the product, as required by current legislation and good pharmacovigilance practices.
The format and content of the PSUR are described in the GVP Module VII published on the EMA website.
When to submit the PSUR
The MAH shall check the EURD list to verify the DLP and the submission date of the PSUR for the active substance of the medicinal product. In particular, MAHs of products authorised under Articles 10(1), 10a, 14 and 16a shall check the list to verify whether the PSUR is required also for these types of products and act accordingly.
PSUR Work Sharing and Synchronisation Project
The PSUR Work Sharing and Synchronisation Project was initiated in 2002 with the aim of harmonising PSUR data lock points (DLP) allowing Marketing Authorisation Holders (MAHs) to submit PSURs for products containing the same substance to National Competent Authorities (NCAs) at the same time, thereby allowing work sharing and reducing administrative burden for NCAs.
With the entry into force of Directive 2010/84/EU and Regulation 1235/2010/EU, the PSUR WS and PSUR Synchronization project has represented the basis for the gradual introduction of the PSUR Single Assessment (PSUSA) procedure for nationally authorised medicinal products.
The PSUR WS was officially declared concluded in December 2019. Through this project, over 1,500 procedures have been finalized, with a significant reduction in the workload for NCAs and MAHs.
The PSUR WS and PSUR Synchronization project represented a key example of successful voluntary collaboration between National Agencies and Industry, aimed at managing large volumes of work and simplifying the safety assessment processes of medicines, and simultaneously improving of resource allocation. It also significantly contributed to the harmonization of information on the safety of products containing the same active substances/combinations of active substances in Europe.
Evaluation of PSURs in the PSUSA procedure
Directive 2010/84/EU introduced the principle of the European evaluation procedure of PSURs for active ingredients or combinations authorized in more than one Member State (PSUR Single Assessment or PSUSA procedure) and established the creation of a single list of active ingredients and associated DLPs (EURD list).
The assessment of PSURs under the PSUSA procedure involves the active ingredients/combinations of medicines authorized via the centralized procedure (Centrally Authorised Products or CAPs), medicines authorized by national authorization procedures and those authorised through mutual recognition or decentralized procedure (Nationally Authorised Products or NAPs).
The implementation of the outcome of the PSUSA procedures is a legal obligation for marketing authorization holders (MAHs), including those medicines exempted from participating in the procedure but containing the same active ingredients or combinations of active ingredients. Therefore, when a PSUR single assessment procedure leads to a variation of the marketing authorization, MAHs of all the products containing the active ingredients/combinations subject to the procedure are required to submit a variation application to align their products to the PSUSA procedure outcome.
The timelines for submission of the concerned variation applications may vary, depending on the type of marketing authorization and decision-making process:
- for the PSUSA procedures including CAPs, the MAHs of the medicines authorized with centralized procedure involved in the procedure do not have to submit a variation application at the end of the procedure, as the outcome is directly implemented when the European Commission issues its decision updating the EPAR on the EMA portal
- the MAHs of CAPs not involved in the PSUSA procedure should submit a variation application within 60 days from the communication received from the EMA
- if the procedure involves CAPs + NAPs, the MAHs of the NAPs should submit the request for variation according to the timelines reported in the table below*, while the above applies to CAPs.
- for PSUSA procedures involving NAPs only (medicines authorised by national, mutual recognition and decentralized marketing authorization procedures), the concerned MAHs should submit the variation application as per the timelines and criteria reported in the table below*, depending on whether the position of the CMDh was adopted by consensus or by majority.
* Timelines for submission of the variation applications for the adaptation of product information of the NAPs following the conclusion of the PSUSA procedures (PSUSA NAPs only and CAPs/NAPs procedures)
NAPs involved in the PSUSA procedure | NAPs NOT involved in the PSUSA procedure | |
PSUSA NAPs only procedures - CMDh position by consensus | As per timetable attached to the PSUSA assessment report published on the EMA website | As per timetable attached to the PSUSA assessment report published on the EMA website |
PSUSA NAPs only procedures - CMDh position by majority | MAHs to submit variations within 10 days after publication of the Commission Decision on the EC website. EC Decision are published on this page | MAHs to submit variations within 60 days after publication of the Commission Decision on the EC website. EC Decision are published on this page |
PSUSA CAPs/NAPs mixed procedure | MAHs to submit variations within 60 days after publication of the Commission Decision on the EC website. EC Decision are published on this page | MAHs to submit variations within 60 days after publication of the Commission Decision on the EC website. EC Decision are published on this page |
Follow up of the PSUSA: the PSUFU procedure for NAP
If at the end of a PSUSA procedure it was not possible to finalize the examination of a safety issue (for example a signal, a new risk or other safety data), the Lead MS or the PRAC may exceptionally recommend to the CMDh the implementation of a PSUFU procedure (for guidelines on Follow-Up PSURs see http://www.hma.eu/314.html), where it is deemed necessary to review such data before the date of the following PSUR.
As for the PSUSA NAP and PSUR WS procedures, a Summary Assessment Report of the procedure (SmAR) is also published for the PSUFU on the CMDh website http://www.hma.eu/611.html, which includes the Lead MS recommendations and the rationale/justification for such recommendations.
The MAHs of the medicines involved are required to periodically consult the aforementioned site to find out about the requirements to be fulfilled. In particular, if the conclusion of the PSUFU procedure has resulted in a recommendation requiring modification of the product information or, in general, of the Marketing Authorization, the texts to be implemented will also be published. The standard deadline for submitting changes is 60 days from the date of publication on the aforementioned site, unless a different date is expressly indicated in the text of the recommendation.
Documents for the PSUSA procedures and submission of PSURs
For the submission of PSURs as of 13 June 2016, the use of the PSUR Repository is mandatory. Information and instructions for registration to the repository are available on this page.
The PSUSA procedure relating to the PSUR assessment of active ingredients contained in medicinal products authorized with centralized procedure, also applied in the case of mixed PSUSA procedures of active ingredients contained in both CAP and NAP (CAP + NAP procedures), together with the EURD list and information on how to submit the PSUR, can be found on the EMA website.
The procedure relating to the assessment of PSURs of active ingredients contained in medicinal products authorized only with the national procedure can be found on the HMA/CMDh website (“CMDh Standard Operating Procedure on the Processing of PSUR Single Assessment for Nationally Authorised Products”).
PSUR of active ingredients NOT listed on the EURD list or on the Extended list
Active ingredients not listed on the EURD list (or on the Extended list) are active ingredients authorized in one Member State only. Therefore, the submission of the PSUR is subject to the normal sending frequency required by current legislation, as also specified in chapter VII.C.2. Standard submission schedule of PSURs of Module VII of the GVP - Periodic safety update report, except for different conditions imposed at the time of the marketing authorization by the competent authority.
In the event that the active ingredient/combination of active ingredients is not on the EURD list but the medicine is authorized in more than one European Member State, an email can be sent to the EMA to EURDList@ema.europa.eu
Since the use of the PSUR Repository for the filing of PSURs has become mandatory as of 13 June 2016, MAHs of medicinal products containing active ingredients/combinations of active substances authorized only in a member state are required to send their PSURs through the PSUR Repository, according to the methods described above