FDA regulations
Mechanisms
As early as possible
b. regulatory affairs
e. legal department
RISK MANAGEMENT TEAM
ORGANISATION
KEY ASPECTS
• Clearly defined roles and responsibilities
• Leader (Reward power)
• Key decisions of the product
• Reward system
• Regulatory affairs office
TEAM AT UPJOHN
Cross-functional team
Led by marketing
Team divided into 2 parts
Cont…
PRE-RELAESE PHASE
• Product developers
• Research
• Internal processes
• Shape the product
• Safety and efficacy
POST-RELEASE PHASE
• Product commercializes
• Fine tune promotions
• Marketing plan
• Responds to issues (not necessarily related to safety)
EXTENDED CHALLENGES
External factors-
• Physicians giving wrong prescription
• Given to contraindicated patients
• Wrong dosage
• Example- Cleocin (anti-staphylococcus antibiotics)
Standard dose- 150mg four times a day
Prescribing 450mg four times a day
• Lower than effective dose
FDA & POST APPROVAL STEPS
• Pairing of RM team with company’s FDA representation team
• Choice of members simplified
• More effective as representatives
CONTD…
POST- APPROVAL
• Rigorous surveillance system
• Take immediate action
• Benefit to other product’s launch
• Helps ward off FDA intervention
IMPLICATIONS
• One of the earliest company to address risk management
issue
• Pharmacia & Upjohn merged with Pfizer
Pfizer’s REM
Risk evaluation and mitigation strategy, includes
• A medication guide
• A patient package insert
• Communication plan- information to health care
providers
• Elements to ensure safe use of product:-
1. Training/certification for health care professionals
2. Dispensing medicine in certain settings
3. Registration of each patient using medication
• An implementation system