Back to Basics – The Risk Management Plan (RMP)
The Risk Management Plan (RMP) documents the risk management system considered necessary to identify, characterise and minimise a medicinal product’s important risks.
The RMP should be updated throughout the life cycle of the product, for example;
- if there is a change in the list of the safety concerns
- when there is a significant change in the existing additional pharmacovigilance activities
- if an emerging safety issue is confirmed.
The RMP should be assigned a new RMP version number and a date each time it is updated and submitted for assessment.
An updated RMP can be submitted as a standalone [currently C.I.11] variation, when necessary, but it is most often submitted as a consequence of or part of another variation.
The format and content of the RMP should follow the RMP template; Guidance on the format of the risk management plan (RMP) in the EU – in integrated format which consists of seven parts.
For a generic medicinal product, hybrid products and/or fixed combination products with no new active substance the safety concerns should be aligned to those of the originator product that are available;
- either from the originator’s approved RMP
- or from the list of safety concerns of the substance published on the CMDh website.
RMPs are approved per each medicinal product, not per MAH, therefore only one RMP should be submitted for an MRP or DCP with different MAHs. The RMP must remain identical in RMS/all CMS throughout the product life cycle.
The RMP should be provided in eCTD section 1.8.2. To facilitate the assessment a ‘tracked changes’ version of the RMP, in Microsoft word, should also be provided in the ‘working-documents’ folder outside eCTD.
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 the document; for eCTD submissions this would be the RMP submitted with the last eCTD sequence of the procedure (usually the closing sequence).
UK RMP: The MHRA states you can either submit a GB/UK RMP or use the approved EU RMP with the GB/UK specific annex attached. Further information of UK RMP can be found on the MHRA website and their Guidance note on good pharmacovigilance practices.
Feel free to contact us here at ERA to assist you with all things regulatory in Ireland, UK and across the EU.
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Written by
Fiona Downey
Fiona Downey 1
