Medyur Pharmaceuticals Limited
BRAND NAME:          CITICOLINE SODIUM ORAL DROPS 100 mg/mL
  GENERIC NAME:        Citicoline Sodium Oral Drops 100 mg/mL
      1.1     Detailed description of Pharmacovigilance and Risk Management System
                                                                            S
                                       Pharmacovigilance System
At present we have the manual system for compilation of safety information, risk identification and reports
generation. Our risk minimization plan includes use of following tools for providing additional educational
                             material about the medicine and its use through-
                                                                     through
                                      Patient Information Brochures
                    Physician prescribing material-updated
                                          material         based
                                                              ed on risk identification
                   Package insert-Periodically
                                  Periodically updated based on the risk identification.
   The process of Pharmacovigilance procedure starting from data collection till final reports generation is
                                        depicted in the following chart.
      Medyur Pharmaceuticals Limited
BRAND NAME:     CITICOLINE SODIUM ORAL DROPS 100 mg/mL
GENERIC NAME:   Citicoline Sodium Oral Drops 100 mg/mL
THE ORGANIZATIONAL DIAGRAM PHARMACOVIGILANCE THE HOLDER OF THE
                              REGISTRATION CERTIFICATE
 Doctors        Pharmacists         Institutions   Patients   Patients
         Medyur Pharmaceuticals Limited
 BRAND NAME:          CITICOLINE SODIUM ORAL DROPS 100 mg/mL
 GENERIC NAME:        Citicoline Sodium Oral Drops 100 mg/mL
   1.     The description of the organization’s internal Pharmacovigilance department
                                              Organization
                                 Medyur Pharmaceuticals Limited, India
                                                 Address:
                                 14 Milestone, Rudrapur-Kashipur
                                               Rudrapur          Road,
                            Gadarpur, U.S.Nagar-263152,
                                      U.S.Nagar         Uttarakhand-India.
                                   2.       Pharmacovigilance head:
 This person is Qualified Person Responsible for Pharmacovigilance, responsible for all kind of studies,
 surveys and collecting data and then access properly to give positive results. This person supervises all
                                        the data and their responses.
                            3. Pharmacovigilance
                               Pharmacovi        Senior Executives:
These persons supervise all the kind of studies, surveys, accessing of all signals and properly respond to
                                                the signals.
                                4. Pharmacovigilance Executives:
   These persons guide Marketing team so that they can effectively collect and give responses to the
information or signals from market. These persons sometimes go in the market alone or with marketing
                                 team members whenever it is required.
They move into the actual market (i.e. to the institutions, doctors, consumer of the drugs and pharmacist)
 for collecting data on the response of the drug. After collecting data from market they send these to the
                   office where this data is studied by their seniors for further actions.
               Medyur Pharmaceuticals Limited
 BRAND NAME:               CITICOLINE SODIUM ORAL DROPS 100 mg/mL
 GENERIC NAME:             Citicoline Sodium Oral Drops 100 mg/mL
     2.         A document confirming presence of QPPV on the territory of RK
                                                                           RK flow of information of
                            adverse reaction towards Pharmacovigilance department
                                     The flow of reception of adverse reaction:
1.            Information regarding adverse effects is collected from Doctors, Pharmacist, Patients, Institutions
                                               and the new researches
     2.          After analysis
                         alysis of received information from sources like doctors, pharmacists, institutions &
 Patients improved reports are prepared by executives of Pharmacovigilance department and these reports
                             then transferred to Senior Pharmacovigilance Executives.
     3.          Re-analysis
                        ysis of the generated data is performed by Senior Pharmacovigilance Executives and
          finally submittedto Pharmacovigilance head i.e. QPPA (Qualified Person for Pharmacovigilance).
     4.         The QPPA finally analyze and if require, prepare the report for submission to regional and/or
                                       Zonal Pharmacovigilance authorities.
       Medyur Pharmaceuticals Limited
BRAND NAME:        CITICOLINE SODIUM ORAL DROPS 100 mg/mL
GENERIC NAME:      Citicoline Sodium Oral Drops 100 mg/mL
                                  FLOW OF INFORMATION
                         Regional and/or Zonal Authorities
                              Pharmacovigilance QA
                                     Head
              Senior                                                Senior
         Pharmacovigilance                                     Pharmacovigilance
             Executive                                             Executive
Marketing Team         Pharmacovigilance             Marketing Team       Pharmacovigilance
                           Executive                                          Executive
     Doctors        Pharmacists            Institutions        Patients       New Clinical trials,
                                                                               publications &
                                                                                 researches
      Medyur Pharmaceuticals Limited
BRAND NAME:     CITICOLINE SODIUM ORAL DROPS 100 mg/mL
GENERIC NAME:   Citicoline Sodium Oral Drops 100 mg/mL
                    a.   RECEPTION OF MESSAGES
         Medyur Pharmaceuticals Limited
 BRAND NAME:          CITICOLINE SODIUM ORAL DROPS 100 mg/mL
 GENERIC NAME:        Citicoline Sodium Oral Drops 100 mg/mL
                                     ADVICE ABOUT REPORTING
                            Report adverse experiences with medications
           Report serious adverse reactions: A reaction is serious when the outcome is:
                                                     Death
                                     Life
                                     Life-threatening (real risk of dying)
                                    Hospitalization (initial or prolonged)
                            Disability (significant, persistent or permanent)
                                              Congenital anomalies
                  Required intervention to prevent permanent impairment or damage
                                       1.       Report even if:
                         You’re not certain the product caused adverse reaction
 You don’t have all the details although point nos. 1, 5, 7, 8, 11, 15, 16 & 18 are essentially required.
                                2.          Report can be given by:
      Any health care professional (Doctors includingDentists, Nurses and Pharmacists).
                               3.           Person should Report to:
   After completing, please return this form to the same Pharmacovigilance Centre whose address is
                                              mention on the form.
                    4.      What happens to the submitted information:
Information provided in this form is handled in strict confidence. After accessing, if Pharmacovigilance
department found new and remarkable adverse reactions then the Company’s Pharmacovigilance
                                                                         Pharmacov         Centre
will forward this information to the Peripheral and then Regional Pharmacovigilance Centers, where the
                                      causality analysis is carried out.
Data is periodically reviewed by the National Pharmacovigilance Advisory Committee. The Committee
 is entrusted
     ntrusted with responsibility to review the data and suggest any interventions that may be required.
         Medyur Pharmaceuticals Limited
BRAND NAME:           CITICOLINE SODIUM ORAL DROPS 100 mg/mL
GENERIC NAME:         Citicoline Sodium Oral Drops 100 mg/mL
                                 3. REVEALING OF SIGNALS
 The information obtained from report will be used to promote safe use of medicines in the local, national
                                                                                                  natio
and international levels. The report will be entered into the national database of adverse drug reactions and
                            be analyzed by expert reviewers on a regular basis.
               A well - completed and duly submitted ADR reported may result in:
                            Appropriate changes in the package insert.
                               Change the
                                      th schedule of the medicine.
            Enhancing educational initiatives to improve the safe use of that Medicine.
Other regulatory and health promotion interventions as the situation may warrant including withdrawal /
                      recall. Other promotional strategies that may be considered include:
                                              Posters.
                                   Leaflets for patients / doctors.
               Pharmacovigilance--related
                                  related articles in the newspapers/health journals.
            Medyur Pharmaceuticals Limited
    BRAND NAME:           CITICOLINE SODIUM ORAL DROPS 100 mg/mL
    GENERIC NAME:         Citicoline Sodium Oral Drops 100 mg/mL
                             4.             PROCEDURE OF DOCUMENTING
                                Regional and/or Zonal Authorities
    The QPPA finally analyze and if require, prepare the report for submission to regional
    and/or Zonal Pharmacovigilance authorities.
                                     Pharmacovigilance QA
                                            Head
    Reanalysis of the generated data and final submission to Pharmacovigilance head i.e.
    QPPA (Qualified Person for Pharmacovigilance).
                 Senior                                                  Senior
            Pharmacovigilance                                       Pharmacovigilance
                Executive                                               Executive
•    After analysis of received information from sources like doctors, pharmacists, institutions &
     Patients an improved reports with the data as per product, batch number of product, area
     type of patients, type of dosage schedule, type of route of administration, type of overdosage,
     type of age group of patients, type of sex of patients, period of treatment
                                                                       treatment & type of severity of
     adverse reactions are prepared and these reports then transferred to Senior
     Pharmacovigilance Executives.
•    Analysis of Adverse reactions whether they are newly identified or already discussed during
     the launching of product in publications, literatures, product manuals, product inserts & other
     product informative documents.
•    If found any particular batch of the product is responsible for described adverse reactions then
     make arrangements for the quality control analysis of aforesaid
                                                             afores batch number.
           Information regarding adverse effects are collected as per pre – approved format.
                                             Doctors
              Medyur Pharmaceuticals Limited
      BRAND NAME:                  CITICOLINE SODIUM ORAL DROPS 100 mg/mL
      GENERIC NAME:                Citicoline Sodium Oral Drops 100 mg/mL
                           5.         A DATABASE FOR PHARMACOVIGILANCE
     Main database used for Pharmacovigilance purposes (e.g. compilation of safety reports, expedited/electronic
      reporting, signal detection, sharing and accessing global safety information) are provided with a statement
                                       regarding the validation status of the database systems.
         A statement is regarding the compliance of the systems with the
                                                                     the internationally agreed standards for
                                           electronic submission of adverse reaction reports.
       Database is also used to identify potential signals and analyze data in order to clarify the risk factors and
                                                          apparent changes in reporting profiles.
       Database functionally
                      onally enables us to search and retrieve data to facilitate cumulative data review, signal
                                                               detection and trend analysis.
                                                1.          TRAINING OF EMPLOYEES
         To ensure harmonized implementation of the Programmed efforts at a uniform understanding of the
     operational systems,
                      ms, along with standardized formats to document and analyze ADRs. An induction training
                                    program is arranged for all persons after joining the division.
      Intensive interaction / training sessions is organized for not only staff within the Pharmacovigilance units
                                                                                                             u
     but also staff who may receive or process safety reports, such as sales personnel or clinical research staff to:
2.       CLEARLY DEFINE THEIR INDIVIDUAL AND TEAM ROLES AND RESPONSIBILITIES
                                            ii.              Set operational benchmarks e.g.
                                           1.              Each Pharmacovigilance Executive
                                      a.             to collate and scrutinize the data received
                           b.        to perform the analysis of all forms received every month.
                                                     c.        to submit a monthly report.
                 d.         to report any alarming or critical ADR along with supportingevidence
                                     2.           Each Senior Pharmacovigilance
                                                              Pharmacovigila    Executive
                      a.           to collate the data received from Pharmacovigilance Executive.
                                                b.           to verify / validate the analysis.
                                           c.               to pass on the final data to QPPV.
                            iii.      Evolve SOPs for generating and forwarding ADR data.
       Medyur Pharmaceuticals Limited
BRAND NAME:              CITICOLINE SODIUM ORAL DROPS 100 mg/mL
GENERIC NAME:            Citicoline Sodium Oral Drops 100 mg/mL
          iv.         Impart relevant skills for carrying out ADR data capture namely.
        1.           Appropriate communication skills to elicit ADR related information
                2.       For recording ADR information through hands-on
                                                               hands on training
                        3.     For careful collation and completeness of data
These training programs and interaction meetings
                                        meetings are used to be held every 6 months after the initial
                                                 training.
            Medyur Pharmaceuticals Limited
 BRAND NAME:                   CITICOLINE SODIUM ORAL DROPS 100 mg/mL
 GENERIC NAME:                 Citicoline Sodium Oral Drops 100 mg/mL
                 7.              THE LIST OF DOCUMENTS OF PHARMACOVIGILANCE
        Different types of documents used in the Pharmacovigilance department are as follows:
                          1.         Suspected Adverse Drug Reaction Reporting Form
                                                  2.     Expedited Report
                                                  3.     Electronic Report
                                4.          Periodic Safety Update Reports (PSURs)
                                       5.          Risk Management Assessment
                                             6.        Internal Audit Reports
                                                  7.     Training Manuals
            8.                 A CONTROL SYSTEM OF QUALITY PHARMACOVIGILANCE
For the Quality Management, Pharmacovigilance department or authorized Persons perform their activities
                 as per described responsibilities and these responsibilities are audited time to time.
                      Quality management of Pharmacovigilance is generally based on:-
                                                                                 on:
                 •        Acquiring complete data from adverse effects generation points.
                                                                                  point
                      •        Complete assessment of acquired data of adverse effects.
•          Transfer of necessary information to higher authorities of Pharmacovigilance department in the
                                             favor of safety of particular medicines.
    •         To fulfill the responsibility to make aware with found adverse effects to all related medical
                               professionals and to give corrective & preventive actions.
•           To take required safety measures and Call-back
                                                 Call back products which are already in market, if found
                                 serious adverse event or guided by higher authorities.
•           Preparation
                    ion and submission of adverse events reports and related documents like PSURs, Risk
Management systems etc. to the regional and zonal Pharmacovigilance Authorities for further study and
                                                             analyses.
      Medyur Pharmaceuticals Limited
BRAND NAME:     CITICOLINE SODIUM ORAL DROPS 100 mg/mL
GENERIC NAME:   Citicoline Sodium Oral Drops 100 mg/mL
                                 Approved By:
                                Dr. N K Nagrani
                           Head, Pharmaco-vigilance
                      Medyur Pharmaceuticals Limited, India.
                                                      India
           Medyur Pharmaceuticals Limited
     BRAND NAME:         CITICOLINE SODIUM ORAL DROPS 100 mg/mL
     GENERIC NAME:       Citicoline Sodium Oral Drops 100 mg/mL
    Document confirming presence of qualified person responsible for pharmacovigilance for
collection and registration of adverse reactions detection on the territory of Republic of Uzbekistan
                                        ===Attached Herewith===
      Medyur Pharmaceuticals Limited
BRAND NAME:      CITICOLINE SODIUM ORAL DROPS 100 mg/mL
GENERIC NAME:    Citicoline Sodium Oral Drops 100 mg/mL
                     NAME                     :             Dr. N K Nagrani
                                       PERSONAL DETAILS:
                        Name                                :      N K Nagrani
                      Date of birth                    :          March 12, 1960
                      Place of birth                    :         Lucknow, India
                      Nationality                  :            Indian
                      Address                  :
                            14 Milestone, Rudrapur-Kashipur Road,
                     Gadarpur, U.S.Nagar-263152, Uttarakhand-India.
                                                             India.
                        PROFESSIONAL EXPERIENCE
                                              Working as::
                                  Head of Department (CLINICAL AND
      Aug. 2002 Onwards                     BIOLOGICAL)in
                                           Medyur Pharmaceuticals Limited, India.
                                                                           India
                                         Engaged in private practice in own clinic as
      Jan 98 – July 2002                           Consultant Physician.
                      MEDICAL EDUCATION & TRAINING
       Sept. 96 – Aug. 98
                                         Certification, Clinical Research (CRA), INDIA
                                             Internship and Residency in Medicine,
                                                  DelhiUniversity, Delhi, India
        Nov. 93 – Oct.95
                                                          MD physician,
       Sept. 91 – Oct. 93                              Era’s Medical College
                                                           Lucknow, UP
                                                       Medical Degree MBBS,
       July 85 – May 91                                Era’s Medical College
                                                           Lucknow, UP