Better Regulation of Medicines Initiative (BROMI)

Better regulation is an important Government agenda aimed at minimising bureaucracy for businesses and front-line staff in the public sector and delivering better public services. BROMI forms an important part of this initiative.

National Business Awards logo

Better regulation is an important Government agenda, aimed at minimising bureaucracy for businesses and front-line staff in the public sector and delivering better public services. As part of this initiative, and in response to the Better Regulation Task Force report `Regulation - Less is More’ March 2005 (external link), all Government Departments have drawn up simplification plans. One aspect of the Department of Health’s simplification plan (which can be viewed at on the Department of Health website) is the work of BROMI.

4 November 2011: MHRA stop sending Anonymised Single Patient Reports (ASPRs)/Individual Case Safety Reports (ICSRs) from literature articles to industry

Anonymised Single Patient Reports (ASPRs) and electronic equivalent, E2B Individual Case Safety Reports (ICSRs) sent to industry by the MHRA from ADRs reported in literature articles have been identified by the BROMI Vigilance workstream as an area where significant efficiencies could be made.

As of 24 October 2011, the MHRA updated the logic for how adverse drug reaction reports received are sent out to companies to prevent literature article based ADRs being sent out as ASPRs/ICSRs. Analysis by the MHRA has shown that this will reduce the number of ASPRs/ICSRs sent out to industry by between 33-50%.

The MHRA will be performing an analysis on the reduction in ASPRs/ICSR to calculate estimated savings, and results will be presented at the subsequent BROMI Vigilance meeting and communicated to industry.

Companies should continue to check the list of literature ADRs reported to the MHRA to check whether an ADR from a literature article has already been reported. The following process should be followed:

  1. Once a literature article reporting an ADR is identified, this should be entered into the marketing authorisation holder’s (MAH’s) pharmacovigilance system for collection and collation of ADR reports.
  2. Before submission of an expedited report to the MHRA, open the Excel file.
  3. Check the literature reference in the company report against the literature references.
  4. If the literature article and patient details can already be identified in the list, the company report should not be forwarded to the MHRA. The MHRA ADR reference should be added to the company ADR documentation and a record added that the ADR has been located on the MHRA literature ADR list with date.
  5. If the literature article and patient cannot be identified in this list, the ADR should be submitted to the MHRA as per the reporting requirements defined in Volume 9A.

For access to the list, and more information please visit the page below:

Adverse drug reaction (ADR) reports received by the MHRA from literature articles

17 February 2011: Best Practice in Reporting of Individual Case Safety Reports (ICSRs)

We are pleased to announce the release of the 'Best Practice in Reporting of Individual Case Safety Reports (ICSRs)'. The guide sets the MHRA's position on how to code adverse drug reactions (ADRs) to a high-quality standard for entry into our Sentinel database.

Data quality of ICSRs is an important issue that affects all stakeholders, particularly to support accurate detection and analysis of drug safety signals. Furthermore, errors in reports create a large volume of enquiries, resulting in a significant administrative burden for both industry and the MHRA in updating cases. The need to develop a guide was identified as a Better Regulation of Medicines Initiative (BROMI), combining ideas from both the MHRA and UK industry trade associations to address differences that occur in classification and coding practices across companies.

Industry colleagues may be aware that in parallel to producing this guide we have been conducting quality audits on a company by company basis. The selection for audit may be based upon concerns raised through review of reports at signal assessment, compliance data or intelligence gathered from pharmacovigilance inspections.

Companies with a high error rate are invited to discuss the findings. It is hoped the guide will contribute to delivering high standards in classification by highlighting common findings from audits of ICSRs and providing specific examples of good practice. We see the guide as a useful way to improve quality without the need for face to face meetings with companies.

We hope you find this guidance helpful and are able to implement the ‘Best Practice’ within your pharmacovigilance system. If you have any comments or questions, please send them to the Pharmacovigilance Service Desk by e-mail pharmacovigilanceservice@mhra.gsi.gov.uk

Best Practice in Reporting of Individual Case Safety Reports (ICSRs)PDF file (opens in new window) (838Kb)
 

Reports on progress

On 12 March 2012, BROMI published its fifth report on progress:

Better Regulation of Medicines Initiative (BROMI): Fifth report on progressPDF file (opens in new window) (109Kb)

This report outlines further progress since the fourth report and developments include:

  • work to further expand the patient information self certification scheme
  • a reduction in the volume of Anonymised Single Patient Reports (ASPRs) generated and sent out to industry
  • a new approach to coordinated communications to healthcare professionals
  • new workstreams on reclassification of medicines and communications.

On 15 September 2009,  BROMI published its fourth report on progress:

Better Regulation of Medicines Initiative (BROMI): Fourth report on progressPDF file (opens in new window) (182Kb)

This report outlines further progress since the third report and developments include:

  • updated Variations Regulations which will come into force on 1 January 2010
  • the success of BROMI at the National Business Awards in November 2008
  • the agreement of the third party pre-approval scheme for changes to pack design for patient information as a mainstream procedure
  • the exciting initiatives that are moving forward in the pharmacovigilance work stream.

On 8 May 2008, BROMI published its third report:

Better Regulation of Over-the-counter Medicines Initiative: Third report and recommendationsPDF file (opens in new window) (133Kb)

This report outlines further progress since the third report and developments include:

  • a self-certification scheme for certain minor changes to labeling and patient information leaflets rolled out to the prescription only (POM) sector from 1 November 2006 and the quality audit system has moved from 100% to 10%
  • a pilot is underway to assess the feasibility of MA holders working together to produce a common PSUR for the same active substance through a work sharing scheme
  • a streamlined process for processing applications for copy licenses under Article 10c of Directive 2001/83/EC (as amended) went live on 1 February 2007 and is being monitored
  • a mechanism has been implemented to allow roll over of pending variations from the old to the new licence following a change of ownership application, including the roll over of Periodic Safety Update Reports (PSURs) and renewals.

On 11 December 2006, BROMI published its second report:

Better Regulation of Over-the-counter Medicines Initiative: Second report and recommendationsPDF file (opens in new window) (114Kb)

This report outlines further progress since the first report and developments include:

  • wider roll out of the product information self-certification scheme to the prescription-only medicines (POM) sector
  • work on the development of a code of practice on pack re-design outlining a self-certification model for non-statutory packaging information
  • initiation of a review of the medicines statutory label warnings
  • progress on the second work stream in relation to variations, copy licences and change of ownership applications
  • identification of a third work stream in relation to pharmacovigilance requirements.

The first report of BROMI was published in May 2006:

Better Regulation of Over-the-counter Medicines Initiative: First report and recommendationsPDF file (opens in new window) (108Kb)

National informed consent ('simple abridged', Article 10c) applications

The process for approval of national marketing authorisation applications submitted under Article 10c of the Directive (‘simple abridged applications’) has been reviewed within BROMI.  Further information is available in the section below:

National informed consent ('simple abridged', Article 10c) applications
 

The following presentation was presented at the 2008 MHRA Annual Conference. It highlights the most common deficiency areas related to BROMI simple applications

Better Regulation of Medicines Initiative (BROMI) simple applicationsPDF file (opens in new window) (831Kb)

Detailed Descriptions of Pharmacovigilance System (DDPS)

The BROMI Detailed Descriptions of Pharmacovigilance System (DDPS) requirements have been superseded by the new pharmacovigilance legislation introduced in 2012.  For information on the transition to the Pharmacovigilance System Master File please visit 2012 pharmacovigilance legislation changes: implications for marketing authorisation holders

BROMI Renewals

Following a successful BROMI project new procedures have been put in place for national renewals. This involves a reduced submission whereby information that is currently held on the Sentinel database may be omitted from the consolidated renewal file (see list below). In addition applicants are required to submit a cover letter which includes a checklist. This will enable us to channel the renewal application to the appropriate assessment team and expedite assessment.

You should submit your national renewal through the portal in the usual manner and include the completed letter template (see link). The following documents may be omitted from the consolidated file if they are the same as previously advised and no changes are proposed:

  • Details of contact persons
  • Chronological list of variations
  • Current Summary of Product Characteristics, labels and leaflets
  • Authorisations/GMP Certificates for manufacturing sites
  • Declaration from a QP that the active is manufactured in accordance with GMP.

You are expected to check the information held on RAMA. Please note that details of any errors or anomalies that you may identify in the licence data held on our systems should be sent to the Data Review Team at DataReviewTeam@mhra.gsi.gov.uk. If you do not have access to RAMA please submit the documents but still use the letter template.

BROMI renewal Letter Template Word file (opens in new window) (46Kb)

MHRA key BROMI contacts


Information workstream Jan MacDonald
020 3080 6267
Authorisation workstream

Copy licences
Keith MacDonald
020 3080 6105

Change of ownership
Aidan Hardy
020 3080 6693

Vigilance workstream Mick  Foy
020 3080 6633


Page last modified: 10 December 2012