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Human Oversight in AI-Enabled Pharmacovigilance: What ‘HITL’ Actually Has to Mean

1. Why Human Oversight Is a Control, Not a Reassurance

  • As artificial intelligence becomes embedded in pharmacovigilance workflows, the presence of a human reviewer is often assumed to be a safeguard. The implicit belief is that if a person is
    involved somewhere in the process, risk is automatically controlled. That assumption is flawed.
  • Human oversight in AI-enabled pharmacovigilance is not a reassurance mechanism. It is a control. Its purpose is to mitigate known and foreseeable risks associated with automated
    outputs, including missed information, biased interpretation, and over-reliance on system recommendations.
  • In safety-critical activities, simply adding a human step does not guarantee meaningful oversight. If the human role is poorly defined, lacks authority, or is limited to confirming system
    outputs, the risk profile remains largely unchanged. In some cases, it may worsen, as apparent human involvement can increase unwarranted trust in the system.
  • Effective oversight must therefore be intentional. It requires clarity on when human judgement is expected to intervene, what decisions a human can override, and how that intervention materially affects outcomes. Without this clarity, “human review” becomes a procedural label rather than a genuine risk control.
  • For pharmacovigilance organisations, this distinction matters. Oversight exists to manage the consequences of error, not to create comfort that a process appears compliant. Treating human involvement as a checkbox undermines its purpose and leaves critical risks unaddressed.

2. What Human Oversight Actually Means in Practice

  • Human oversight in AI-enabled pharmacovigilance is not a single concept. It is best understood through three distinct forms of human involvement, each serving a different control purpose

1. Human-in-the-Loop (HITL):

A qualified human reviews AI outputs and has the authority to accept, modify, or reject them before they influence decisions.

2. Human-on-the-Loop (HOTL):

Humans supervise system performance over time, monitor outputs and trends, and intervene when predefined thresholds or anomalies are detected.

3. Human-in-Command (HIC):

Humans retain authority to decide whether, when, and how an AI system is used, including the ability to limit, suspend, or discontinue its use.

  •  These are not interchangeable labels. They represent different oversight mechanisms with different implications for risk control and accountability.
  • Human-in-the-loop is most appropriate where incorrect outputs could directly affect regulatory reporting, safety assessment, or patient protection. The defining feature is not the presence of a human, but the requirement that human judgement actively determines the outcome before decisions are finalized.
  • Human-on-the-loop applies where AI systems operate with a lower level of immediate decision impact. In this model, humans do not intervene in every individual output but remain
    responsible for supervising performance, detecting drift, and escalating issues when behaviour deviates from expectations. This form of oversight is only effective when monitoring is robust
    and escalation pathways are clear.
  • Human-in-command underpins all other forms of oversight. It establishes that responsibility for AI use sits with the organization, not the system. This includes decisions about scope of use,
    acceptable risk, and when continued operation is no longer justified. Without this authority, other oversight mechanisms lack enforceability.
  • Selecting the appropriate form of oversight depends on how much influence the AI system has on pharmacovigilance decisions and the consequences of error. Choosing an oversight model that is misaligned with actual system impact can create a false sense of control while leaving material risks unmanaged.
  • For Heads of Safety, the key question is not whether one of these oversight models exists, but whether the chosen model is appropriate for the use case and defensible given its impact.

 

Black Swan” Events in AI
A “black swan” event refers to a rare and unexpected failure with disproportionately high impact.
In pharmacovigilance, even infrequent AI errors can matter if consequences affect safety or compliance, which is why average performance metrics alone are insufficient

3. Matching Oversight Models to Pharmacovigilance Use Cases

  • Selecting an oversight model is not a theoretical exercise. It must be driven by how an AI system is actually used within pharmacovigilance workflows and by the consequences of error if that
    system fails. In practice, many AI-enabled pharmacovigilance activities influence decisions more directly than initially assumed.
  • Case processing is a clear example. AI systems used to extract medical concepts, identify seriousness criteria, or prioritize cases can affect reporting timelines, downstream assessments,
    and escalation decisions. Where such influence exists, human-in-the-loop oversight is typically required, as it ensures that qualified human judgement actively determines outcomes before
    regulatory or safety-relevant decisions are finalized.
  • Other use cases may require a different oversight approach, but only where the impact of error is demonstrably low. Examples may include AI systems used for workload balancing or visualization of trends, where outputs do not directly determine regulatory actions on a case-by-case basis.In these scenarios, human-on-the-loop oversight may be appropriate only where errors do not directly influence regulatory or safety decisions. Even then, this approach is acceptable only if
    system performance is continuously monitored, deviations are readily detectable, and clear escalation and intervention mechanisms are in place. The absence of human intervention at the
    level of individual outputs must be explicitly justified through risk assessment and supported by strong supervisory controls.
  • Across all use cases, human-in-command oversight remains non-negotiable. The organisation must retain authority over whether an AI system is used at all, under what conditions, and with
    what limitations. This includes decisions to restrict scope, pause operation, or discontinue use when risks outweigh benefits. Human-in-command establishes accountability at the organisational level and ensures that oversight is enforceable rather than symbolic.
  • A common failure is selecting an oversight model based on intended use rather than actual operational behaviour. Outputs that are reused downstream, inform prioritisation, or influence
    multiple steps in the workflow can elevate risk over time. Oversight models must therefore be revisited as workflows evolve and reliance on AI increases.
  • For Heads of Safety, the key principle is alignment. Oversight must match real system influence, not convenience or vendor positioning. When oversight models are proportionate to impact,
    they function as genuine controls. When they are not, they create a false sense of security.

4. Why Human Review Alone Is Not Sufficient

  • Including a human review step in an AI-enabled workflow does not, by itself, ensure effective oversight. In practice, human review can fail to mitigate risk if it is not deliberately designed to
    counter known behavioural effects associated with automated systems.
  • One of the most significant risks is automation bias. When AI systems perform well most of the time, reviewers may unconsciously defer to their outputs, even when information is incomplete, ambiguous, or inconsistent. Over time, this deference can reduce critical scrutiny and lead to missed errors, particularly in high-volume environments where efficiency pressures exist.
  • This risk is not eliminated simply by requiring a human to “check” outputs. If the reviewer’s role is limited to confirmation, lacks clear authority to challenge results, or is constrained by time or tooling, the presence of human review provides little additional protection. In such cases, human involvement can create the appearance of control without materially changing outcomes.

 

Human vs Machine Roles

Machines should perform tasks they can execute reliably and at scale.
Humans should retain tasks requiring judgement, context, and accountability.

 

  • Effective oversight therefore requires more than procedural review. It requires clarity on what the human reviewer is expected to evaluate, when escalation is required, and how
    disagreement with AI outputs is resolved. Reviewers must be supported with appropriate training, decision authority, and system transparency to enable meaningful intervention.
  • For pharmacovigilance organisations, this has a practical implication. Oversight models must be designed with an understanding of how humans actually interact with AI systems in real
    workflows. Controls that do not account for automation bias risk becoming ineffective over time, even if they appear robust on paper.
  • Human oversight is intended to reduce risk, not to legitimise automation. Where human review is treated as a formality rather than an active control, it fails to serve its purpose and can leave
    critical risks unmanaged.

5. Leadership Accountability and Lifecycle Oversight

  • Effective human oversight of AI-enabled pharmacovigilance systems cannot be delegated solely to technical teams or embedded within operational procedures. Decisions about how AI is used, controlled, and monitored are leadership responsibilities.
  • Senior pharmacovigilance leadership must understand how AI systems are deployed in practice, how their outputs influence decisions, and where errors could have impact. Reliance on vendor descriptions, average performance metrics, or intended-use statements is insufficient if they do not reflect actual workflow behaviour and decision influence.
  • Oversight is not a one-time design decision. AI systems evolve, workflows change, and reliance can increase gradually over time. As systems become more embedded, their influence on safety
    and regulatory outcomes may expand beyond the original scope. Leadership oversight must therefore extend across the full lifecycle of AI use, from initial risk assessment and deployment
    through ongoing monitoring, change management, and, where necessary, decommissioning.
  • This lifecycle perspective also applies to human oversight models. A model that is appropriate at introduction may become insufficient as system performance improves, volumes increase, or
    outputs are reused downstream. Regular reassessment is required to ensure that oversight remains proportionate to actual risk and influence.
  • Accountability for AI use in pharmacovigilance ultimately rests with the organisation. Human-in-
    command oversight ensures that responsibility for risk acceptance, escalation, and continued use remains clearly assigned and enforceable. Without this, other oversight mechanisms lack
    authority and effectiveness.
  • For Heads of Safety, the implication is clear. AI does not reduce responsibility by automating tasks. As its role within pharmacovigilance systems expands, leadership accountability becomes
    more concentrated, not less.

Deploying an Inspection Ready AI System in PV

Artificial intelligence in pharmacovigilance should not be assessed by how advanced the technology is. It should be assessed by what happens when the technology is wrong.

Executive Summary

  • Artificial intelligence is increasingly being applied across pharmacovigilance activities, particularly in case processing, triage, and assessment. While these technologies are often introduced to improve efficiency and scalability, their use raises important questions about risk, oversight, and accountability.
  • In a GxP-regulated environment, AI systems used in pharmacovigilance must meet regulatory expectations for risk management, oversight, and accountability.
  • It is important to develop a risk-based perspective on the use of artificial intelligence in pharmacovigilance. AI systems should not be evaluated as standalone productivity tools, but as components of the pharmacovigilance system whose outputs can materially influence regulatory decisions and patient safety outcomes.
  • Risk in AI-enabled pharmacovigilance is defined not by algorithmic complexity, but by two factors:
  • Degree to which AI outputs influence decisions &
  • Consequences of incorrect outputs.

Even technically simple systems may represent high risk when their outputs affect reporting obligations, safety assessments, or downstream signal detection activities.

  • We should understand the known and foreseeable failure modes, including false negatives, automation bias, and the compounding effect of downstream reuse of AI outputs. It is important to know why human oversight must be deliberate and proportionate to risk, and why human-in-the-loop models alone are insufficient without clear accountability and safeguards against over-reliance.
  • Finally, emphasis should be placed on the role of safety leadership. Classification of AI risk, design of oversight models, and continuous monitoring are leadership responsibilities that cannot be delegated to technology providers or implementation teams. As AI systems become more influential within pharmacovigilance workflows, accountability becomes more concentrated, not diluted.

Organizations should consider applying a structured, inspection-ready approach to AI in pharmacovigilance, grounded in risk awareness, transparency, and patient safety.

Why AI in Pharmacovigilance Must Be Treated as a Risk-Based System

  • Artificial intelligence in pharmacovigilance should not be assessed by how advanced the technology is. It should be assessed by what happens when the technology is wrong.
  • This is a deliberate position. AI used in pharmacovigilance must be evaluated primarily through the lens of risk, not innovation.
  • Risk is driven by two factors:

1.Consequence of an incorrect output &

2.Degree to which the AI system influences pharmacovigilance decisions.

Sophistication or novelty does not reduce risk. Influence and impact define it.

  • This framing matters for Heads of Safety. An AI system used for case processing, triage, or assessment is not evaluated as a productivity enhancement. It is evaluated as part of the pharmacovigilance system itself, with direct implications for patient safety, regulatory compliance, and organisational accountability.
  • Risk assessment is therefore not a one-time exercise performed at deployment.

It must be applied throughout the lifecycle of AI use.

  • This is why AI in pharmacovigilance must be treated as a risk-based system, not a tool.

How Risk Is Defined in AI-Enabled Pharmacovigilance

  • Risk in AI-enabled pharmacovigilance is not determined by how complex the technology appears to be. It is determined by how much influence the AI system has on decisions and the consequence of an incorrect decision.
  • This distinction is critical. An AI system performing a technically simple task can represent high risk if its output directly affects regulatory reporting, medical judgement, or patient safety. Conversely, a technically complex system may present lower risk if its outputs are clearly limited, well understood, and subject to effective human control.
  • Risk increases as AI systems move closer to stand-alone operation. When outputs are consumed without meaningful challenge, or when they materially shape decisions without sufficient human intervention, the potential impact of error increases.

In pharmacovigilance, even small errors can alter the understanding of a medicine’s benefit-risk profile.

  • Risk is also contextual. The same AI capability can fall into different risk categories depending on how and where it is used. An extraction model supporting case intake may be lower risk when outputs are fully reviewed, but higher risk when those outputs are reused downstream to drive assessments or reporting decisions.
  • For Heads of Safety, this means risk classification is not a technical exercise delegated to vendors or data scientists. It is a business and safety decision that must consider real workflow influence, error detection mechanisms, and actual reliance on the system in practice. This understanding underpins expectations for oversight, monitoring, documentation, and governance.

Explicit Risks That Must Be Anticipated

  • The risks associated with AI in pharmacovigilance are not theoretical. Specific failure modes are well understood and particularly relevant to safety-critical activities.

One of the most significant risks is false negatives. AI systems may fail to identify relevant adverse events, seriousness criteria, or safety signals, even when overall performance metrics appear acceptable. In pharmacovigilance, these failures are not benign. Missed information can delay reporting, distort safety assessments, and undermine patient protection.

  • Automation bias represents another important risk. When AI systems are perceived as reliable, human reviewers may place undue trust in their outputs. This can lead to reduced vigilance, insufficient challenge, and a gradual erosion of critical review. Human review alone does not eliminate this risk. Without deliberate safeguards, human involvement can become procedural rather than protective.
  • A further risk arises from downstream reuse of AI outputs. Information generated early in the workflow is often reused in later steps such as assessment, aggregation, or signal detection. As outputs travel further through the pharmacovigilance process, their influence increases and errors can compound, even if the original use case appeared limited.
  • These risks increase whenever AI outputs influence regulatory or clinical judgement. High average accuracy or good intentions are not sufficient safeguards. Known failure modes must be anticipated and actively mitigated.
  • For Heads of Safety, the implication is clear. These risks are foreseeable. Failure to address them cannot be justified as unexpected system behaviour.

What This Means for Case Processing and PV Use Cases

  • Many AI use cases in pharmacovigilance are introduced as operational support. In practice, their influence often extends far beyond clerical assistance. Case processing is a clear example. AI systems used to extract medical concepts, identify seriousness criteria, or prioritise cases directly influence regulatory timelines and downstream safety evaluation. Even when described as assistive, these outputs frequently shape what is reviewed, what is escalated, and what is ultimately reported.
  • Errors in these contexts may be infrequent but consequential. A missed hospitalization, a misinterpreted narrative, or an overlooked adverse event may not significantly affect aggregate metrics, but it can materially affect patient protection and compliance.
  • Another compounding factor is downstream reuse. Risk accumulates not because the algorithm changes, but because its outputs travel further through the pharmacovigilance process.
  • As a result, many AI-supported case processing activities sit higher on the risk spectrum than initially assumed. Classification cannot be based on convenience.

It must be based on influence and consequence.

Human-in-the-Loop and Proportionate Oversight

  • Human oversight is not symbolic review. It is an active control designed to mitigate known risks.
  • One important oversight model is human-in-the-loop. In this approach, AI outputs are reviewed and either accepted, modified, or rejected by a qualified human before they influence decisions.
  • Human review alone, however, does not guarantee accuracy. Automation bias can undermine oversight when reviewers unconsciously defer to AI outputs. Without deliberate safeguards, human-in-the-loop can degrade into human-on-paper.

Oversight must therefore be proportionate to risk. As AI influence increases, so must the clarity of reviewer responsibility, the depth of review, and the supporting quality controls. Oversight models must account for human behaviour, not just system performance.

What This Means for Safety Leadership and Accountability

  • Risk classification of AI use in pharmacovigilance is not a technical decision. It is a leadership responsibility.
  • Safety leadership must understand how AI systems are actually used, how outputs influence decisions, and where errors could have impact. Vendor descriptions, average accuracy, or intended use statements are insufficient if they do not reflect real operational behaviour.
  • Risk assessment is not static. AI systems evolve, workflows change, and reliance can increase over time. Continuous review, monitoring, and escalation mechanisms are therefore essential.
  • This is why expectations around human oversight, performance monitoring, and governance exist. They are not generic best practices. They are responses to known and foreseeable risks.
  • AI does not dilute accountability. It concentrates it.

Artificial intelligence will increasingly shape pharmacovigilance activities. The risks are not hypothetical, and ignoring them is not an option.

 

In subsequent posts, we will explore how these risks can be mitigated in practice, including the role of human-in-the-loop oversight, monitoring, and governance.

Is it Drug Induced Liver Injury (DILI), or something else?

Ever faced a hepatic signal in a trial that looked like classic drug-induced liver injury (DILI), but turned out to be something entirely different?

Here’s a hypothetical scenario that might resonate, where hepatic physiology,
herbal pharmacology, and cultural practices intersected to produce a pseudosignal that mimicked hepatotoxicity.

A Complex Signal in an Early Phase Trial

During an early Phase trial of a novel drug, one site reported liver enzyme elevations in three participants from the high-dose cohort:

  • ALT 2–3 × ULN
  • Bilirubin: mildly elevated (1.2 × ULN) in one case
  • No clinical symptoms, no jaundice, fatigue, or right upper quadrant pain.

It looked like hepatocellular injury, potentially qualifying as a Hy’s Law signal. But something didn’t add up.

The Hidden Variable: Herbal Co-Exposure

Upon deeper review of case narratives and follow-up interviews, the medical monitor discovered that the participants had been consuming traditional herbal decoctions:

  • Andrographis paniculata
  • Phyllanthus amarus

These were considered “health tonics” in the local culture and were not disclosed during standard medication history. Their omission was unintentional, these herbs were simply part of daily life.

Why Would These Matter?

Both herbs are pharmacologically active:

  • Andrographolide, the key compound in Andrographis paniculata, is a known CYP3A4 inhibitor
  • Phyllanthin and hypophyllanthin, from Phyllanthus amarus, inhibit CYP3A4, CYP2C9, and potentially conjugation enzymes like UGT

The mechanism likely involved:

  • CYP enzyme inhibition
  • Impaired clearance of the parent drug
  • Accumulation of reactive intermediates
  • Oxidative and mitochondrial stress in hepatocytes
  • ALT/AST leakage

This wasn’t classic immune-mediated DILI, it was a pharmacokinetically driven pseudo-DILI, shaped by metabolic interference from herbal products.

Pharmacological Evidence (CYP Modulation) Andrographis paniculata

  • Primary active compound: Andrographolide

Pharmacological Evidence (CYP Modulation) Andrographis paniculata

  • Mechanism: Inhibits CYP3A4 activity (in vitro studies)

Reference:
Elza Sundhani, Endang Lukitaningsih, Arief Nurrochmad, Agung Endro Nugroho. Potential pharmacokinetic and pharmacodynamic herb-drug interactions of Andrographis paniculata (Burm. f.) and andrographolide:
A systematic review.

Phyllanthus amarus

  • Active compounds: Phyllanthin, hypophyllanthin
  • Mechanism: Inhibits CYP3A4 and CYP2C9

Reference:
Taesotikul T, Dumrongsakulchai W, Wattanachai N, Navinpipat V, Somanabandhu A, Tassaneeyakul W, Tassaneeyakul W. Inhibitory effects of Phyllanthus amarus and its major lignans on human microsomal cytochrome P450 activities: evidence for CYP3A4 mechanism-based inhibition. Drug Metab Pharmacokinet. 2011;26(2):154-61. doi: 10.2133/dmpk.dmpk-10-rg-107. Epub 2010 Dec 17. PMID: 21178301.

Medical Monitoring Strategy

Once the pattern became clear, the safety team responded rapidly and decisively:
Pharmacokinetic (PK) Substudy
Goal: Determine if herbal co-use altered systemic exposure and metabolite profiles

  • Used stored plasma samples
  • Compared AUC, Cmax, and metabolite-to-parent ratios between herbalexposed vs. unexposed participants
  • Analysis conducted using non-compartmental modeling

Key Results:

  • Significant increase in AUC of parent compound in herbal users
  • Strikingly higher metabolite-to-parent ratio
  • Modestly extended half-life

Conclusion: Exposure was exaggerated due to impaired metabolism, likely contributing to hepatic stress, but not direct hepatotoxicity.

In Vitro Microsome Assay
Goal: Test direct inhibition of hepatic CYP enzymes by the herbal extracts

  • Human liver microsomes used (pooled donor panels)
  • Co-incubated with midazolam and diclofenac to probe CYP3A4 and 2C9 activity
  • Enzyme kinetics analyzed via LC-MS/MS

Key Results:

  • Andrographis extract inhibited CYP3A4 activity
  • Phyllanthus extract inhibited both CYP3A4 and CYP2C9
  • No CYP induction observed in PXR-based reporter assays

Outcome and Protocol Response

Following the findings:

  • Dose escalation was paused temporarily
  • CRF and ICF were updated to include herbal/traditional supplement disclosure
  • A 14-day washout period was implemented for known hepatic modulators
  • ALT/AST/bilirubin monitoring was intensified on Days 4, 7, 10, and 14

After herbal intake was discontinued, enzyme levels normalized within 10 days. No further cases were reported. The trial resumed with stronger hepatic safety controls in place.

Still Reflecting….

Even now, this scenario raises important questions:

  • Are we doing enough to proactively uncover culturally “invisible” exposures in global trials?
  • Are PK/PD insights being used early enough to differentiate real signals from pseudo-DILI?
  • Are we integrating hepatic physiology, enzyme modulation, and cultural pharmacology into our signal detection framework?

This wasn’t just a pharmacovigilance issue. It was a clinical, cultural, and mechanistic puzzle; one that we solved by looking beyond lab values.

Let’s Keep the Conversation Going!

  • Have you managed hepatic safety signals that turned out to be driven by cultural or dietary confounders?
  • How do you screen for herb-drug interactions in early-phase settings?
  • Let’s share ideas — because the more perspectives we hear, the better we can safeguard participants and protect the integrity of our science.

Medication Errors & Patient Safety – Part I

Why Medication Errors Matter More Than We Think

Medication errors are a significant public health concern, often occurring during various stages of care, whether preventive, diagnostic, therapeutic, or rehabilitative. These errors not only affect patient outcomes but also highlight critical gaps in the safe use of medicinal products. There is a growing need to strengthen risk mitigation strategies and enhance prevention efforts through existing regulatory mechanisms. Beyond the clinical impact, medication-related harm also places a substantial financial burden on healthcare systems globally, with associated costs estimated at around US $42 billion each year. Medication errors are unintended mistakes that can happen at any stage ofthe medication process, whether it’s during prescribing, storing, dispensing, preparation, or administration. When such errors occur repeatedly, follow a recognizable pattern, or lead to serious patient harm, it becomes critical to investigate the root causes and contributing factors. Understanding the clinical impact of these incidents, along with identifying practical solutions and preventive strategies, is key to ensuring they do notrecur.

Stages of Medication Use Process

  1. Storage
  2. Prescribing Stage
  3. Transcribing Stage
  4. Preparation Stage
  5. Dispensing Stage
  6. Administation Stage
  7. Monitoring Stage

What is a Medication Error?

A medication error is an unintended failure in the drug treatment process that leads to, or has the potential to lead to, harm to the patient.

Adverse Event:
GVP Annex I (Rev 3) defines an adverse event as any untoward medical occurrence in a patient or clinical trial subject administered a medicinal product and which does not necessarily have a causal relationship with this treatment. An adverse event can therefore be any unfavorable and unintended sign (including an abnormal laboratory finding, for example), symptom, or disease temporally associated with the use of a medicinal product, whether or not considered related to the medicinal product. Medication related adverse events should be distinguished from other adverse events (e.g. fall, surgery on wrong body site etc.).

Adverse Reaction:

An adverse reaction (ADR) is a response to a medicinal product which is noxious and unintended (Directive 2001/83/EC, Article 1 (11)). This includes adverse reactions which arise from:

  • the use of a medicinal product within the terms of the marketing authorization.
  • the use outside the terms of the marketing authorization, including overdose, off label use, misuse, abuse and medication errors;
  • occupational exposure.

Patient Safety Incident

WHO’s Conceptual Framework for International Classification for Patient Safety (WHO ICPS) defines a patient safety incident as an event or circumstance that could have resulted, or did result, in unnecessary harm to a patient. The scope of patient safety incidents covers the entire health care process whereas the scope of (suspected) adverse reactions in pharmacovigilance is limited to the use of medicines by a consumer or healthcare professional. Patient safety incidents may occur in hospitals or other health care communities and may or may not involve a medicinal product.

Correlation Among Medication Errors, Preventable and Non-Preventable Adverse Reactions, and Intercepted Errors

The diagram is provided for illustrative purposes only to support understanding of medication errors in the context of patient safety, and is not intended to inform or replace pharmacovigilance reporting obligations.

Ref: European Medicines Agency Good practice guide on recording, coding, reporting and assessment of medication errors. EMA/762563/2014

 

Ref: Contemporary View of Medication–Related Harm. A New Paradigm. NCC MERP and Medication Errors. www.nccmerp.org

Classification of Medication Errors Reports

To support effective recording, coding, reporting, and assessment, medication errors should be classified based on factual information specific to each case.
Itis important to clearly distinguish between:

  • Medication errors associated with adverse reaction(s)
  • Medication errors without harm
  • Intercepted medication errors
  • Potential medication errors

The classification depends on where the break occurs in the sequence of events leading to the error and the resulting consequences forthe patient, as illustrated below:

Ref: European Medicines Agency Good practice guide on recording, coding, reporting and assessment of medication errors. EMA/762563/2014

 

Intercepted Medication errors (Near Miss)
An intercepted error indicates that an intervention caused a break in the chain of events in the treatment process before reaching the patient which would have resulted in a ‘potential’ ADR. The intervention has prevented actual harm being caused to the patient. A near miss from a patient safety perspective is a random break in the chain of events leading up to a potential adverse event which has prevented injury, damage, illness or harm, but the potential for harm was nonetheless very near.
Example: A wrongly prepared medicine is intercepted by a nurse before being administered.

 

Potential medication errors
The recognition of circumstances that could lead to a medication error, and may or may not involve a patient. Refers to all possible mistakes in the prescribing, storing, dispensing, preparation for administration or administration of a medicinal product by all persons who are involved in the medication process and may lead to: a) medication error with harm, but without knowing the actual cause, b) medication error without harm and without knowing the actual cause, or c) medication error without harm, but with the awareness ofthe actual cause.
Example: Pharmacist noticed that the names of two medicines are similar and could clearly lead to product name confusion in practice, but no patient was actually involved or has taken the medicine.(Scenario c)

 

Medication Errors with Harm (Adverse Reactions)Medication errors that result in harm to the patient, specifically those associated with one or more adverse reactions. These cases also involve preventability.
Example: A patient receives an incorrect dose leading to hypotension and hospitalization.

 

Medication Errors without harm

NCC MERP Index for Categorizing Medication Errors

Ref:©2025 National Coordinating Council for Medication Error Reporting and Prevention. All Rights Reserved. *Permission is here by granted to reproduce information contained here in provided that such reproduction shall not modify the text and shall include the copyright notice appearing on the pages from which it was copied.
This copyright statement will change to the new year after the 1st of every year

Postmarketing Adverse Drug Experience (PADE) Inspections – Part IV

Legal Framework of PADE Inspections

Good Corrective Action Plan – Four Reasons to Submit a Complete and Timely

Written Response

  1. May be considered in an FDA compliance decision.
  2. Demonstrates your acknowledgment and understanding of the observations to the FDA
  3. Demonstrates your commitment to correct the observations to the FDA
  4. Establishes credibility with the FDA

Points to Consider for Written Responses to the FDA

(SUBMIT THE REPORT WITHIN 15 WORKING DAYS)

Inspection Reporting: FORM FDA 483, Inspectional Observations

Inspection Classifications

No Actions Indicated

(NAI)

Voluntary Action Indicated (VAI) Official Action Indicated (OAI)
No Objectionable conditions

or practices were found

during an inspection (or the

objectionable conditions

found do not justify further

regulatory action).

 

Objectionable conditions or practices were found, but do not rise to the level warranting OAI classification. Objectionable conditions or practices were found, whose scope, severity, or pattern warrants the recommendation for a regulatory action.

a) Warning Letters

The issuance of a Warning Letter (WL) may be warranted when the inspection uncovers significant objectionable conditions related to noncompliance with PADE requirements. The CDER PVC Team and OSI management will evaluate all inspections classified as OAI by OBIMO on a case-by-case basis.

b) Untitled Letters

An Untitled Letter (UL) may be warranted when the deficiencies found at the firm are severe enough to justify a formal letter to the firm, but do not meet the threshold of regulatory significance for a WL.

Factors that influence the issuance of a WL or UL include the nature and extent of the violations (for example, if they are repeated or deliberate), the compliance history of the inspected firm, and the corrective actions implemented by the firm.

c) Enforcement Actions

  1. Injunction: Injunction should be considered when follow-up inspection(s) show that the firm has a continuing pattern of significant and substantial deviations, despite previous attempts by FDA to obtain compliance. 1.
  2. Seizure: Seizure for failure to comply with post marketing adverse drug experience reporting regulations would be possible only if the approval of the application for the product has first been withdrawn (FD&C Act, section 304(a)(1)). Seizure would then be based on distribution of an unapproved drug product. 2.
  3. Prosecution: Evidence that a firm is submitting false information, not submitting required reports for serious post marketing adverse events, or withholding important information, the submission of which may have resulted in the Agency requiring labelling changes or withdrawing an application, should be referred to the Office of Criminal Investigations (OCI) for consideration of prosecution.

 

Post marketing Adverse Drug Experience (PADE) Inspections – Part III

Legal Framework of PADE Inspections

Scientific Literature Reports

Determine:

  • If the firm reviews scientific literature and the frequency of the review.
  • If the applicant or non-applicant is submitting expedited ICSRs for adverse experiences obtained from the published scientific and medical literature that are both serious and unexpected.
  • If the applicant or non-applicant is submitting a copy of the published article as an ICSR attachment for each expedited ICSR of an adverse experience obtained from the published scientific and medical literature. Foreign language articles should be accompanied by an English translation of the abstract.

Foreign Postmarketing Adverse Experience Reporting

Determine:

  • If written procedures address the surveillance, receipt, evaluation, and reporting of adverse experiences from affiliates, subsidiaries, contractors, and business partners outside the United States.
  • If serious and unlabelled (i.e., unexpected) adverse experiences from foreign sources have been submitted to FDA within 15 calendar day.

Solicited Safety Data

Determine:

  • How the firm identifies and monitors all sources of solicited safety information including, but not limited to, post marketing studies, nonapplicant-sponsored clinical data obtained by the firm, and patient engagement programs, to ensure that the firm’s pharmacovigilance personnel receive all potential adverse experiences. The identification and monitoring of solicited safety data should be addressed in the firm’s written procedures.
  • If the firm is monitoring its firm-sponsored internet and social media sites, and the frequency of the monitoring.
  • If solicited safety data has been assessed for seriousness, unexpectedness, and causality.
  • If solicited safety data that has been assessed as serious, unexpected, and possibly related to the suspect product has been submitted to FDA within 15 days of receipt of the information.
  • During inspection, auditor may select several Annual Reports and confirm that the status of the firm’s post marketing studies is included in the reports.

Aggregate Safety Reports:

The reporting interval is quarterly for the first three years following the approval of the application or license, and annually thereafter, unless FDA instructs the Firm otherwise.

Determine:

  • If the PADER or PAER contains all the required content as described in 21 CFR 314.80(c)(2) or 21 CFR 600.80(c)(2), respectively.
  • If the PADER or PAER has been submitted within the required regulatory timelines.
  • Several Annual Reports may be selected to confirm that the status of the firm’s post marketing studies is included in the reports, as required by 21 CFR 314.81.
  • All reports must be submitted in electronic format, as described in 21 CFR 314.80(g) and 21 CFR 600.80(h).

Contractor Oversight

  • Oversight of outsourced services may include a broad range of activities to ensure that all outsourced services and activities associated with post marketing safety are performed according to applicable FDA regulations.
  • Identify the name, business location, and contact information for any contractor involved in the surveillance, receipt, evaluation, or reporting of adverse experiences to FDA, including all domestic and foreign locations where safety information is processed.
  • If the applicant or non-applicant has written procedures for obtaining and processing safety information from its contractors.
  • Assess how the applicant or non-applicant ensures that its contractors develop written procedures.
  • Determine the contractor’s specific responsibilities. Determine how the applicant or non-applicant ensures that its contractors fulfil their responsibilities. Applicants or non-applicants may outsource some or all of their post marketing safety obligations, but remain responsible for complete, accurate, and timely reporting to FDA.
  • Determine how the contractor documents its receipt date for obtaining the minimum dataset for a valid ICSR and how it communicates this information to the applicant or non-applicant. The clock for expedited reporting starts as soon as the minimum information for a valid ICSR has been received by the contractor or its representatives.

Electronic Submissions

  • Determine if safety report submissions are in an electronic format that FDA can process, review, and archive, as required.
  • Review system-generated delivery confirmation notices from either the Electronic Submission Gateway (ESG) or the Safety Reporting Portal (SRP) and determine if the firm has a procedure for correcting and resubmitting any submission for which the message delivery notice (MDN) indicated that the submission was not accepted.
  • Determine if the firm has a corrective action for each late submission to the Agency, according to the MDN
  • Determine if MDNs are being retained.

Waivers & Record Keeping

  • A copy of the waiver for any regulatory requirement pertaining to post marketing safety, may be requested to determine compliance with the terms of the waiver.
  • For approved drugs or biologics, if all records containing information relating post marketing safety reports (whether or not submitted to FDA) have been maintained for a period of 10 years, or for combination products, the longest retention period applicable.
  • Anyone marketing a prescription drug for human use without an approved new drug application or abbreviated new drug application must comply with the recordkeeping and reporting requirements of 21 CFR 310.305.

Postmarketing Adverse Drug Experience (PADE) Inspections – Part II

Legal Framework of PADE Inspections

  1. LAW: Federal Food, Drug and Cosmetic Act (FDCA)
  2. Title 21 of the Code of Federal Regulations (CFR)
  3. FDA’s Current Thinking

Inspectional Observations: USFDA 2023

1 21 CFR 314.80(b) Failure to develop written procedures Written procedures have not been developed for the [surveillance] [receipt] [evaluation] [reporting to FDA] of post marketing adverse drug experiences.
2 21 CFR 314.81(b)(1)(ii) Failure to meet specifications An NDA-Field Alert Report was not submitted within three working days of receipt of information concerning a failure of one or more distributed batches of a drug to meet the specifications established for it in the application.
3 21 CFR 314.80(c)(1)(i) Late submission of 15-day report. Not all adverse drug experiences that are both serious and unexpected have been reported to FDA within 15 calendar days of initial receipt of the information.
4 21 CFR 314.80(c)(1)(ii) Failure to investigate serious, unexpected events Adverse drug experiences that were the subject of post marketing 15-day reports were not [promptly] investigated.
5 21 CFR 314.80(c)(2) Late submission of annual safety reports Not all annual periodic adverse drug experience reports have been submitted within 60 days of the anniversary date of the approval of the application.
6 21 CFR 314.80(c)(2)(ii)(A) Incomplete periodic safety report Failed to submit a periodic report containing

  • [a narrative summary and analysis of the ADE information for the reporting interval in the report.]
  • [an analysis of the post marketing 15-day Alert reports submitted during the reporting interval.]
  • [a history of actions taken since the last report because of adverse drug experiences.]
  • [an index with a line listing of your patient identification code and adverse reaction term(s) for all ICSRs you submitted for the reporting interval.]
7 21 CFR 314.80(d) Failure to submit scientific article A postmarketing 15-day Alert report based upon scientific literature was not accompanied by a copy of the published article.
8 21 CFR 314.80(j) Failure to maintain records Failed to maintain for a period of 10 years records of all adverse drug experiences known to you, including raw data and any correspondence.
9 21 CFR 314.81(b)(2) Timely submission An annual report was not submitted [each year] [within 60 days of the anniversary date of U.S. approval of the application] to the FDA division responsible for reviewing the application.

Ref: Number of 483 issued from the System*

Inspections ending between 10/1/2022 and 9/30/2023
https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/inspection-references/inspection-observations

Written Procedures Must Address

  1. Surveillance
    • Account for all sources
    • Spontaneous
    • Solicited
    • Internet sources (firm sponsored)
    • Literature …and more!
  2. Receipt
    • ADE info
    • Initial
    • Follow-up
    • Receipt from any source
  3. Evaluation
    • Seriousness
    • Expectedness
    • Relatedness
    • ADEs from any source
    • Follow-up procedures
  4. Reporting
    • 15-day Alert Reports
    • Non-expedited individual case safety reports (ICSRs)
    • Aggregate Reports
    • All info must be submitted electronically

Ref: Postmarketing Drug Safety and Inspection Readiness June 19, 2018. Center for Drug Evaluation and Research (CDER) Small Business and Industry Assistance (SBIA) Webinar. USFDA

Written Procedures

  1. Develop written procedures for the surveillance, receipt, evaluation, and
    reporting of postmarketing safety information, including procedures for
    managing safety information with contractors and business partners, as
    applicable.
  2. Written procedures should be maintained and followed.
  3. Determine if written procedures provide for complete, accurate, and timely reporting of safety data to FDA.
  4. Regulations pertaining to the requirements for written procedures: 21 CFR 4 310.305(a), 21 CFR 314.80(b), and 21 CFR 600.80(b).

Surveillance

  • Determine if the firm is monitoring potential sources of adverse event information
  • Determine if the firm is surveilling both foreign and domestic sources.
  • Determine if the firm is promptly reviewing all postmarketing safety information received from any source


Many other sources such as firm-sponsored websites, firmsponsored social media, legal cases, product complaint files etc.

  • The timeline for submission of adverse experiences to FDA begins the day that the applicant, nonapplicant, or its contractors or business partners, obtain the minimum data set for a valid adverse event report.
  • The minimum dataset required to consider information reportable is
    • an identifiable patient
    • an identifiable reporter
    • a suspect product and
    • an event.
  • The date of receipt must be accurately determined and documented for the receipt of initial and follow-up information received by any method (for example, by phone, electronic mail, postal mail, fax, literature, websites, or employees).

Evaluation

Determine how:

  • Safety information from any source is evaluated to determine if an adverse experience is present.
  • Adverse experience reports are evaluated to establish if each report is spontaneous or solicited.
  • All adverse experiences, both spontaneous and solicited, are evaluated for seriousness and expectedness.
  • For adverse experiences originating from solicited sources, determine how the causal relationship between the product and the adverse experience is assessed.
  • If adverse experiences that are both serious and unexpected are promptly investigated and if all attempts to obtain additional information are documented.

Reporting

  1. Spontaneous adverse experiences, foreign or domestic, that have been evaluated as both serious and unexpected are submitted to FDA no later than 15 calendar days from the initial receipt of the information.
  2. For solicited adverse experiences, foreign or domestic, determine if all adverse experiences that have been evaluated as serious, unexpected, and possibly related to the suspect product are submitted to FDA no later than 15 calendar days from initial receipt of the information.
  3. Review 15-day Alert reports submitted late to the Agency.
  4. For each late report, the firm should provide justification for why the reports were late and appropriate corrective actions, if applicable.
  5. Domestic spontaneously reported non-expedited ICSRs are being submitted to FDA with or before the Periodic Report.
  6. The firm is in possession of any adverse event data that were not reported to the Agency as required.

Stay tuned for Part III, where we will explore the safety reports.

Postmarketing Adverse Drug Experience (PADE) Inspections – Part I

Legal Framework of PADE Inspections

PADE Statutory Provisions / Regulations: Prescription Drug Products for Human Use

S.no FD&C Act, subchapter V, part A, section 505 (21 U.S.C. 355) Comments
1 21 CFR 310.305 New Drugs: Records and reports concerning adverse drug experiences (ADEs) for marketed prescription drugs for human use without an approved new drug application
2 21 CFR 314.80 New drug applications: Post marketing reporting of ADEs
3 21 CFR 314.81(b)(2) New drug applications: Annual reports
4 21 CFR 314.90 New drug applications: Waivers
5 21 CFR 314.98 Abbreviated applications: Post marketing reports
6 21 CFR 314.540 Accelerated approval of new drugs for serious or life-threatening illnesses: Post marketing safety reporting
7 21 CFR 314.630 Approval of new drugs when human efficacy studies are not ethical or feasible: Post marketing safety reporting
8 21 CFR part 4, subpart B Post marketing safety reporting for combination products

Approval vs. Marketing

Once a drug is approved, applicant holders MUST receive, evaluate, and report adverse drug experiences (ADEs) to FDA, even if the drug is not marketed.

PADE Inspection – Scope

  1. Written procedures
  2. Product list (approval date, status, etc.)
  3. Late or Missing Periodic Reports or Annual Reports
  4. Late, missing, incomplete, or inaccurate 15-day reports
  5. ADEs from all sources
  6. Root cause analyses and corrective actions for deviations
  7. Confirmations for electronic submissions
  8. Training Documents
  9. Safety Contracts, Agreements, and Business Partners
  10. Organization, roles, and responsibilities
  11. Waivers

Who can be inspected for PADE Compliance?

  1. Application holders: 

    Applicants with approved drugs and therapeutic biologics (prescription and non-prescription)

    • New Drug Application (NDA)
    • Abbreviated New Drug Application (ANDA)
    • Biologics License Application (BLA)
  2. Non- Applicants: 

    Manufacturers, packers, distributors, retailers, and certain others named on product labels (responsibilities vary based on product type)

    • Approved prescription and non- prescription drugs and therapeutic biologics (NDA, ANDA, BLA)
    • Unapproved prescription drugs
    • Unapproved non-prescription drugs
  3. Third parties: 

    Contractors, vendors, and other third parties

    • Pharmacovigilance activities conducted on behalf of application holders or non-applicants

Risk Based Selection for PADE Inspection

  1. Inspection History:

    • Compliance and inspection history

      • Never inspected for PADE compliance
      • Inspection findings from other program areas
    • Firm’s written responses to previous PADE inspections
  1. Firm Information:

    • Corporate changes
    • Portfolio (type and number of products)
    • Complaints
    • Internal FDA information
    • Information from other health authorities
  2. Product Portfolio:

    • New molecular entities
    • High-risk
    • Patient exposure
    • Recalls Submissions to FDA
      • Individual Case Safety Reports (ICSRs)
      • Annual reports
      • Periodic report

Hy’s law & Drug Induced Liver Injury – Part II

Drug-Induced Liver Injury Occurrence

  1. Most frequent cause of acute liver failure in North America and Europe.
  2. No definite causative agent has been attributed in several cases.
  3. Underlying mechanisms are still unclear and hence is difficult to predict during drug development.
  4. May mimic almost any known type of liver disease.
  5. Rare yet potentially life-threatening.
  6. Key reason for drugs to fail to achieve marketing authorization, frequent cause for post-authorization restrictions and product withdrawals.
  • Monitoring of standard serum liver tests to detect milder liver injury is the main approach to anticipate a possible DILI risk in Clinical Trials.
  • Evaluation of each potential DILI case in clinical trials requires a systematic collection of adequate diagnostic datasets and a rigorous assessment for causality, performed by clinical experts in this area.
  • The evaluation of DILI is critical because most drugs that cause severe DILI do so infrequently and usual drug development databases with up to a few thousand subjects exposed to a new drug will not reveal any cases.
  • Such databases, on the other hand, may show evidence or signals of a drug’s potential for severe DILI, if clinical and laboratory data are properly assessed for evidence of lesser injury, that may not be severe but could predict the ability to cause more severe injuries.

FDA’ s eDISH Program for Hepatotoxicity Assessment

Hy’s Law and eDISH Development: The Hy’s Law principle served as the foundation for the FDA’s creation of the ‘eDISH’ software program, designed to evaluate Drug-Induced Serious Hepatotoxicity.

Step-Based Approach:

  1. Data from case reports are examined for peak values of liver enzymes ALT and TBL over the observation period. These values are plotted on an x-y chart as logarithm10 multiples of elevations above the upper limits of the normal reference ranges (ULN).
  2. For an individual patient, time course of ALT, TBL, AST, and ALP are plotted together for visual comparison.
  3. A medical text narrative, written by a skilled physician, provides additional context about the patient’s condition. This narrative helps estimate the most likely cause of abnormal findings and assesses the probability of drug-induced hepatotoxicity.

Causality Assessment:

Requires considering of multiple potential factors.

Several possible causes are common and Insufficient to simply label cases as ‘confounded.’

Estimated likelihood is categorized as ‘probable’ if the likelihood is over 50% and higher than all other causes combined.

Sufficient information and thorough patient investigation are essential to rule out alternative causal factors.

Note: The upper right quadrant doesn’t automatically define cases as ‘Hy’s Law’; It identifies patients as of unique importance. Further clinical information is essential for a comprehensive medical diagnosis aimed at identifying the most likely cause of the observed findings.

Approach to the diagnosis of DILI

Conclusion:

  1. DILI is a key concern for regulators, drug developers, and physicians, and is difficult to predict during drug development process.
  2. As severe DILI is generally rare, finding a single case may require treatment of thousands of people from varied patient populations.
  3. The clinical trials present an exclusive opportunity to detect hepatotoxicity and cases of potential DILI with a study drug prior to its use in general population.
  4. Monitoring the liver test abnormalities is useful for assessing trends over time and to analyse imbalance between study drug and placebo/comparator groups.
  5. Due to the limited number of subjects in a clinical trial, monitoring the standard serum liver tests to detect milder liver injury can be considered a predominant approach to predict the risk of possible DILI in clinical trials.
  6. Considering that there may be varied mechanisms of DILI and different clinicopathological phenotypes, a systematic collection of adequate diagnostic datasets along with a focused causality assessment performed by clinical experts is required for evaluation of each potential case of DILI in clinical trials.

Hy’s law & Drug Induced Liver Injury – Part I

Drug-Induced Liver Injury Occurrence

  1. Most frequent cause of acute liver failure in North America and Europe.
  2. No definite causative agent has been attributed in several cases.
  3. Underlying mechanisms are still unclear and hence is difficult to predict during drug development.
  4. May mimic almost any known type of liver disease.
  5. Rare yet potentially life-threatening.
  6. Key reason for drugs to fail to achieve marketing authorization, frequent cause for post-authorization restrictions and product withdrawals.
  • Monitoring of standard serum liver tests to detect milder liver injury is the main approach to anticipate a possible DILI risk in Clinical Trials.
  • Evaluation of each potential DILI case in clinical trials requires a systematic collection of adequate diagnostic datasets and a rigorous assessment for causality, performed by clinical experts in this area.
  • The evaluation of DILI is critical because most drugs that cause severe DILI do so infrequently and usual drug development databases with up to a few thousand subjects exposed to a new drug will not reveal any cases.
  • Such databases, on the other hand, may show evidence or signals of a drug’s potential for severe DILI, if clinical and laboratory data are properly assessed for evidence of lesser injury, that may not be severe but could predict the ability to cause more severe injuries.

Hy’s law

Hy’s Law cases have the following three components:

  • The drug causes hepatocellular injury, generally shown by a higher incidence of 3-fold or greater elevations above the ULN of ALT or AST than the (non-hepatotoxic) control drug or placebo.
  • Among trial subjects showing such AT elevations, often with ATs much greater than 3 x ULN, one or more also show elevation of serum TBL to >2 x ULN, without initial findings of cholestasis (elevated serum ALP).
  • No other reason can be found to explain the combination of increased AT and TBL, such as viral hepatitis A, B, or C; preexisting or acute liver disease; or another drug capable of causing the observed injury.

This observation formed a basis for the development of the e-DISH plot by the U.S. FDA.

Translation of Zimmerman’s observation that pure hepatocellular injury sufficient to cause hyperbilirubinemia is an ominous indicator of the potential for a drug to cause serious liver injury.

Recognition of the importance of altered liver function, in addition to liver injury, began with Zimmerman’s observation that drug-induced hepatocellular injury (i.e., aminotransferase elevation) accompanied by jaundice had a poor prognosis, with a 10 to 50percent mortality from acute liver failure (in pre-transplantation days).

Finding one Hy’s Law case in the clinical trial database is worrisome; finding two is considered highly predictive that the drug has the potential to cause severe DILI when given to a larger population.

USFDA has been using Hy’s law rigorously to screen out potentially hepatotoxic drugs for almost 20years, and “since 1997 did not have to withdraw a single drug approved after 1997 because of post-marketing hepatotoxicity”.

*  1. EASL Clinical Practice Guidelines: Drug-induced liver injury. J Hepatol(2019), https://doi.org/10.1016/j.jhep.2019.02.014

2.EVOLUTION OF THE FOODANDDRUG ADMINISTRATION APPROACH TO LIVER SAFETY ASSESSMENT FOR NEW DRUGS: CURRENT STATUS AND CHALLENGES. JOHN R. SENIOR.DRUG SAF (2014) 37 (SUPPL 1):S9–S17

Any potential Hy’s Law cases should be:

  • Handle das a serious unexpected adverse event associated with the use of the drug.
  • Reported to the FDA/Regulators promptly (i.e., even before all other possible causes of liver injury have been excluded).
  • Reporting should include all available information, especially that needed for evaluating the severity and likelihood that the drug caused the reaction, and, should initiate a close follow-up until complete resolution of the problem and completion of all attempts to obtain supplementary data.

Time Lag:

  • Combined elevation of ALT or AST and TBL may not be concurrent elevation.
  • Typically, ALT or AST elevation are followed by bilirubin elevation (delay of up to 4 weeks).

Time course of elevations – ALP elevations:

  • “Pure” hepatocellular injury initially may show secondary ALP elevations due to intrahepatic cholestasis.
  • Hence, cases with increased ALT or AST and TBL, associated with increased ALP, cannot automatically be discarded as not matching Hy’s law criteria.
  • Additionally, ALP values >2 x ULN were not found to decrease the risk of ALF in patients fulfilling Hy’s law in the Spanish DILI registry.

R Ratio and ALP:

  • Both ALP activity and the R ratio should be considered in the exclusion of cholestatic or mixed type injury.

Direct vs Indirect Bilirubin:

  • Hepatocellular dysfunction is indicated by increased direct, i.e. conjugated bilirubin only.
  • Conditions such as haemolysis, or drug-related enzyme inhibition may lead to increase in indirect, i.e., unconjugated bilirubin.
  • Hence, fractionated bilirubin should be assessed since cases with predominantly unconjugated mild hyperbilirubinemia would not qualify as potential Hy’s law cases.

Conclusion

  1. DILI is a key concern for regulators, drug developers, and physicians, and is difficult to predict during drug development process.
  2. As severe DILI is generally rare, finding a single case may require treatment of thousands of people from varied patient populations.
  3. The clinical trials present an exclusive opportunity to detect hepatotoxicity and cases of potential DILI with a study drug prior to its use in general population.
  4. Monitoring the liver test abnormalities is useful for assessing trends over time and to analyse imbalance between study drug and placebo/comparator groups.
  5. Due to the limited number of subjects in a clinical trial, monitoring the standard serum liver tests to detect milder liver injury can be considered a predominant approach to predict the risk of possible DILI in clinical trials.
  6. Considering that there may be varied mechanisms of DILI and different clinicopathological phenotypes, a systematic collection of adequate diagnostic datasets along with a focused causality assessment performed by clinical experts is required for evaluation of each potential case of DILI in clinical trials.