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Pharmacovigilance Requirements in Canada

In Canada, the pharmacovigilance system is mature, ICH-aligned, and regulated by Health Canada (Marketed Health Products Directorate and Biologic and Radiopharmaceutical Drugs Directorate).

1. Clinical Safety (Clinical Trials)

Clinical trials are governed under Division 5 of the Food and Drug Regulations and require Health Canada approval.

  • Expedited Reporting: Sponsors must report Suspected Unexpected Serious Adverse Drug Reactions (SUSARs):

    • Fatal or Life-Threatening: Initial report within 7 calendar days, followed by a full report within 8 days.

    • Other Serious Unexpected: Within 15 calendar days.

  • Periodic Reporting: Development Safety Update Reports (DSURs) are required annually or upon request.

  • Submission: Direct submission to Health Canada.

2. Post-Marketing Pharmacovigilance

Regulated under Division 1 of the Food and Drug Regulations.

  • Personnel & Infrastructure:

    • No Local QPPV / PSMF: Canada does not mandate an EU-style QPPV or PSMF. MAHs must designate internal responsible personnel for compliance, and foreign MAHs often use a Canadian importer/representative.

  • Incident Reporting (ICSRs):

    • Timelines:

      • Serious Unexpected (Domestic & Foreign): Within 15 calendar days.

      • Non-Serious: Not expedited (captured in periodic reports).

    • Mandatory Hospital Reporting: Hospitals must report serious ADRs and medical device incidents.

  • Risk & Periodic Reporting:

    • PSURs: Required typically every 6 months initially, then annually, or upon Health Canada request.

    • RMPs: Required on a case-by-case basis for high-risk or new products.

Summary of Requirements

Component Requirement in Canada
Regulatory Authority Health Canada
Framework Food & Drugs Act / ICH Aligned
Local QPPV / PSMF Not required (Internal designate used)
Safety Reporting 15 days (Serious Unexpected)
Clinical Reporting SUSARs (7/15 days)
Submission Language English / French

 

 

 

Patient Identifier - Four Minimum Criteria - Canada

One or more of the following should automatically qualify a patient as identifiable: age or age category (e.g., adolescent, adult, elderly), gender, patient identification number, or reference to "a patient".

PSUR or Aggregate Reports in Canada

The manufacturer shall prepare an annual summary report of all information relating to adverse drug reactions and serious adverse drug reactions to the drug that it received or became aware of during the previous 12 months. These are also known as CAR or Canadian Annual Reports.

NOT routinely required to be submitted to Health Canada. However, while preparing the annual summary report, the manufacturer concludes that there has been a significant change, it shall notify the Minister (Health Canada) without delay, in writing, unless this has already been done.

Discontinued Products in Canada - Reporting Requirements

In accordance with the Regulations, the MAH must report any AR information received prior to the discontinuation of the sale in Canada. Although the MAH is not obliged to report any new cases of adverse reactions received following the product's discontinuation, Health Canada strongly encourages the reporting of all serious adverse reactions and may request the provision of this information. If a serious AR was known to the MAH before the discontinuation of sale, they must still report as per the expedited reporting requirements even if the end of the 15-day reporting timeframe as required by the Regulations is after the date on which sales were discontinued. Follow-up information for cases known to the MAH prior to the discontinuation of sale should be reported to MHPD in accordance with the Regulations and should be sought as part of the follow-up practices described under Section 3.4.

When expired and unexpired lots of a discontinued product continue to be available in pharmacies, the MAH is still under obligation to report ARs to MHPD if this information was received by the MAH prior to the discontinuance. As mentioned above, Health Canada may still request the MAH to provide information that it receives following the discontinuation of sales.