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Received: 18 August 2021 Revised: 3 December 2021 Accepted: 15 December 2021

DOI: 10.1111/bcp.15193

THEMED ISSUE REVIEW

Pharmacovigilance in low- and middle-income countries: A


review with particular focus on Africa

Ronald Kiguba1 | Sten Olsson2 | Catriona Waitt3,4

1
Department of Pharmacology and
Therapeutics, Makerere University, Kampala, Low- and middle-income countries (LMIC) face unique challenges with regard to the
Uganda
establishment of robust pharmacovigilance systems capable of generating data to
2
Pharmacovigilance Consulting, Uppsala,
Sweden inform healthcare policy and practice. These include the limited integration and reli-
3
Department of Pharmacology and ability of pharmacovigilance systems across LMIC despite recent efforts to harmonize
Therapeutics, University of Liverpool, UK
pharmacovigilance rules and regulations in several regional economic communities.
4
Infectious Diseases Institute, Makerere
University College of Health Sciences, Uganda
There are particular challenges relating to the need to translate reporting tools into
numerous local languages and the low numbers of healthcare providers relative to
Correspondence
Catriona Waitt, Department of Pharmacology
number of patients, with very short consultation times. Additional factors frequent in
and Therapeutics, University of Liverpool, UK. LMIC include high uptake of herbal and traditional medication, mostly by self-
Email: cwaitt@liverpool.ac.uk
medication; disruptive political conflicts jeopardizing fragile systems; and little or no
access to drug utilization data, which makes it difficult to reliably estimate the true
risks of medicines use. Pharmacovigilance activities are hindered by the scarcity of
well-trained personnel with little or no budgetary support from national govern-
ments; high turnover of pharmacovigilance staff whose training involves a substantial
amount of resources; and little awareness of pharmacovigilance among healthcare
workers, decision makers and consumers. Furthermore, little collaboration between
public health programmes and national medicines regulatory authorities coupled with
limited investment in pharmacovigilance activities, especially during mass drug
administration for neglected tropical diseases and mass vaccinations, produces major
challenges in establishing a culture where pharmacovigilance is systematically
embedded. Very low spontaneous reporting rates with poor quality reports hinders
robust signal detection analyses. This review summarises the specific challenges and
areas of progress in pharmacovigilance in LMIC with special focus on the situation in
Africa.

KEYWORDS
Africa, medicines safety, pharmacovigilance

1 | I N T RO DU CT I O N understanding and prevention of adverse effects or any other possible


drug-related problems”.1 Encompassed within this definition are mul-
The World Health Organization (WHO) defines pharmacovigilance as tiple elements relating to the safety of medication, including the
the “science and activities related to the detection, assessment, reporting of substandard and falsified (SF) medicines, medication

This is an open access article under the terms of the Creative Commons Attribution License, which permits use, distribution and reproduction in any medium,
provided the original work is properly cited.
© 2021 The Authors. British Journal of Clinical Pharmacology published by John Wiley & Sons Ltd on behalf of British Pharmacological Society.

Br J Clin Pharmacol. 2023;89:491–509. wileyonlinelibrary.com/journal/bcp 491


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492 KIGUBA ET AL.

errors, drug abuse and misuse, exposure to drugs during pregnancy 2.2 | Therapeutic ineffectiveness
and breastfeeding, therapeutic ineffectiveness, occupational exposure,
off-label use, ecopharmacovigilance (environmental pollution), medical Therapeutic ineffectiveness or lack of therapeutic effectiveness is not
devices and diagnostics, overdose, and suspected transmission of well-studied in LMIC. In Asia, a recent South Korean study showed
infectious agents via medicines.2 that consumers are more likely than HCWs to report therapeutic
Low- and middle-income countries (LMIC) face specific chal- ineffectiveness.11 As of 2018, Uganda's national pharmacovigilance
lenges with regard to pharmacovigilance. These include the limited database had not yet captured any reports of therapeutic ineffective-
integration of pharmacovigilance systems across LMIC despite recent ness of artemisin-based combination therapies for malaria despite
efforts to harmonize pharmacovigilance rules and regulations in sev- several anecdotal reports by HCPs in that setting.12
eral regional economic communities; the need to translate reporting
tools into numerous local languages; high patient-to-healthcare
worker (HCW) ratio with very short consultation times; scarcity of 2.3 | Pharmacovigilance of antimicrobial resistance
well-trained pharmacovigilance personnel with little or no budgetary
support for these activities from national governments; high turnover Pharmacovigilance databases are a potentially valuable tool for the
of pharmacovigilance staff whose training involves a substantial indirect surveillance of antimicrobial resistance (AMR) in settings with
amount of resources; little awareness of pharmacovigilance among limited capacity for laboratory-based AMR monitoring. Stimulating
HCWs, decision makers and consumers; very low reporting rates the reporting of suspected AMR-related adverse events is a low-cost
with poor quality spontaneous reports, which hinders robust signal approach for generating AMR signals for antimicrobial stewardship
detection analyses; little collaboration between public health programmes in LMIC.13,14
programmes and national medicines regulatory authorities; limited
investment in pharmacovigilance activities especially during mass
drug administration for neglected tropical diseases; high uptake of 2.4 | SF medicines
herbal and traditional medication, mostly by self-medication; regions
with disruptive conflict jeopardizing fragile systems; and little or no A systematic review and meta-analysis of 96 studies on SF medicines
access to drug utilization data, which makes it difficult to reliably in LMIC showed a regional prevalence of 19% in Africa and 14% in
estimate the true safety risks of medicine use.3–7 Consequently, local Asia—the highest estimates of the extent of SF medicines globally—
pharmacovigilance data contributes little to regulatory decisions in with a market size of up to USD 200 billion. Antimalarials (19%) and
most LMIC.7 antibiotics (12%) were the drug categories at highest risk.15 SF anti-
The WHO Programme for International Drug Monitoring (WHO- malarials contributed to the death of up to 150 000 under-5 children
PIDM) was established in 19688; however, pharmacovigilance activi- in 39 SSA countries in 2013.16
ties in LMIC have mostly gathered momentum over the past 20 years. Most safety signals picked up by the East African
In this paper, we review the specific challenges and areas of progress pharmacovigilance systems were related to SF medicines,9 which is
in pharmacovigilance in LMIC with special focus on the situation in not surprising given the known high burden in this region.17 This
Africa. high burden is attributable to weak pharmaceutical governance and
poor/nonexistent medicines regulatory systems.18–20 Africa imports
70% of its medicines, which promotes illicit trade in SF medicines.
2 | S C O P E OF P H A R M A C O V I G I L A N C E The inadequate supply chain management and monitoring of
medicines in LMIC encourages infiltration of these products in the
Despite the breadth of pharmacovigilance activities, supply chain system and, equally, causes drug stock-outs that
pharmacovigilance systems in LMIC primarily focus on adverse drug encourage consumers to buy medicines from unregulated
reaction (ADR)-reporting. However, progress is being made with markets.18
respect to the additional aspects.

3 | RISK MANAGEMENT AND


2.1 | Medication errors EV A L U A T I O N / S I G NA L D E T E C T I O N

A recent case study of pharmacovigilance systems in four East African Pharmacovigilance reports are made using individual case safety
countries showed that medication errors were not well captured in reports (ICSRs). The majority of LMIC manually review each ICSR to
the national pharmacovigilance databases.9 Kiguba and colleagues detect safety signals from the small number of reports in their local
observed that HCWs in Uganda, a country in sub-Saharan Africa databases.21 LMIC can also creatively interrogate other sources of
(SSA), were less likely to disclose medication errors due to fear of safety signals e.g. peer-reviewed journal publications and can pro-
punitive action from the authorities.10 mote quality assurance of their pharmacovigilance data to
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KIGUBA ET AL. 493

strengthen signal detection efforts in their own settings.22 Since 4 | STATUS OF PHARMACOVIGILANCE
1978, the Uppsala Monitoring Centre (UMC; established in Uppsala, S Y S TE M S I N L M I C
Sweden) on behalf of WHO, have been maintaining a global reposi-
tory of ICSRs, VigiBase. A low-cost VigiFlow system, established by 4.1 | Overview of regulatory pharmacovigilance in
UMC, can be used to manage drug safety information at the LMIC
national level and to share the data globally through VigiBase. LMIC
that are members of the WHO-PIDM can utilize VigiLyze to con- The majority of LMIC have nascent or nonexistent regulatory
duct signal detection analyses on national, regional and global safety pharmacovigilance systems that cannot adequately monitor the safety
data in VigiBase, promoting international collaboration.8,23 High- of medicines when compared with the mature pharmacovigilance
income countries (HIC) use a mix of manual and complex statistical infrastructure in HIC.28 To promote best practice in regulatory
tools with programmed criteria applied to very large complex pharmacovigilance the WHO in collaboration with Global Fund
pharmacovigilance databases that outpace human capacity for man- established the minimum specifications for a functional
ual reviews.24 For instance, the US Food and Drug Administration pharmacovigilance system in 2010.29 The WHO Global Benchmarking
and UK Medicines and Healthcare products Regulatory Agency use Tool can be used to monitor the maturity level of national systems; a
Quantitative Signal Detection Algorithms in their pharmacovigilance maturity scale of 1 is the lowest (regulatory system with minimal
systems.25 However, the current version of VigiLyze provides the activity) and 4 is the highest (regulatory system with advanced perfor-
same kind of disproportionality statistical analysis as Quantitative mance).30 These systems can also be evaluated using the
Signal Detection Algorithms and is accessible to all member coun- pharmacovigilance performance indicators.31
23
tries of the WHO-PIDM.
It is noteworthy that methods to enhance signal detection and
interpretation, and the prediction of ADRs at both the individual and 4.2 | Harmonization of pharmacovigilance systems
community levels continue to advance, and bring additional areas in LMIC
where disparity between HIC and LMIC may continue to widen. Two
key examples include individual pharmacogenomic testing and preci- Several new guidelines and regulations have emerged across LMIC
sion medicine as a tool to anticipate and prevent ADRs at individual adding complexity to the existing pharmacovigilance requirements
level, and the use of big data and artificial intelligence to aid signal including duplication of activities. Thus, significant burden has been
26
detection and interpretation. placed on stakeholders whilst adding little or no benefit for patients
Pharmacogenomics is a field that explores relationships or consumers. In attempt to address this, regional economic communi-
between genes and drug effects, with potential to personalize medi- ties have undertaken harmonization measures to strengthen
cal therapy. For clinical scenarios in which a genotype is clearly pharmacovigilance in LMIC as illustrated in Figure 1. These include
linked to important outcomes, direct genetic testing is increasingly Association of Southeast Asian Nations (ASEAN); Asia-Pacific Eco-
used to support clinical decision making, for example testing for nomic Cooperation; League of Arab States; African Medicines Agency
the HLA-B*1502 allele prior to initiation of carbamazepine to (AMA); East African Community; Economic Community of West
reduce the risk of Stevens–Johnson syndrome. The drug label for African States; South African Development Community; and Pan
carbamazepine recommends HLA-B*1502 screening in all “at-risk American Health Organization (PAHO).
populations” and notes heightened risk “across broad areas of Since 2009, the African Medicines Regulatory Harmonization
Asia”, particularly highlighting the strong risk among those of Han (AMRH) initiative has served as a foundation for the establishment of
Chinese ancestry.27 Such individualised approaches to predict indi- the AMA.32–36 The AMRH initiative was established to strengthen
vidual risk of ADR represents a paradox of equity as testing is medicines regulation in Africa by promoting the effectiveness, effi-
cost-prohibitive and often technologically unavailable in LMIC, ciency, transparency and collaboration of regulatory mechanisms in
including in many areas comprised predominantly of individuals of these settings.36–39 In 2009, Ghana began to host the WHO Collabo-
highest risk. rating Centre for Advocacy and Training in Pharmacovigilance, which
Machine learning is part of artificial intelligence that deals with aimed to promote the uptake of pharmacovigilance by Ministries of
the ability of machines to learn without having human input. Due to Health and other stakeholders across Africa.40 This had major impact
improved computational techniques and the availability of larger on the development of pharmacovigilance in Africa. Training was pro-
datasets in regions where electronic medical records are routine, vided in English by people with a local perspective, but it excluded
there is an increasing trend in machine learning adoption in Francophone countries in Africa. In 2011, Morocco became the WHO
healthcare. Whilst such innovations have great potential in under- Collaborating Centre for strengthening pharmacovigilance capacity in
standing and predicting safety-related events, these technologies the Eastern Mediterranean, Francophone and Arab states. This has
are more difficult to access in LMIC and rely on electronic medical enabled numerous patient safety-related research and training
records, which again are in their infancy in much of the developing activities including the pharmacovigilance of medication errors, herbal
world. medicines and vaccines.41
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494 KIGUBA ET AL.

F I G U R E 1 Global economic regions of relevance to pharmacovigilance in low- and middle-income countries. APEC, Asia Pacific Economic
Cooperation; ASEAN, Association of Southeast Asian Nations; ECOWAS, Economic Community of West African States; EAC, East African
Community; LAS, League of Arab States; PAHO, Pan American Health Organization; SADC, Southern African Development Community

In Africa, 54 of the 55 countries have National Medicines Regula- been signed by 16 other Member States.38 However, only five Mem-
tory Authorities (NMRAs) or administrative units that perform all or ber States have enacted a law to implement the AMA treaty.53 In July
some NMRA functions, albeit with differing levels of growth, exper- 2021, the AMA was established after ratification by the minimum
tise and maturity; 87% of the NMRAs lack functional required number of AU Member States.38
39,42,43
pharmacovigilance systems. None of the African NMRAs are at A specific challenge in LMIC is that in most countries there is little
WHO Global Benchmarking Tool maturity level 4. In SSA, only Ghana or no budgetary support for pharmacovigilance activities by national
and Tanzania have NMRAs at maturity level 3, which depicts stable governments; there exists heavy reliance on donor funding.3,5 How-
30,44
and well-functioning systems. ever, political will is necessary to enable establishment of sustainable
In 2016, the African Union (AU) Model Law on Medical Products budgets to recruit full-time pharmacovigilance staff, conduct routine
Regulation, hereafter AU Model Law, was endorsed by the AU Heads pharmacovigilance trainings and develop national pharmacovigilance
of State and Government to promote medicines regulatory harmoni- policies.5,6,54,55 India demonstrated how initial pharmacovigilance ini-
38,39,45,46
zation and collaboration in Africa. The AU Model Law is a tiatives failed until the national government established infrastructure
legislative framework with 1 of its 5 key tenets being to harmonize for the national pharmacovigilance system and recruited full-time
the requirements and processes for ensuring safe medicines in pharmacovigilance staff.5 In East Africa, Kenya, Tanzania and Uganda
Africa.47 The AU Model Law was developed and promoted through have designated budgets for pharmacovigilance activities that should
the AMRH initiative by the New Partnership for Africa's Development be enhanced to implement national pharmacovigilance guidelines and
(NEPAD), which evolved into the African Union Development Agency regulations more effectively and impactfully.9,39 Pharmacovigilance
48,49
NEPAD. activities generate little or no income for NMRAs, which limits invest-
In 2019, the AU Assembly adopted the AMA treaty,50–52 which ment in pharmacovigilance analysis, feedback and expansion in
each Member State should sign and then enact a corresponding LMIC.56 Introducing the European Union's pharmacovigilance fees
national law to implement this treaty. Rwanda was the first AU Mem- approach, although attractive, could dampen the growth of
ber State to sign the treaty in 2019,34,35,50 and it has subsequently pharmacovigilance systems in LMIC.4,57 However, change has been
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KIGUBA ET AL. 495

proven possible: Lesotho and Namibia are excellent examples of Afri- health information systems.56 However, healthcare databases are
can countries with national governments that fully fund their common in the ASEAN and are the most important source of
39
NMRAs. pharmacovigilance information in Indonesia.21,25
Key timelines of relevance to the development of pharmaco-
vigilance systems in LMIC are illustrated in Figure 2.
7 | LO W RE P O RT I N G R A T ES I N L M I C

5 | S O U R C E S OF D A T A A N D M E T H O D S OF The majority of LMIC with national pharmacovigilance systems have


REPORTING weak regulatory enforcement and minimal pharmacovigilance aware-
ness, resulting in very low reporting rates; few regulatory decisions on
Data on drug safety can be harnessed using several methods, as show medicines safety are drawn from local data.7 Assessment of four east
in Figure 3. Historically, most LMIC data derived from spontaneous African countries in 2018 showed that only 1% of health facilities
reports. By 2018, SSA and Arab countries had each contributed fewer had reported medicine-related harm in the previous year.9 Targeted
than 1% of pharmacovigilance reports in VigiBase58–61 indicating the pharmacovigilance awareness campaigns in LMIC should leverage
importance of more proactive approaches including cohort event public health programmes (e.g. HIV, malaria, tuberculosis [TB]) to pro-
monitoring (CEM) and targeted spontaneous reporting (TSR). mote the reporting of medicine-related harm.2 Other key stakeholders
include HCWs; manufacturers and MAHs; patients/consumers; and
higher learning institutions.
6 | S O U R C E S OF P H A R M A C O V I G I L A N C E
I N F O R M A T I O N I N LM I C
8 | P H A R M A C O V I G I L A N C E TR A I N I N G I N
Spontaneous reports, primarily submitted by HCWs are the main LMI C
source of pharmacovigilance data for regulatory authorities in LMIC.
Pharmaceutical companies and market authorization holders (MAHs) The first training course on CEM and active surveillance in PHPs on
submit the largest number of pharmacovigilance reports in the ASEAN African soil was in Accra, Ghana in 2007, initiated by WHO headquar-
but are much less represented in SSA.21 Sentinel sites for active sur- ters with training support from the Intensive Medicines Monitoring
veillance in public health programmes (PHPs) are important sources of Programme, New Zealand.62
data. In SSA, hospital databases are infrequent sources of In 2014, Beckmann and colleagues developed a comprehensive
pharmacovigilance data due to the limited availability of electronic model pharmacovigilance curriculum for adoption by educational

FIGURE 2 Key milestones in the development of pharmacovigilance systems in low- and middle-income countries
13652125, 2023, 2, Downloaded from https://bpspubs.onlinelibrary.wiley.com/doi/10.1111/bcp.15193 by Nat Prov Indonesia, Wiley Online Library on [26/03/2024]. See the Terms and Conditions (https://onlinelibrary.wiley.com/terms-and-conditions) on Wiley Online Library for rules of use; OA articles are governed by the applicable Creative Commons License
496 KIGUBA ET AL.

FIGURE 3 Hierarchy of sources of individual case safety reports

institutions.63 This model curriculum provides a focused approach for demonstrated that the practice-based, skill-oriented
both preservice and regular in-service training of HCWs to improve pharmacovigilance training method is more effective than the lecture-
pharmacovigilance awareness and, ultimately, promote reporting. based/knowledge transfer training method in increasing the rate and
Preservice pharmacovigilance training is a long-term low-cost inter- quality of ADR-reporting by healthcare professionals.69
9
vention that should be integrated in higher education systems.
Pharmacovigilance education should address three key aspects:
awareness, knowledge and reporting. HCWs should: be aware that 9 | ENGAGEMENT AND EMPOWERMENT
medicines can cause ADRs and should include them in differential OF COMMUNITIES IN
diagnosis; be knowledgeable about the most frequently used medi- PHARMACOVIGILANCE
cines, risk factors for ADRs and other drug-related problems; and
understand the purpose of reporting ADRs and other drug-related Patients or consumers are often excluded from pharmacovigilance
64
problems. activities in LMIC, despite awareness of the value of their involve-
In 2019, the International Society of Pharmacovigilance organized ment.70–72 Since the early 2000s, it has been increasingly recognised
the first-of-a-kind Symposium and Training in Africa, which targeted that the patient is the primary stakeholder in pharmacovigilance,
professionals in the field of pharmacovigilance including regulatory which has the ultimate aim of ensuring their safe use of medica-
agencies, pharmaceutical companies, academia, healthcare providers tions.73 This recognition has led to a shift from the patient being a
and community settings. This event delivered on key topics including: passive recipient to an active participant in their own healthcare.
the current pharmacovigilance landscape in Africa; pharmacovigilance Patient reporting can be defined as, “users of drugs (or their parents
during the preapproval phase in Africa; pharmaco-epidemiological or carers) reporting suspected ADRs directly to a spontaneous
methods and other methods that fit with Africa's unique challenges; reporting system”.74 It has been noted that patient reports may differ
implementing the concept of Qualified Person in Pharmacovigilance; both qualitatively and quantitatively from healthcare provider-
pharmacovigilance inspections; and Risk Management Planning.65 initiated reports, for example describing effects that have substantial
In 2020, four East African universities (in Ethiopia, Kenya, adverse impact on quality of life or that might be sensitive to disclose
Rwanda and Tanzania) launched a generic pharmacovigilance core to a healthcare provider such as sexual dysfunction.74,75 A 2017 sys-
curriculum for undergraduate students of pharmacy, medicine, nursing tematic review of 34 studies confirmed that patient reporting brings
and dentistry. These countries adopted Lareb's pharmacovigilance novel information particularly relating to severity and impact on daily
curriculum, previously adopted from the WHO model curriculum for living, hence complementing the information derived from healthcare
66,67
universities. This focuses on five core pharmacovigilance compe- providers. Thus, patient reporting will contribute to better decision-
tencies for future healthcare professionals, namely: (i) the ability to making processes in regulatory activities.71
understand the importance of pharmacovigilance and drug-induced The majority of evidence has come from Europe, where patient
harm in the context of pharmacotherapy in order to (ii) prevent, reports have been acceptable since the revised European
68
(iii) recognize, (iv) manage and (v) report adverse drug reactions. The pharmacovigilance legislation (Directive 2010/84/EU), which came
curriculum's content could be integrated into exiting courses or taught into force in 2012 and introduced a new framework for drug surveil-
as a standalone programme. Gerritsen and colleagues have lance and proposed valuable changes to improve drug safety.76 This
13652125, 2023, 2, Downloaded from https://bpspubs.onlinelibrary.wiley.com/doi/10.1111/bcp.15193 by Nat Prov Indonesia, Wiley Online Library on [26/03/2024]. See the Terms and Conditions (https://onlinelibrary.wiley.com/terms-and-conditions) on Wiley Online Library for rules of use; OA articles are governed by the applicable Creative Commons License
KIGUBA ET AL. 497

includes the legal right for individual citizens to report suspected found that many patients were already aware of ADRs either through
ADRs directly to the authorities.77 personal or family experience, and wanted more information and edu-
Increasing numbers of countries make provision for direct patient cation on these.85 In China, an evaluation of spontaneous ADR
ADR reporting. Surveying direct patient reporting systems in 50 coun- reports from children (made by the child or their carer) were found to
tries that were part of the WHO-PIDM between 2013 and 2014, comprise only 2.5% of 3348 reports.86
Margraff and colleagues found that most countries had implemented Whilst access to the internet and ownership of a smartphone
a patient ADR reporting system, although many had been very are the pre-requisites to using mobile apps, which most
recently established. Many different forms were found to exist world- individuals in LMIC, particularly in SSA, cannot afford, the Unstruc-
wide leading to the recommendation that these should be harmonized tured Supplementary Service Data (USSD) and Integrated Voice
by considering the strengths and weaknesses of all existing forms.78 Response systems are alternative tools that are accessible on both
On a similar theme, Pal and colleagues reviewed WHO strategy for low-tech basic feature mobile phones and high-tech smartphones
collecting safety data in PHPs: patient reports can be incorporated and do not use the internet. The USSD and Integrated Voice
into these structures.79 Despite increasing recognition of the benefits, Response systems are real-time text-driven technologies that allow
and changes to legislature in some HIC, evidence from LMIC remains users to interact directly from their mobile phones by making a
scanty. The International Society of Pharmacovigilance Workgroup on selection from a menu. The USSD interface is a key success factor
Patient Engagement assessed patient stakeholder involvement in in the extensive penetration of mobile money banking in rural
pharmacoepidemiology research through systematic review. Few pub- unbanked SSA87 but its use in pharmacovigilance has not yet been
lications mention patient or other stakeholder engagement in the evaluated. The Pharmacovigilance Rapid Alert System for
design, analysis or reporting of research: of 11 identified studies, Consumer Reporting (PRASCOR) has been used successfully in
10 were in Europe or North America. A lack of standardised language Nigeria. Potential reporters are encouraged to send a text message
to report patient involvement was noted.80 Tanzania is an example of to a specific number at Nigeria's National Agency for Food and
an SSA country that promotes direct patient/consumer reporting of Drug Administration and Control and are then contacted by
adverse events using a bespoke paper form and made available in the phone.88
9
local language (Swahili). However, more convenient methods, An example of technological advance enabling patient self-
e.g. digital pharmacovigilance, are needed to promote reporting and reporting is seen in the South African MomConnect platform that
ensure quality. An attempt to review data from 50 countries that par- allows pregnant women to directly enter information relating to
ticipate in the WHO-PIDM, found gaps in data quality so that only medication exposure and harms.89 MomConnect was launched in
36 were represented in the final analysis; all 6 African countries ini- 2014 with the dual intent of providing a platform for health pro-
tially identified were then excluded. Unsurprisingly, stronger and more motion through supportive text messaging to mobile phones of
established pharmacovigilance systems were associated with more pregnant women (using SMS and USSD technology) and of
81
patient reporting. establishing a registry of pregnancies.89 Individual interaction,
Several qualitative studies have explored culturally specific com- through asking questions and reporting symptoms is supported by
munity perceptions with regard to patient-initiated ADR-reporting. the system, and hence self-reported pharmacovigilance can be
Thai patients prescribed statins were able to explain how they identi- achieved.90 Strong partnership between the South African Ministry
fied and assessed experiences of suspected ADR and had generally of Health and Non-Governmental Organizations with shared launch
considered the same issues as are present in published causality events, and promotion to be incorporated into antenatal care has
tools,82 leading the authors to recommend that clinicians encourage resulted in the system being accessed by almost two thirds of
patients to self-monitor for potential ADRs and give credence to their pregnant women across the country. There are some factors
83
reports. Drawing from a very different perspective, Bukirwa et al unique to South Africa that may have enhanced the success of this
investigated local perceptions and experiences with antimalarial treat- initiative such as wide mobile phone coverage, including among
ment in Uganda. Although community members often recognised females in rural area, and female literacy rates of >90%.90
adverse events, these were rarely reported either due to it being a Furthermore, current running costs of approximately $1 million
known and expected event, or because of concerns relating to the USD annually will be prohibitive to other LMIC seeking to adapt
cost of additional visits to healthcare facilities. Community engage- the model.
ment on the benefits of reporting and providing sensitization, training More widely, online reporting and mobile phone applications
and feedback will be important aspects to increase participation.83,84 (e.g. Med Safety App and WhatsApp) can be leveraged to promote
pharmacovigilance. The Med Safety App was adapted for LMIC from
the prototype app developed by the European Union's Innovative
1 0 | TE C HN O LO GI C A L A D V A N C ES A N D Medicines Initiative. Since 2017, Med Safety has been introduced in
DIGITAL PHARMACOVIGILANCE SYSTEMS eight LMIC supported by an agreement with WHO, namely Armenia,
Botswana, Burkina Faso, Cote d'Ivoire, Ethiopia, Ghana, Uganda and
Patient self-reporting may be easier to implement in regions with Zambia.91 India has developed and implemented its own
85
higher mobile phone penetration. In Saudi Arabia, Kassem et al mobile app.92
13652125, 2023, 2, Downloaded from https://bpspubs.onlinelibrary.wiley.com/doi/10.1111/bcp.15193 by Nat Prov Indonesia, Wiley Online Library on [26/03/2024]. See the Terms and Conditions (https://onlinelibrary.wiley.com/terms-and-conditions) on Wiley Online Library for rules of use; OA articles are governed by the applicable Creative Commons License
498 KIGUBA ET AL.

1 1 | R I S K C O M M U N I C A TI O N B E TWE E N 12 | PHARMACOVIGILANCE IN PHPS IN


PHARMACOVIGILANCE SYSTEMS AND LMI C
HCWS AND COMMUNITIES
12.1 | Overview of pharmacovigilance in PHPs
A common weakness of pharmacovigilance systems in LMIC is
poor communication and feedback to HCWs and communities. Public and private healthcare systems in LMIC are complemented by
Regular feedback to HCWs and consumers instils in them the dedicated PHPs to address the huge burden of infectious diseases
importance of reporting medication-related harm, prompting greater through mass distribution of new and/or repurposed medicines
involvement in pharmacovigilance activities.56 Feedback to the e.g. antiretrovirals, anti-TB medicines, antimalarials, vaccines and med-
public could include warnings on drug safety signals (e.g. drug icines for neglected tropical diseases (NTDs).6 The safety profile of
toxicities, poor-quality medicines) and the regulatory action(s) fol- distributed medicines is rarely well known in LMIC since safety data
lowing the detection of safety signals e.g. product withdrawals. are primarily generated in HIC whose populations differ socioeconom-
The communication of pharmacovigilance information to HCWs ically, epidemiologically and genetically. Initially, international donors
and communities entails mechanisms such as periodic bulletins, provided substantial funding to PHPs in LMIC to increase access to
newsletters, websites, mobile apps (Med Safety, WhatsApp, medicines for the priority infectious diseases without proportionate
Twitter, etc.), SMS, email, toll-free telephone lines, radio and televi- investment in pharmacovigilance infrastructure to monitor the safety
sion. In East Africa, Ethiopia and Tanzania have communication of these medicines6,40,42,93–98; the immediate benefits of providing
plans that are specific for pharmacovigilance; Kenya has a commu- potentially life-saving medication eclipsed considerations of risk.
nication plan that is not specific for pharmacovigilance; and However, it can be argued that integration of pharmacovigilance is
Rwanda does not have a communication plan.9 The implementation ethically essential, as illustrated in Figure 4. The harms that can result
of these communication plans, where they exist, has not always from neglecting pharmacovigilance can be illustrated through occur-
been smooth. For instance, in Ethiopia, the bullen/newsletter rence of serious adverse events. For example, permanent hearing loss
should be published four times annually but only one bulletin was occurs in around half of patients who are given injectable medicines
published in 2018.9 The public can call Kenya's pharmacovigilance for treatment of multi-drug resistant (MDR) TB e.g. capreomycin and
centre but the line is not toll-free, which limits the number of aminoglycosides99; in recognition of this burden and associated costs,
would-be callers.9 newer, potentially less toxic treatment alternatives e.g. bedaquiline

FIGURE 4 Ethical imperative for integrating pharmacovigilance activities into public health programmes and mass drug administration
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KIGUBA ET AL. 499

and delamanid are being introduced despite their expense.100 The The MDA campaigns are often conducted by community drug
number of SSA countries with pharmacovigilance centres linked with distributors or schoolteachers with little or no healthcare back-
PHPs has increased from 10 in 2000 to 35 in 2018.3,101 Sentinel sites ground.113 This unacceptable lack of systematic safety follow-up of
in PHPs are the commonest source of pharmacovigilance data in SSA: hundreds of millions of people exposed to preventive chemotherapy
76% of pharmacovigilance reports in Kenya are contributed by the for NTDs in LMIC should be reviewed and strengthened. Community
HIV programme and 47% in Ethiopia by the TB programme.9 How- dialogue should ensure that needs and concerns of those receiving
ever, pharmacovigilance structures related to mass drug administra- the drugs are taken into account.
tion (MDA) campaigns for NTDs remain almost nonexistent.

12.3 | Pharmacovigilance of anti-TB, antiretroviral


12.2 | Pharmacovigilance in neglected tropical and antimalarial medicines
diseases programmes
Pharmacovigilance relating to other PHPs has gained more attention.
NTDs are a diverse group of viral, bacterial, protozoal and parasitic In 2013, WHO published guidelines for PHPs that fortified spontane-
worm infections or infestations that affect more than 1.5 billion peo- ous reporting systems with more robust pharmacovigilance methods
ple worldwide.102–104 The populations most often affected live in such as CEM and TSR.112,114–116 CEM and TSR can generate verifi-
102,103,105
poverty (<USD 2/day) with inadequate sanitation. The initial able denominator data to measure the risks of medicines.79 Ghana
WHO target was to eradicate or eliminate these diseases by and Nigeria have successfully implemented CEM to evaluate the
106,107
2020 through 2 main strategies: (i) preventive chemotherapy safety of artemisinin-based combination therapies for malaria treat-
using MDA and (ii) intensified disease management.102,103 ment and Uganda has applied TSR to monitor the safety of tenofovir,
In 2017, a billion people received preventive chemotherapy for at an antiretroviral drug.117–119 Collaboration between PHPs and
least one NTD (Uniting to Combat Neglected Tropical Diseases Africa NMRAs is critical to strengthening pharmacovigilance systems but is
108
and Neglected Tropical Diseases; World Health Organization). often limited.3,119 Some LMIC have demonstrated coordinated action
Preventive chemotherapy is used in the control of five diseases: between their national expanded programmes on immunization and
soil-transmitted helminthiasis (834 million requiring chemotherapy), NMRAs,120 which is in line with the recent merging of the director-
schistosomiasis (218 million), lymphatic filariasis (941 million), ates of vaccines and medicines safety surveillance at WHO.121 The
onchocerciasis (185 million) and trachoma (192 million). Some WHO is implementing the smart safety surveillance project to
medicines are effective against several diseases, some against only strengthen, expand and streamline pharmacovigilance in LMIC.
one. All the medicines are donated by their manufacturers to the NTD This project will optimize the post-marketing surveillance of new pri-
programmes. ority medicines and vaccines that have not been tested elsewhere.
Monitoring the safety of medicines for NTDs is ethically impera- LMIC will share expertise and experiences, and build in-country
tive because these medicines are given regularly, sometimes annually, capacity for pharmacovigilance.101,122
109
to all at-risk populations without prior screening or diagnosis. Thus,
the population exposed to these medicines is often much larger than
the infected population. In a benefit–harm perspective, uninfected 12.3.1 | Anti-TB medicines
individuals are exposed to risks of medicine-related harm.107,110,111
However, robust pharmacovigilance systems to detect, record and New and repurposed anti-TB medicines have recently been intro-
analyse treatment-related adverse events for preventive chemother- duced to manage MDR-TB. WHO introduced the active drug safety
112
apy are scarce. Even where national pharmacovigilance systems monitoring and management (aDSM) framework to strengthen the
exist, no serious attempts are made to document, manage and report pharmacovigilance of these in LMIC,123 see Figure 5. The aDSM pro-
adverse events following MDA because the priority of NTD gramme primarily focuses on the identification, management and
programmes is to maximize MDA coverage by building confidence reporting of serious adverse events linked to new regimens for MDR-
that the medicines are safe. Treatment-related adverse events are fre- TB and extensively drug-resistant TB.123
quently managed and contained at the sites and are not reported to The novel MDR-TB medicines, bedaquiline, delamanid and pre-
the NMRAs for fear of undermining confidence that may negate the tomanid received accelerated approval by the US Food and Drug
impact of MDA campaigns. For example, in 2017/2018, zero adverse Administration, European Medicines Agency and the Japanese and
events following MDA were reported to the NMRAs in three East Korean regulatory authorites124–126 based on limited clinical data
African countries (Kenya, Ethiopia, Tanzania) despite the millions of from HIC and were scaled up rapidly in LMIC despite the gaps in
individuals exposed to MDA during the same period. Furthermore, knowledge about safety.101,124–126 Clofazimine and linezolid have
there is limited or no funding for monitoring the safety of medicines been repurposed for MDR-TB treatment, are prescribed with little
for NTDs in contrast to the priority PHPs and there is little or no col- experience and for longer than their recommended duration of use,
laboration between NTD programmes and in-country which increases the risk of drug-related toxicities, and have not yet
pharmacovigilance systems. been approved for this indication.127 The aDSM framework should
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500 KIGUBA ET AL.

FIGURE 5 Relationship between national tuberculosis (TB) control programmes and pharmacovigilance systems

improve pharmacovigilance relating to these agents. In Asia, India has in several SSA countries including Burkina Faso, Ghana, Kenya,
created an elaborate pharmacovigilance system that automatically Mozambique, Nigeria, Tanzania and Zimbabwe.133,134
transmits bedaquiline-related safety data between the TB programme
and the national pharmacovigilance database.128 However, the crea-
tion of a global aDSM database for new and repurposed medicines 13 | P H A R M A C O V I G I L A N C E I N
alongside WHO's VigiBase duplicates rather than consolidates NO N C O M M U N I C A B L E D I S E A S E S
pharmacovigilance activities in LMIC where resources are in limited PROGRAMMES
supply. The recent introduction of the PAVIA project, supported by
EDCTP, in Ethiopia, Tanzania, Eswatini and Nigeria is an attempt to Noncommunicable diseases comprise an increasing burden of disease
improve the pharmacovigilance of MDR-TB and supports the integra- in LMIC, with the major conditions being cardiovascular disease, dia-
tion of aDSM with general pharmacovigilance.129 betes mellitus and cancer. Therefore, events relating to medicines
safety, including ADRs and drug–drug interactions will increasingly
relate to additional classes of medication.135 Whilst much
12.3.2 | Antiretroviral medicines pharmacovigilance data in LMIC has been drawn from public health
programmes focusing on specific conditions, the emergence of
The rapid scale up of the new HIV drug dolutegravir as the main increasing co-morbidities and more complex medication regimens
agent in both first-line and second-line antiretroviral therapy, underpins the importance of integrated systems.
together with concurrent TB preventive therapy (especially isonia-
zid) uptake prompted adoption of the aDSM model for monitoring
the safety of these medicines e.g. in Uganda.130 Through such pro- 14 | PR E G NA NC Y P HAR M AC OVIG IL AN CE
cesses, Uganda described previously unrecognized signals relating
to glucose dysregulation131 and are currently investigating potential It is increasingly recognised that worldwide, most women require
memory disturbances.132 Considerations relating to dolutegravir and drug treatment at some point during pregnancy.136 Moreover, in
pregnancy are described below. LMIC, there are some particular risks. In many settings, the preva-
lence of HIV in women attending antenatal care far exceeds the
national average, and pregnancy increases vulnerability to severe
12.3.3 | Antimalarial medicines malaria, which in turn can threaten the viability of the pregnancy.
Furthermore, no pregnancy screening is done prior to MDA; the
Cohort event monitoring has been successfully implemented in the probability of exposing women who are not yet known to be preg-
active safety monitoring of artemisinin-based combination therapies nant to the drugs is high.
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KIGUBA ET AL. 501

It is rare for sufficient pregnancy safety data to be available documented, together with follow-up for adverse events during
before a drug is widely introduced into a population that includes pregnancy and surveillance for birth defects after parturition. How-
women of reproductive potential. Despite increasing recognition that ever, engagement with antenatal care, particularly in early pregnancy
pregnant women should be included in clinical trials to enable assess- during the time when exposure presents greatest potential terato-
ment of safety and effectiveness,137–139 even in the field of antiretro- genic risk, remains variable and low in many LMIC. Furthermore,
viral therapy, there is a median delay of six years between drug maternity health records are usually paper-based, contain a level of
140
licensing and the availability of pharmacokinetic data in pregnancy. detail that falls short of what would be required to capture all the
If clinical trials and pharmacokinetic studies are undertaken, these necessary information, and are held either by the woman or the
may not provide the necessary data. healthcare facility and therefore can be difficult to access
The dolutegravir story drew global attention to the challenges systematically.
and complexities that are faced when introducing a new, effective The Table S1 summarizes key studies describing the incorporation
drug into a population. Dolutegravir is an HIV integrase strand trans- of pregnancy pharmacovigilance and birth outcome surveillance into
fer inhibitor that has been shown in nonpregnant populations to the routine monitoring systems.
reduce the viral load twice as quickly as the existing standard of care In summary, prospective, comprehensive data of drug exposure
141
therapies, a finding that was later confirmed in trials among during pregnancy and correlation with birth outcome data are
Ugandan and South African women presenting with untreated HIV in required. In LMIC, the best solutions will be those that dovetail with
the third trimester of pregnancy.142,143 In 2016, the Botswanan Minis- existing systems and infrastructure to enable a sustainable interven-
try of Health decided to transition national policy to dolutegravir- tion that has buy-in from all the relevant stakeholders. Training of
based regimens for all people living with HIV. The Tsepamo study had HCWs on the importance of accurate collection of such data should
initially been designed to monitor for birth defects with the standard be prioritised.
of care efavirenz-based regimens, but adapted to monitor births fol-
lowing dolutegravir exposure in pregnancy. An interim analysis to
inform WHO policy revealed the unexpected finding of neural tube 15 | PAEDIATRIC PHARMACOVIGILANCE
defects in 0.9% (4 out of 426 periconception exposures),144,145 which
led to a global safety alert and many countries recommending that As with pregnancy, information on the safety and efficacy of a
dolutegravir be withheld in women of childbearing potential. How- medicine used for neonates (<28 d), infants (28 d–23 mo), children
ever, the drug had already been proven effective and better tolerated (2–11 y) and adolescents (12–17 y) is limited if individuals from these
than the comparator, and communities of women living with HIV ages are not included in the premarketing clinical trials, which is
raised a well-publicised process calling for clear communication of frequently the case. Even where children are included in trials, drug
risks and benefits together with individual choice.146 This highlighted toxicity is poorly reported when compared with adults. Particular chal-
the tension between a public-health policy and the autonomy of indi- lenges in understanding medicine-related harms relate to the lack of
viduals, in addition to the fragile birth defect surveillance and trial data, that children are often given drugs off label or unlicensed
pharmacovigilance systems that exist in many LMIC. Furthermore, this because of lack of specific data and that they have different physiol-
emphasised the inability of standard clinical trials or pharmacokinetic ogy impacting on pharmacokinetics. Furthermore, some adverse drug
studies to generate a sufficient sample size to detect rare events. events that are subjective in nature may be difficult for a child to
Mofenson and colleagues147 argue that to rule out a 2-fold increase in describe.
overall birth defect risk, with a 3% prevalence in the general popula- In the UK, an analysis of the contribution of children and young
tion, 200 preconception/early first trimester exposures are required; people to the UK Medicines and Healthcare products Regulatory
however, for rare defects such as neural tube defects, (0.1% and Agency yellow card scheme over a 10-year period found that patients
≤0.06% prevalence in countries without and with food folate fortifica- from as young as 10 years were able to contribute reports, although
tion, respectively),148 at least 2000 preconception/early first trimester most were submitted by adolescents aged 17 or 18 years. Most
exposures are needed to rule out even a 3-fold increase in risk reporting related to vaccines, oral contraceptives, acne medication,
(e.g. from 0.1 to 0.3%). With each subsequent analysis of the dolu- anti-infectives and antidepressants. The authors conclusion that
tegravir data, as the denominator of exposed pregnancies has children and adolescents are given the knowledge and resources to
increased, the signal for association with NTD has decreased, further support themselves in reporting ADRs is consistent with the consen-
emphasising the challenges of obtaining sufficient data for clear clini- sus for engagement and empowerment of adult patients.150 In
149
cal recommendations. Uganda, only one in six reports in the national pharmacovigilance
It has long been recognised and emphasised by initiatives includ- database in 2012–2014 were from patients aged <20 years.22
ing the SGDs and WHO policy, that engagement with antenatal care Most pharmacovigilance reports surrounding paediatric
substantially reduces maternal and infant mortality. Theoretically, populations have focussed on specific populations or disease areas,
pregnancy pharmacovigilance systems could be incorporated into and generalizability may be limited. Most studies have shown that
antenatal care, with a complete medical history including all drug when systems are established, increasing numbers of ADRs are
exposures prior to and during the current pregnancy being reported.151,152
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502 KIGUBA ET AL.

16 | P H A R M A C O V I G I L A N C E OF V A C C I N E S The greatest challenge of COVID-19 vaccine safety monitoring will be


faced by pharmacovigilance systems in LMIC, particularly in Africa,
It is imperative that vaccine administration is accompanied by robust where weak or nonexistent regulatory pharmacovigilance systems
pharmacovigilance given that these products are used widely in prevail. African countries over-rely on paper-based forms for AEFI
populations who are currently well; the risk–benefit considerations reporting but should embrace electronic tools of AEFI reporting e.g.
are such that even low rates of adverse events may be unacceptable. Med Safety, DHIS2 and WHO's VigiFlow.161 LMIC should draw from
the experience of scaling up the pharmacovigilance of antiretrovirals,
anti-TB medicines and antimalarials e.g. a different set of important
16.1 | Vaccines in children AEFIs and AESIs could arise in LMICs with different clinical patterns
of local diseases from HICs e.g. HIV, malaria, TB, nutrition status.
The WHO minimum requirements of a country's capacity to monitor COVID-19 vaccines target very large healthy adult populations
vaccine safety are: (i) a national causality assessment committee for seeking to reduce their risk of developing severe disease.158 Thus,
adverse events following immunization (AEFI); and (ii) reporting a min- LMIC should promote transparency and effective monitoring of vac-
imum of 10 AEFIs per 100 000 surviving infants annually.153 In the cines to foster public trust in COVID-19 vaccination programmes.
past decade, LMIC reported AEFIs less frequently to VigiBase and Global collaboration is imperative for LMIC to tap into the well-
with a lower proportion of serious AEFIs than HIC120 possibly developed pharmacovigilance systems in HIC, which promote such
because of the establishment of vertical Expanded Programmes on transparency and rapid feedback to the public. LMIC could be guided
Immunization (EPIs) that do not communicate well with the NMRAs. to give priority to the signal evaluation of serious/unexpected adverse
Collected AEFIs are not incorporated into VigiBase, partly also events to avoid overwhelming their pharmacovigilance systems and
because EPIs have not adopted the ICH E2B standard for recording wastage of scarce resources. Benign adverse events e.g. headache,
and exchange of ICSR data. The NMRAs in Africa have limited capac- injection site pain and fever could be evaluated when additional
ity to monitor vaccine safety.108 However, the WHO Africa region resources are available.161 A WHO-approved list of AESIs for COVID-
registered the largest increase in the proportion of countries that are 19 in LMIC has been published.162 The African Vaccine Regulatory
able to report ≥10 AEFIs during the past decade; from 15% (n = 7) of Forum is a good platform to promote international collaboration and
47 countries in 2010 to 57% (n = 27) in 2019.120 The observed the African Advisory Committee on Vaccine Safety will support
growth in AEFI reporting in Africa is attributable to WHO's increased African countries on pharmacovigilance and COVID-19 vaccine
investment in the region; that is, conducting vaccine safety trainings safety.163,164 The PAHO Member States developed a
and supporting the establishment of national AEFI surveillance sys- pharmacovigilance dashboard to support the introduction and safety
tems including standardization of the AEFI data collection tool.154 monitoring of COVID-19 vaccines on the American continent.165
LMIC could further improve their vaccine safety surveillance sys-
tems by strengthening collaboration between National EPIs and
NMRAs. Such collaboration could improve the rate and quality of 17 | P H A R M A C O V I G I L A N C E I N TH E
AEFI reporting to foster timely detection and response to vaccine P R I V A T E H E A L T H C A R E SE C T O R I N L M I C
safety signals.154 For instance, the total number of AEFIs in Eritrea, an
African country, increased 90-fold during 3 years (11 in 2016; 966 in The national pharmacovigilance infrastructure in most LMIC sits
2018) when their NMRA and EPI formed an integrated AEFI surveil- within the public healthcare sector, which presents challenges for the
lance system. Eritrea enhanced its vaccine safety surveillance system safety monitoring of medicines obtained from the private healthcare
by training HCPs and establishing an AEFI causality assessment sector. Private health facilities in LMIC, particularly in SSA, are
120
committee. scarcely involved in pharmacovigilance activities due to the percep-
tion that adverse events are only associated with poor quality
healthcare.6 However, pharmacovigilance is an essential component
16.2 | COVID-19 vaccines of high-quality healthcare, and there is a need to promote
pharmacovigilance activities in the private sector to foster patient
By March 2021, >40 COVID-19 vaccine candidates were in phase III safety.
clinical trials or had received emergency approval.155 By April 2021,
almost 1 billion doses of vaccines had been administered globally
albeit inequitably with 40 doses per 100 people in North America and 18 | P H A R M A C O V I G I L A N C E I N TH E
1.1 doses per 100 people in Africa.156–158 The WHO Global Vaccine PHARMACEUTICAL INDUSTRY IN LMIC
Safety Initiative promotes harmonization of the reporting of AEFIs
and adverse events of special interest (AESI).159 A recent survey in Stringent pharmacovigilance regulatory requirements are infrequently
more than 100 LMIC showed that the existence of well-functioning available or enforced on pharmaceutical companies/MAHs in develop-
child immunization programmes is not a strong predictor of country ing markets, particularly in SSA.128 MAHs should, by international
160
readiness to deliver and monitor the safety of COVID-19 vaccines. standards, employ qualified persons for pharmacovigilance (QPPVs)
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KIGUBA ET AL. 503

and submit ICSRs, Periodic Safety Update Reports, Risk Management exposure and ADE.172 The Beijing pharmacovigilance database
Plans and Periodic Benefit–Risk Evaluation Reports to their respective receives adverse drug event data from 94 hospitals in the region, and
NMRAs. Implementing these pharmacovigilance requirements for this has been used to analyse reports arising from the use of tradi-
MAHs is costly for local small-scale manufacturers in LMIC and, thus, tional Chinese medicine. As an example, between 2004 and 2014,
ought to be adapted to the local situation.6 Ghana and Kenya were 1393 cases of anaphylaxis were triggered by HTM injections.173 In
the first LMIC in SSA to require MAHs to have QPPVs. In 2018, Vietnam, 5% of severe cutaneous ADRs were found to relate to
Tanzania introduced the mandatory requirement for MAHs to have HTM.174
9
QPPV. Furthermore, MAHs in Ethiopia and Tanzania are required to In other settings it can be even more challenging to develop sys-
conduct post-marketing surveillance and to submit Periodic Safety tems to understand the composition, formulation, uses and effects of
Update Reports and Periodic Benefit–Risk Evaluation Reports to their traditional remedies. To understand effects, mechanism and causality,
NMRAs. Currently, the involvement of MAHs in national it is essential to know about precise composition or recipes, their prep-
pharmacovigilance systems in SSA is minimal and compliance should aration, storage, route of administration and dosing. Furthermore, the
be enforced through pharmacovigilance inspections.166 However, dose may be difficult to quantify and variation within the composition
NMRAs in SSA should as well build the capacity to analyse the reports may occur seasonally or geographically. Ethnopharmacology is an
requested from MAHs. 9
In contrast to the dearth of “interdisciplinary scientific exploration of biologically active agents
pharmacovigilance regulation for MAHs in SSA, the majority of traditionally employed or observed by man”.175 Drawing from exten-
ASEAN (7 of 10) have legal frameworks for MAHs to report ADRs to sive experience in South America, Rodrigues describes how
their drug regulatory agencies.21 ethnopharmacological surveys to describe uses, dosages, sources and
methods of preparation of HTM could be adapted to examine safety
aspects, proposing a tool comprising a list of questions that could be
19 | PHARMACOVIGILANCE FOR HERBAL applied during interview and observational studies, focussing on col-
O R T R A D I T I O N A L M E D I CA T I O N S lecting information and spontaneous reports of ADRs. Establishing a
causal relationship can be complex given the combinations of herbs
Herbal and traditional medicinal products (HTM) include man- used. It is not yet clear if adopting the proposed tools can yield high
ufactured products containing herbal ingredients and simple prepara- quality data enabling such causality assessment.176 Furthermore, such
tions of herbal substances, the majority of which are derived from products are often prescribed outside of conventional healthcare set-
plants. Systems include Chinese medicine, Ayurvedic medicine (Indian tings. Three quarters of HTM practitioners around Lagos, Nigeria
subcontinent), Aboriginal medicine (Australia), te Rongoa Maori claimed that herbal medicines have no adverse effects, under 7% had
(New Zealand) and many others.167 Whilst recently increasing in pop- ever documented any ADR, and no documentation was ever for-
ularity in many well-resourced settings,168 in LMIC, a substantial pro- warded to pharmacovigilance authorities.177 Looking more broadly,
portion of the population relies on HTM as their main, or only source Skalli and colleagues surveyed HTM pharmacovigilance in African
of primary healthcare, for reasons including cost, ease of access, per- members of the WHO-PIDM in 2014. Whilst spontaneous reporting
ception of safety and sociocultural factors. Pharmacovigilance of of HTM ADRs is permissible in most countries, the number of reports
HTM should be concerned with all aspects of use that have conse- received by most countries was very low or insignificant, with reports
quences relating to safety and efficacy. from traditional prescribers being extremely rare and originating from
Recognising the importance of this, the WHO published guide- a single country (Morocco). A need for regulation, training and techni-
lines on safety monitoring and pharmacovigilance for herbal medi- cal assistance was noted.178
cines.169 WHO-PIDM aims to develop a comprehensive global The significant under-reporting of adverse events from HTM
pharmacovigilance strategy that responds to the healthcare needs of probably relates to lack of awareness of pharmacovigilance issues
LMIC. The UMC launched a traditional medicines programme to stim- and reporting systems among those dispensing and using the
ulate reporting for these products and developed the herbal anatomi- preparations, administration outside of the mainstream healthcare
cal therapeutic chemical classification systema and a recommendation settings and perceptions of safety. Furthermore, a significant
170,171
for a standardized nomenclature of therapeutic plants. In 2001, proportion of HTM use is directly initiated by the patient, rather
the UMC introduced a traditional medicines surveillance scheme to than via a healthcare provider of any type. Once more, it is clear
stimulate reporting and improve the quality of reports of suspected that community engagement and empowerment is important to
ADRs associated with HTMs. raise awareness of safety issues, and the need to report these to
In some settings, the formulation of HTM lends itself to the adop- healthcare providers.
tion of regulatory science. The National Medical Products Administra-
tion in China proposes to advance the regulatory capacity of
traditional Chinese medicines with the adoption of regulatory science. 20 | RECOMMENDATIONS
The China Hospital pharmacovigilance system was established in
2015, as a nationwide programme to identify safety signals proac- In LMIC, a stepwise approach to strengthening national
tively and to assist the analysis of the association between drug pharmacovigilance infrastructure based on available resources is
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504 KIGUBA ET AL.

recommended, moving from a core framework to advanced capacity. to estimate the risks of medicines using pharmacoepidemiological
The harmonization of regulatory systems across LMIC ensures that methods. The potential sources of robust pharmacovigilance data for
weak or nonexistent pharmacovigilance systems draw from the more pharmacoepidemiological studies are cohort studies (including CEM),
established systems. Thus, LMIC in Africa ought to focus on the most record-linkage studies, registries (e.g. insurance registries, pregnancy
essential functions and to build reliance between countries.122,179 and birth outcomes registries) and randomized controlled trials.56,180,181
Pharmacovigilance systems in LMIC should invest in electronic LMIC should strengthen the pharmacovigilance of frequently
health information systems to support the establishment of large used medicines used to treat NTDs and noninfectious diseases (diabe-
healthcare databases capable of using unique individual identifiers to tes, high blood pressure, stroke, etc.) due to the rising morbidity, mor-
link medication use data with medicine-related harm data. Large elec- tality and healthcare costs associated with these diseases.182
tronic databases enable the use of statistical techniques and make it LMIC, particularly in Africa, should accelerate global and regional
possible to evaluate the health impact of pharmacovigilance regulatory harmonization to foster collaboration and reliance. Compe-
decisions.19,56 These databases should be built using international stan- tent regulatory authorities in Africa engender trust and could provide
dards for record keeping, allowing easy exchange of data between the main ingredient of any useful roadmap towards building the
pharmacovigilance partners. The databases provide denominator data desired collaboration. Thus, reliance on the work and regulatory
decisions made by other African countries in their region with more

T A B L E 1 Pharmacovigilance priorities in low- and middle-income competent regulatory authorities facilitates faster approval of novel
countries (LMIC) and essential medicines—making the medicines more accessible to
their populations.179 In-country harmonization of national regulatory
Creating a culture where pharmacovigilance is prioritised
and programmatic pharmacovigilance activities should also be a
Training on pharmacovigilance to be embedded into medicine,
priority.
pharmacy, nursing and midwifery curricula
Over the past two decades, considerable progress has been made,
Feedback provided to healthcare workers, policy makers and
consumers in response to pharmacovigilance reports and focus on the priority areas summarized in Table 1 will improve

Regular in-service training opportunities and easy-to-access updates


pharmacovigilance in LMIC, and so ultimately, improve the health of
on pharmacovigilance the populations.
Engagement and empowerment of communities to report medicine-
related harms AC KNOW LEDG EME NT
Harmonisation of patient reporting tools C.W. is supported by a Wellcome Clinical Research Career Develop-
Media and public engagement activities to raise awareness of ment Fellowship 222 075/Z/20/Z. C.W. is an investigator on the
pharmacovigilance DolPHIN-2 Study, funded by Unitaid. R.K. is supported by a Makerere
Consultation with and involvement of community representatives, University Research and Innovations Fund grant (no grant number).
particularly for mass drug administration
Unstructured Supplementary Service Data approaches to enable COMPETING INTER ESTS
patient self-reporting using standard mobile phone
No author has any conflict of interest.
Systems and infrastructural development
Stepwise approach to strengthening national pharmacovigilance CONT RIB UTOR S
infrastructure based on available resources, moving from a core
All authors contributed equally to the manuscript.
framework to advanced capacity
Harmonization of regulatory systems across LMIC to ensure that
DATA AVAILABILITY STAT EMEN T
weak or nonexistent pharmacovigilance systems draw from the
more established systems Data sharing not applicable to this article as no datasets were gener-

Engaging pharmaceutical companies and market authorization holders ated or analysed during the current study.
as partners in national pharmacovigilance systems through
regulations compatible with international standards OR CID
Learning both within and between countries Ronald Kiguba https://orcid.org/0000-0002-2636-4115
Building on local strengths and clinical priorities Sten Olsson https://orcid.org/0000-0002-6078-0649
Targeted pharmacovigilance awareness campaigns in LMIC should Catriona Waitt https://orcid.org/0000-0003-0134-5855
leverage public health programmes (e.g. HIV, malaria, tuberculosis)
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