EFSA supporting publication 2015:EN-739 EXTERNAL SCIENTIFIC REPORT Strategy support for the Post-Market Monitoring (PMM) of GM plants: Review of existing PMM strategies developed for the safety assessment of human and animal health1 ADAS UK ltd2 ABSTRACT Commission Implementing Regulation (EU) No 503/2013 on applications for authorisation of genetically modified (GM) food and feed legalised the requirement for a Post-Market Monitoring (PMM) plan if the outcome of the risk assessment identifies a need to do so. This report provided a systematic review of existing monitoring programmes for food, feed, human and animal health and an inventory of data collection sources that may be useful for PMM of GM food and feed. Under the legislative requirements PMM should confirm that specific recommendations of use are followed by the consumer/animal owner, qualify the predicted consumption of GM food and feed and further characterise any intended or unintended effects highlighted during the pre-market risk assessment. The largest barriers to conducting PMM of GM food and feed in the EU were found to be the ‘unrecognisable’ nature of GM traits further down the food and feed supply chain after processing, and the lack of appropriate consumption data at the branded/product level. EU legislation on traceability and labelling of GMOs requires products to carry a ‘unique identifier’, however, this information is lost once the product is further processed to become a product ‘produced from a GMO’. Consumption data held at a product level by retailers or market research agencies was shown to be more useful for PMM of GM food or feed than that held at the national level by public bodies. The project concludes that several changes would be required in order to conduct comprehensive PMM of GM food and feed in the EU, namely; greater detail on traceability requirements of GMOs, a database of which food and feed products contain which GM traits at specific quantities, consumption data at the branded/product level and a system for reporting the relevance and intensity of effects and unintended effects. © [ADAS], 2015 KEY WORDS GMO, Post-Market Monitoring, Post-Market Surveillance, trait, consumption data, composition data DISCLAIMER The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety 1 2 EFSA-Q-2013-00701 Steven Tompkins, Lottie Alves, Elizabeth Hudson, Alan Lyne, Daniel Commane (University of Reading), Richard Weightman Any enquiries related to this output should be addressed to GMO@efsa.europa.eu Suggested citation: ADAS, 2015. Strategy support for the Post-Market Monitoring (PMM) of GM Plants: review of existing PMM strategies developed for the safety assessment of human and animal health. EFSA supporting publication 2014:EN739, 117 pp. Available online: www.efsa.europa.eu/publications © European Food Safety Authority, 2015 Strategy support for the Post-Market Monitoring of GM Food and Feed Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. EFSA supporting publication 2015: EN-739 2 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed SUMMARY BACKGROUND AND METHODOLOGY Commission Implementing Regulation (EU) No 503/2013 on applications for authorisation of genetically modified (GM) food and feed legalised the requirement for a Post-Market Monitoring (PMM) plan if the outcome of the risk assessment has identified a need to do so. Three specific examples are given in this Regulation: 1) when the GM food or feed has altered nutritional composition; 2) when the nutritional value of the GM food or feed differs from the conventional ones; 3) when there is a likelihood of increased allergenicity due to the genetic modification. The aim of this project was to identify strategies, and existing monitoring or surveillance data that are collected in the EU, and provide recommendations to assist with the development of EFSA guidance for applicants on the design of PMM plans. The project consisted of two main work packages focussed on gathering evidence, and a third work package which consisted of a discussion on how PMM could be conducted in the EU using existing data sources and the methods currently available. The methodology for WP1 and WP2 are detailed below. WP1 – Systematic review of existing monitoring programmes The aim of this work package was to carry out a review of existing PMM programmes used to monitor human and animal health. In this work package the principles of a systematic review methodology were used to; search for, screen and present results of papers for inclusion. The review took into account all PMM programmes, including, those for food, feed, human and animal health. Specifically, programmes identified had a focus on either quantifying consumption of the product being monitored, or identifying adverse/expected effects. The review used structured search criteria, which were developed in ‘Scopus’, the largest abstract and citation database of peer-reviewed literature. The search terms were then used in both ‘Scopus’ and ‘Web of Knowledge’ which returned a total of 3,809 records. The team then applied rigorous selection criteria in two stages, a stage one based on the title and abstract of the paper only, and a stage 2 based on a review of the full paper. Stage 1 reduced the total number of papers to 513 and Stage 2 reduced the total number of papers to 164. Final papers (164) were reviewed in a MS Excel database based on key descriptors relating to the design of programme and summarised in a discussion of results in the final report. WP2 – Inventory of data collection methodologies The objective of Work Package 2 was to identify and review existing survey, monitoring or surveillance programmes for food, feed, human and animal health that may inform the design of a PMM system for GM food or feed. The types of programmes reviewed included existing networks and data sources on food and feed consumption, and animal and human health. Initially, informal consultation was conducted to get an initial appreciation of the types of data collection programmes that may be available, and to direct an internet based search. WP1 SYSTEMATIC REVIEW RESULTS The vast majority of the papers obtained through the systematic review process of existing monitoring programmes were those related to Pharmacovigilance, the name given to the monitoring of adverse effects of medical drugs. Three main stages of Pharmacovigilance were identified through the systematic review; data collection, signal detection/evaluation and the reporting of the signal. In Pharmacovigilance data can be collected both actively and passively. Active surveillance describes EFSA supporting publication 2015: EN-739 3 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed methods where the operator instigates work such as conducting questionnaires/interviews with patients or conducting post-clinical trials. Passive surveillance utilises spontaneous reporting systems to pick up on unintended effects of drugs in general, using mediums such as consumer care lines and healthcare professional reporting card schemes e.g. the yellow card system operational in the UK to link adverse effects to specific products. Passive surveillance schemes are easier to conduct than active ones as frameworks for collecting data are already operational in many countries. However, many have criticised this approach due to large scale under reporting of adverse effects by the general public and healthcare professionals and a lack of consistency of information recorded between countries. Active surveillance methods allow for the monitoring of multiple outcomes within the same scheme, and will capture adverse effects even if there is a delay between consumption and the event. The clear disadvantage of active methods are their resource intensive nature. Similar schemes to Pharmacovigilance operate, albeit at a smaller scale for vaccines (Vaccinovigilance) and cosmetics (Cosmetovigilance). These schemes are similar in design to Pharmacovigilance, with country based systems for reporting adverse effects. Monitoring schemes are established in some countries for herbal medicines to understand adverse effects, particularly when they are used in combination with other drugs. Currently, monitoring largely occurs in countries such as Germany where herbal medicines are regulated in the same way as other medicinal drugs (not ‘over the counter’), and thereby their use can be accurately known. Novel foods are the group of products in the literature that have the most applicability to the PMM of GM food and feed. PMM of novel foods is a useful method to clarify expected exposure to the novel food, or novel food ingredient in ‘real world’ populations. PMM of novel foods takes two distinctive steps, 1) clarifying the expected consumption of the food, and 2) identifying adverse effects. Methods of PMM in novel foods have typically employed a combination of active and passive surveillance methods. Active surveillance takes the form of cohort and case-control trials and consumption questionnaires, while passive surveillance utilises spontaneous reporting systems largely via consumer care lines included on the products in question. As the consumer care line is used to report any feedback on the product such as customer complaints, many of the reports received on these lines relate to complaints about the product (such as standards of packaging or organoleptic qualities) rather than reports of adverse health effects from consumption of the product. Our review found that PMM for animal feeds or veterinary products is an unexplored area, with comparatively little focus in the literature. Pharmacovigilance for veterinary medicines operates in a similar way to that for human drugs, however, individual animal owners are encouraged to report adverse effects to a local veterinarian who in turn reports adverse effects. WP2 INVENTORY OF DATA COLLECTION SOURCES RESULTS The overall objective of Work Package 2 was to identify and describe programmes (survey, monitoring or surveillance) that would be relevant for PMM of GM food and feed. The work package majored on food composition and consumption data, as many networks designed to understand adverse effects are covered by the programmes described in WP1. Our analysis started by investigating the extent to which the existing regulatory framework on traceability and labelling may allow a user to understand which GM traits are included in food and feed products. Traceability legislation under Regulation (EC) 178/2002 requires Food Business Operators (FBOs) to understand who products/ingredients are supplied from, and who they are sold to (unless the customer is the end consumer). For GMOs, all products containing, consisting of or produced from GMOs must be positively labelled to indicate their presence. Crucially, these requirements do not require the operator to know exactly which GM trait(s) is included in the product. The system of unique identifiers does require that materials ‘consisting of or containing GMOs’ are labelled with the specific code, but this EFSA supporting publication 2015: EN-739 4 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed is not required once those materials are further processed, to constitute a product which is ‘produced from GMOs’. This is for example the case where GM soybeans (the raw material) would be further processed into soybean oil (an ingredient); where soybeans consist or contain a GMO, and soybean oil is produced from a GMO. Our analysis shows that the food and feed supply chains are complex, and ‘tracking’ GM traits through the chain is difficult, and is not supported fully by regulatory requirements. Current food and feed composition data held at the Member State level does not identify the GM components of a product, and are based on mean nutrient values for a range of products. Privately available food composition data, such as that held by grocery retailers, food or feed manufacturers is variable. For grocery retailers with ‘own-branded’ goods, data are held on provenance of the product, but the level of information varies by product (for example more data are held on primary produce than further processed products). Detailed food composition data may be held by the manufacturers: However, the level of detail of this, above and beyond minimum labelling requirements, is uncertain. For feed, composition data may be held by large feed manufacturers on specific products: However, this information is usually commercially sensitive and thus information is not held by the livestock producer/owner. Individual farmers will understand what they have fed to their livestock as a group, however, this information is largely held on a herd rather than an individual animal basis. Additionally in Europe, the least cost ration formulation system for formulation of compound feeds, means that the actual composition of a feed product may vary from batch to batch. Therefore, even if the concentration of the GM trait was constant, the proportions of other ingredients will probably be varying over time, meaning it would be difficult to convincingly attribute adverse effect solely to the GM trait in question. Food consumption data exists in the EU at the national level by Member States (MS), and provides good detail on foods consumed by a selectively representative sample of the population. Data are gathered, classified by broad food group such as ‘white bread’ or ‘fruit’. Therefore in order for the data to be useful for PMM of GM food and feed, more detail would be required on the specific food products monitored to understand which ones contained specific GM traits. Of more value in the context of PMM are the food purchase data collected by grocery retailers and market research companies. In the UK, market research companies use sample households to record food purchases using handheld barcode scanners. The scanners contain nutritional data on 100,000 food products, either branded by manufacturers or own-brand retailer goods. Data on food purchases are also held by retailers where consumers use a loyalty card scheme but these only reflect what is purchased at that particular retailer, meaning it is of limited value for obtaining representative data across a whole population. For the data collected by market research companies, demographics on the makeup of the household are collected, however, exact consumption of the food by family member is not recorded. For feed, no equivalent consumption database exist such as they do for food. Consumption data in the form of feeding records may be held by individual livestock owners such as farmers. However, no initiatives were found during this project that attempted to gather such information on livestock feeds. Determining consumption data by individual animal may be possible for certain species, such as dairy cows where individual feed intakes are recorded electronically. WP3 DISCUSSION AND CONCLUSIONS The project has shown that the largest barrier to conducting PMM for GM food and feed is the ‘unrecognisable’ nature of the GM trait further down the food supply chain. That is, GM food and feed is sold and branded as a seed to farmer/growers to be passed through, an often complex supply chain before being included in food or feed products often as refined ingredients. Through this supply chain the raw material has the potential to be mixed with other similar GM food or feed, or other conventional ingredients (such is the case with vegetable oils where there may not be one distinct EFSA supporting publication 2015: EN-739 5 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed source of raw material). The regulatory framework for traceability and labelling on GM traits is such that the unique identifiers prescribed to traits are no longer required once the substance is not considered to contain the Living Modified Organism, and thus lost once the raw material is further processed into an ingredient. The likelihood of being able to identify the GM trait after this point rests in its visibility to users further downstream. We suggest that GM food and feed which has a specific identity or brand would be far easier to monitor than those that are less recognised further downstream. For example, Implementing Regulation 503/2013 details that GM traits that have a ‘higher likelihood of allergenicity’ require PMM, however, if these traits are agricultural/input and primarily benefit the farmer/grower then it is unlikely they would be recognised on a specific trait level after further processing. Food purchase data held by market research companies and grocery retailers holds promise as a method to monitor consumption of GM food within a smaller sample size. The main barrier to this is the extent to which this type of data is collected throughout the EU, as our investigations show this is not in operation in all EU Member States. Widespread data on feed consumption is not generally available, and if held is often at an individual farm level. The methodologies reported for detecting adverse effects and validating expected effects of products such as drugs, cosmetics and novel foods provide a good basis for designing a system which would work for GM food and feed, if reliable consumption and composition data were known. Of all the examples presented, PMM programmes for novel foods are the most relevant for GM food and feed. These examples used a combination of approaches, such as spontaneous reports through consumer care lines (passive surveillance) through to initiated cohort studies to test the occurrence of reported effects in order to determine the relevance to the product in question. The project has found a large knowledge gap regarding monitoring for adverse effects in terms of animal health. Veterinary Pharmacovigilance is a new area of focus, and as such experience to date is limited. Overall, it is clear that for a robust system of PMM to work, co-operation throughout the supply chain would be required. For PMM of GM traits to work, in many cases an applicant company would need the co-operation and resource of the final marketer of the product (be it food manufacturer, grocery retailer or feed manufacturer) to co-ordinate monitoring of final product use and detection of effects in the final consumer/user. We conclude that widespread PMM of GM food and feed across multiple populations and for all products containing the trait is unlikely to be possible within the confines of existing data collected and EU regulatory frameworks. Nevertheless, PMM may be possible on a small scale for products in which the GM trait is known to be included, where consumption data exists or could be generated and frameworks exist which could be used to monitor spontaneous reports of adverse effects (e.g. customer care lines). What would be required to conduct PMM of GM food and feed in the EU Based on the findings from this project the following changes/items would be required to conduct PMM of GM food and feed in the EU according to the requirements of Implementing Regulation 503/2013. Greater detail in requirements for traceability of GMOs- This project has shown that current traceability requirements only require the operator to detail which traits are in which batches of raw material, ingredients or products up until the point that it is further processed to become an item ‘produced from GMOs’ (i.e. not containing the LMO). In order to accurately know which traits are included in which final product, the unique identifier would be needed to be carried through the supply chain to this stage. A database of which GM food and feed products contain which GM traits, and at what proportion- In order to accurately measure consumption of GM traits the user would need to understand in what EFSA supporting publication 2015: EN-739 6 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed quantities they are present in the final products. This would require a database (or similar) of products which contain GM traits, and at what level they are included in the product. Consumption data at the branded product level- To accurately monitor consumption of particular GM traits, robust data would be required for all branded products which contain the trait. This would likely need to involve those further down the supply chain who are the ultimate vendors of the product (whether food or feed). A system for reporting the relevance and intensity of effects and unintended effects- Under the requirements of Implementing Regulation 503/2013 the user must identify the relevance and intensity of intended and adverse effects which are detected during the pre-market risk assessment. Approaches such as the passive surveillance of novel foods using consumer care lines, and active surveillance with initiated studies may be useful to identify the relevance and intensity of intended or unintended effects of GM traits highlighted during the risk assessment. An agreement on who is responsible for carrying out PMM- For PMM of GM traits to work, in many cases an applicant company would need the co-operation of the final marketer of the product, (be it food manufacturer, grocery retailer or feed manufacturer) to co-ordinate monitoring of use and detection of effects in the final consumer/user. For PMM of GM traits to work, agreement would be needed on who is responsible for PMM, and who would pay. PMM METHODOLOGIES CURRENTLY FEASIBLE IN THE EU Less detailed monitoring Determining which products contain which GM traits, and at what proportion, as well as calculating robust consumption figures are major difficulties in conducting a PMM programme. Less detailed monitoring could be carried out based on import figures of GM traits as raw materials, or ingredients into the EU. These figures could be matched with data on the quantity of generic products such as vegetable oil consumed in the EU, including figures on the quantities of different oils consumed to give an indication of the total amount of the GM trait consumed. This type of monitoring is foreseen to be possible within the constraints of existing data collected within the EU, and whilst it may not comprehensively meet all the requirements of Implementing Regulation 503/2013, could provide knowledge as a starting point. Small scale monitoring of GM traits If large scale monitoring of all food and feed products containing GM traits was seen as unfeasible, small scale monitoring of a selection of ‘reference’ products could be carried out. This system could utilise a selection of products where robust information is held on their composition (the particular GM traits included and at what proportion), and their consumption. Data, such as that collected by market research agencies using hand held scanners in sample households could be used for this purpose. EFSA supporting publication 2015: EN-739 7 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed TABLE OF CONTENTS Abstract .................................................................................................................................................... 1 Summary .................................................................................................................................................. 3 Table of contents ...................................................................................................................................... 8 Background as provided by EFSA ......................................................................................................... 10 Terms of reference as provided by EFSA .............................................................................................. 10 Definitions .............................................................................................................................................. 11 Introduction and Objectives ................................................................................................................... 12 1.1. Introduction ........................................................................................................................... 12 1.2. Scope ..................................................................................................................................... 13 Materials and Methods ........................................................................................................................... 13 2. Work Package 1- Review of existing Post-Market Monitoring programmes ................................ 13 2.1. Scope and Search Terms ....................................................................................................... 13 2.2. Selection Criteria .................................................................................................................. 14 2.3. Gate 1 Review ....................................................................................................................... 15 2.4. Gate 2 Review ....................................................................................................................... 15 2.5. Analysis, Presentation and Collation of Results ................................................................... 17 3. Work Package 2- Inventory of data collection methodologies ...................................................... 17 3.1. Identification of programmes ................................................................................................ 17 3.2. Analysis of programmes ....................................................................................................... 17 Results .................................................................................................................................................... 18 4. Work Package 1- Review of Existing Post-Market Monitoring Programmes: discussion of literature review results .......................................................................................................................... 18 4.1. Pharmacovigilance ................................................................................................................ 18 4.1.1. Data Collection ................................................................................................................. 18 4.1.1.1. Active Surveillance .................................................................................................. 18 4.1.1.2. Passive Surveillance................................................................................................. 20 4.1.1.3. Combined Surveillance Methods ............................................................................. 21 4.1.2. Signal Evaluation and Causality Assessment ................................................................... 21 4.1.3. Signal Reporting ............................................................................................................... 22 4.2. Vaccinovigilance................................................................................................................... 22 4.3. Cosmetovigilance.................................................................................................................. 23 4.4. Herbal Medicines .................................................................................................................. 23 4.5. Veterinary Pharmacovigilance .............................................................................................. 25 4.6. Monitoring of Novel Foods .................................................................................................. 26 4.6.1. Food and Nutrient Intake Assessments............................................................................. 27 4.6.2. Assessment of Reported Adverse Events ......................................................................... 27 4.7. Summary of existing monitoring programmes ..................................................................... 30 5. Work Package 2 - Inventory of data collection methodologies to assess food consumption/composition and human and animal health ...................................................................... 33 5.1. Regulatory requirements for traceability and labelling ......................................................... 33 5.1.1. Traceability requirements ................................................................................................. 33 5.1.2. Specific requirements for GMOs ...................................................................................... 34 5.2. Assessment of food consumption ......................................................................................... 35 5.2.1. Food consumption data collected by member states and third countries.......................... 35 5.2.1.1. Data held by retailers/supermarkets ......................................................................... 36 5.2.1.2. Data held by market research companies ................................................................. 37 5.2.1.3. Data collected by private food manufacturers ......................................................... 37 5.2.2. Current data gaps to calculate food consumption ............................................................. 40 EFSA supporting publication 2015: EN-739 8 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed 5.3. Assessment of feed consumption .......................................................................................... 40 5.3.1. Feed consumption data ..................................................................................................... 40 5.3.2. Current data gaps to calculate feed consumption ............................................................. 40 5.4. Assessment of food composition .......................................................................................... 41 5.4.1. Publicly available food composition data ......................................................................... 41 5.4.2. Privately available food composition data ........................................................................ 41 5.4.2.1. Food retailers ........................................................................................................... 41 5.4.2.2. Foodservice operators .............................................................................................. 42 5.5. Assessment of feed composition ........................................................................................... 42 5.5.1. Feed composition data ...................................................................................................... 42 5.6. Determining the inclusion of GM food and feed in products ............................................... 43 5.6.1. GM varieties used as feed ................................................................................................. 44 5.6.2. GM varieties used as food ................................................................................................ 45 5.7. Data to understand adverse effects........................................................................................ 46 5.7.1. Animal health reporting schemes ..................................................................................... 46 5.7.2. Human health reporting schemes...................................................................................... 47 6. WP3 - The ability to conduct Post-Market Monitoring of GM food and feed in the EU .............. 48 6.1. Requirements under Commission Implementing Regulation (EU) No 503/2013 ................ 48 6.2. GM traits that would require monitoring .............................................................................. 49 6.3. What is required for Post-Market Monitoring of GM food and feed .................................... 51 6.4. Monitoring consumption or use of a GM food or feed in either animals or humans ............ 51 6.4.1. Inclusion of a GM trait in food or feed products .............................................................. 51 6.4.2. Food and feed consumption data ...................................................................................... 52 6.5. Monitoring the relevance and intensity of effects and unintended effects detected during the pre-market risk assessment ................................................................................................................ 53 Conclusions ............................................................................................................................................ 54 7. What would be required to conduct PMM of GM food and feed in the EU.................................. 55 7.1. Greater detail in requirements for traceability of GMOs ...................................................... 55 7.2. A database of which food and feed products contain which GM traits, and at what proportion........................................................................................................................................... 55 7.3. Consumption data at the branded product level .................................................................... 55 7.4. A system for reporting the relevance and intensity of effects and unintended effects.......... 56 7.5. An agreement on who is responsible for carrying out PMM ................................................ 56 8. PMM methodologies currently feasible in the EU ........................................................................ 56 8.1. Less detailed monitoring ....................................................................................................... 56 8.2. Small scale monitoring of GM traits ..................................................................................... 57 References .............................................................................................................................................. 58 Appendix/Appendices ............................................................................................................................ 69 Appendix A. WP1 Paper Review Table........................................................................................... 69 Glossary of abbreviations ..................................................................................................................... 117 EFSA supporting publication 2015: EN-739 9 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed BACKGROUND AS PROVIDED BY EFSA According to the Article 22 of the EFSA‟s Founding Regulation, “The Authority shall contribute to a high level of protection of human life and health, and in this respect take account of animal health and welfare, plant health and the environment, in the context of the operation of the internal market” and “The Authority shall collect and analyse data to allow the characterisation and monitoring of risks which have a direct or indirect impact on food and feed safety”. The EFSA’Science strategy 20122016’ recognises “an increasing trend for risk assessments to include assessment of issues that require a marked broadening of the scientific discourse, such as environmental impacts, occupational health, post-market monitoring, risk comparisons and health benefits”. EFSA performs a centralized risk assessment for food and feed products derived from genetically modified (GM) plants in the European (EU). The EFSA Guidance of the GMO Panel for risk assessment of food and feed from GM plants3 (published in 24 May 2011) indicates that the proposal for a PMM should be a hypothesis-driven scientific exercise, but does not provide detailed guidance on how to set up a PMM in practice. Very recently the Commission Implementing Regulation (EU) No 503/2013 on applications for authorisation of genetically modified food and feed4 (published in 8 June 2013) legalised the requirement of a proposal for Post-Market Monitoring (PMM) plan for the use of food and feed derived from genetically modified (GM) plants, if the outcome of the risk assessment has identified a need to do so. Three specific examples are given in this Regulation: 1) when the GM food or feed has altered nutritional composition; 2) when the nutritional value of the GM food or feed differs from the conventional ones; 3) when there is a likelihood of increased allergenicity due to the genetic modification. To implement the Regulation (EU) No 503/2013 in the risk assessment for GM food and feed, EFSA is launching an open call for tenders to deliver a consolidated review, “Strategy support for the Post Market Monitoring (PMM) of GM plants for the use as food or feed: Review of existing PMM strategies and methodologies developed for the safety assessment of human and animal health”. The review will identify strategies and data collection methodologies useful for further EFSA guidelines on PMM plans for GM food and feed. The output of this procurement will be delivered within 12 months from its inception, and will be published as an External Scientific Report on the EFSA website. TERMS OF REFERENCE AS PROVIDED BY EFSA This contract/grant was awarded by EFSA to: ADAS UK ltd Strategy support for the Post-Market Monitoring (PMM) of GM plants: Review of existing PMM strategies developed for the safety assessment of human and animal health Contract/grant number: OC/EFSA/GMO/2013/03 This call seeks a review on existing PMM programs in the EU and worldwide, and to analyse strategies and methodologies for data collection and collation. The review will investigate the 3 http://www.efsa.europa.eu/en/efsajournal/pub/2150.htm http://eur-lex.europa.eu/JOHtml.do?uri=OJ:L:2013:157:SOM:EN:HTML EFSA supporting publication 2015: EN-739 4 10 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed feasibility of transferring existing knowledge on PMM in areas other than GMOs such as novel foods or feed additives that are relevant for the safety assessment of human and animal health. DEFINITIONS Raw material- refers to the primary produce from a farm-gate, such as ‘soybeans’ or ‘rapeseed’ Ingredient- refers to a component part of a final product, or a further processing of a raw material. Examples include soybean oil or flour. Product- refers to a finished food or feed product composed of a number of ingredients which is purchased by consumers or animal owners. EFSA supporting publication 2015: EN-739 11 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed INTRODUCTION AND OBJECTIVES 1.1. Introduction Genetically modified plants have been commercially cultivated and used across the world since 1996, reaching a hectarage of 160 million in 2011 (James 2012) . For any genetically modified organism (GMO) to be authorised for food and feed use, in the European Union (EU) market, an independent safety assessment must be made by the European Food Safety Authority (EFSA) GMO Panel. The safety assessment guidance provided by EFSA GMO panel, is used by risk managers from the European Commission and Member States when deciding on market approval for a product5. Pre-market risk assessment of GM food and feed is a robust process, however exposure assessment may never be able to predict or reproduce the diversity of populations who may consume the final product. Recently, the Commission Implementing Regulation (EU) No 503/2013 legalised the requirement for Post-Market Monitoring of GM food and feed. Principally it is envisaged that PMM would only be required in cases where the GM food and feed has an altered nutritional composition; when the nutritional value of the GM food or feed differs from the conventional one; and when there is an increased likelihood of allergenicity due to the genetic modification. To date, few applications for approval of food or feed from GMOs have included a plan for PMM, as the majority of GM plants approved for authorisation, within the EU, are those with simple agronomic ‘input’ traits such as herbicide tolerance, or insect resistance. Typically food and feed derived from these GM plants would not require a PMM plan, however, new ‘novel’ GM plants with quality/output traits such as: maize with high lysine (LY038) for use as animal feed, soybeans with modified fatty acid structure (such as MON87705) and rice with high vitamin A content (Golden Rice), are likely to require a PMM plan and at this stage no specific guidance exists on how this should be conducted. The overall objective of the project was to review PMM programmes in the EU and worldwide, and to analyse strategies and methodologies for data collection and collation in order to provide recommendations for PMM methodologies which could be adapted/adopted for the safety monitoring of GM food and feed in the EU. The work was separated into three distinct work packages looking at reviewing existing PMM methodologies, determining potential food consumption data sources and providing recommendations for specific guidance on the PMM of GM food and feed within the EU. The relevant titles of the work packages from the original tender document are found below. Work Packages: 1. Review existing PMM programmes in the EU and worldwide 2. Provide an inventory of data collection methodologies to assess food/feed consumption/composition and human/animal health 3. Provide recommendations for PMM of GM food and feed in the EU 5 See http://www.efsa.europa.eu/en/efsajournal/pub/2150.htm EFSA supporting publication 2015: EN-739 12 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed 1.2. Scope The scope of the report covered existing Post-Market Monitoring strategies, on a global scale, for all products related to human and animal health, food and feed. Any programmes monitoring environmental impacts or medical devices were excluded as they are not relevant to adverse effects related to consumption. MATERIALS AND METHODS 2. WORK PACKAGE 1- REVIEW OF EXISTING POST-MARKET MONITORING PROGRAMMES In this work package the principles of a systematic review methodology were used to; search for, screen and present results of papers for inclusion. The objectives of this work package were to review existing Post-Market Monitoring programmes with specific emphasis on: 1. Distinguishing programmes from an EU and a non-EU country; 2. Distinguishing the product in question as either a food or feed, or a non-food or non-feed product; 3. Distinguishing between general surveillance for adverse events/effects from case-specific monitoring (where a specific hypothesis has been identified); 4. Distinguishing between mandatory and voluntary monitoring schemes. 2.1. Scope and Search Terms This review has taken into account all Post-Market Monitoring programmes, including, those for food, feed, human and animal health. Programmes identified had a focus on either quantifying consumption of the product being monitored, or identifying adverse/expected effects. Programmes that monitored impacts on the environment, or any aspect not related to consumption such as medical devices, and their effects on humans and animals were excluded. Search criteria were developed and then tested in Scopus, the largest abstract and citation database of peer-reviewed literature from multiple disciplines, and then searched for in the ‘Scopus’ and ‘Web of Science’ databases. This allowed qualification of whether the number of results returned were similar across multiple databases and thus if our keywords were suitable in picking up the breadth of literature that was available. Search criteria were arranged into four main levels; 1. Terms which defined the types of programme focused on i.e. post-market or post-launch monitoring rather than more general monitoring. 2. Additional terms which highlighted records referring to specific programmes developed e.g. ‘scheme’ 3. Terms that defined the scope of programmes e.g. ‘food’ 4. Terms that defined the purpose of the monitoring programme e.g. ‘intake’ EFSA supporting publication 2015: EN-739 13 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Below is the structured search string which was used to search academic, and peer reviewed literature in ‘Scopus’ and ‘Web of Science’. TITLE-ABS-KEY("Post-market" OR "Post Launch" OR "post-market surveillance" OR "post launch surveillance" OR Pharmacovigilance OR Cosmetovigilance OR "postmarketing") AND TITLE-ABS-KEY(strategy OR scheme OR plan OR programme OR initiative OR method OR design) AND TITLE-ABS-KEY(food OR feed OR "animal feed" OR drug OR cosmetic OR product OR gmo OR gm OR "genetically modif*" OR "herbal remedies" OR commodity) AND TITLE-ABS-KEY("human health" OR "animal health" OR intake OR consumption OR exposure OR risks OR consumer OR "public health" OR outcome OR impact OR allergen* OR immunolo* OR authenticity) This search yielded 3,258 results in Scopus and 3,791 results in Web of Science, correct as of 13/03/2014 for Scopus and 18/03/2014 for Web of Science (as numbers of results will change when new publications are released). The number of results returned by both databases were comparable, and the results from each database were exported to Endnote separately, and later combined into a final database, with any duplicates identified by Endnote removed. The combined database contained 3809 results. 2.2. Selection Criteria A two stage process was used to select papers for review, using the same criteria at each stage. Stage 1 termed ‘Gate 1 Review’ reviewed papers for inclusion based on their title and abstract (where available) only. Full text articles were acquired for papers passing the Gate 1 Review and also for those for which an assessment could not be made based on the title or abstract alone. Stage 2 termed the ‘Gate 2 Review’ used these same selection criteria, on the full text articles to select final papers for analysis. Table 1: Selection criteria for Gate 1 and Gate 2 Reviews Must answer YES to one or more of the appropriate inclusion values. Screening Questions Inclusion values Question Does study refer to monitoring consumption/intake or adverse/beneficial effects on Yes consumers or animals? Does study focus on a specific example, or give specific guidance on how a PMM programme Yes should be conducted? Does the study outline/describe PMM methodologies used? Yes Abstract in English Yes Study aims to monitor medical devices No Study aims to monitor environmental impacts. No Study focusses on outcomes of a monitoring programme, rather than design of the programme No itself. EFSA supporting publication 2015: EN-739 14 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed 2.3. Gate 1 Review To conduct the Gate 1 Review two researchers independently reviewed, using Endnote, all 3809 references, based on their title and abstract (where available). References were reviewed independently, to avoid the possibility of either consultant influencing the other’s decisions. The Endnote results were exported into a separate Microsoft (MS) Excel document, and once a reference was reviewed, the decision was noted in the MS Excel file. MS Excel was used in this instance, for ease of use over Endnote. References were coded via the following system: Table 2: Gate 1 Review Reference Coding System Code Meaning Y Yes Fits inclusion criteria so through to Gate programme/element of programme mentioned N No Not relevant so excluded from Gate Review 2 M Maybe Unable to make an assessment based on available information, so through to Gate Review 2 R Review Fits inclusion criteria so through to Gate Review 2, usually non-specific D Duplicate Result missed during Endnote duplicate finding process 2 WP2 Not relevant to work package 1, but potentially relevant to work package 2 Review 2- specific Once all references had been reviewed by both consultants a TRUE or FALSE analysis, an example is given below, was carried out in MS excel to compare the results. Table 3: Example MS Excel True or False Calculation =$D2=$C2 TRUE For those results that did not match and would therefore appear FALSE, the abstract was re-read and discussed by both consultants and either a joint decision was reached on the outcome or a third party reviewer was used to decide the outcome. Of the initial 3809 results, this left 513 references to go through to the Gate 2 Review. 2.4. Gate 2 Review The 513 papers identified after the Gate Review 1 were collected via a number of methods. Firstly databases such as; Science Direct and Springer Link were searched for journals and access permitting EFSA supporting publication 2015: EN-739 15 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed papers were downloaded. Where an email address for authors could be found on Scopus, an email was sent to ask for a copy of their paper. Once the papers had been gathered they were screened against the selection criteria again, although this time the full paper was read. If papers were considered irrelevant a note was made of the reasoning and inputted into the Endnote database and the paper was removed from the analysis. Of the 513 papers from the Gate 1 Review, 164 were relevant. Relevant papers were distributed between five separate reviewers for analysis. Papers that were not in English, could not go through to the analysis stage without translation and have, at this stage, not been included in the analysis. A total of 34 papers collected during this process were not in English. The flow diagram in Figure.1 details the systematic review process. Figure 1: Flow diagram of systematic review process EFSA supporting publication 2015: EN-739 16 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed 2.5. Analysis, Presentation and Collation of Results The papers that passed the Gate 2 Review were then reviewed and results collated. Papers were distributed between five reviewers, where papers were re-read and data extracted and inputted into an MS Excel spreadsheet. The results spreadsheet (see Appendix 1) allowed key methodological steps of the Post-Market Monitoring methodology used, to be extracted. For example column headings included; active vs. passive surveillance, mandatory vs. voluntary schemes, strengths and weaknesses of methods and responsibility for reporting/monitoring. Once data were extracted, key themes were drawn out and have been summarised in the results section below. 3. WORK PACKAGE 2- INVENTORY OF DATA COLLECTION METHODOLOGIES The objective of Work Package 2 was to identify and review survey, monitoring or surveillance programmes for food, feed, human and animal health that may be suitable sources of data for a PMM system for GM food or feed. This work package did not cover existing monitoring programmes as this is covered under WP1. The emphasis of Work Package 2 was to understand the feasibility of undertaking PMM for GM food and feed in Europe based on what data are currently collected. 3.1. Identification of programmes A combination of literature and web searching, with informal consultation was used to identify data collection programmes that would be relevant to the PMM of GM food and feed in the EU. The scope of programmes that may be covered under this work package was kept broad, as it was recognised that a PMM system in the EU may need to make use of multiple sources of data to be successful. The types of programmes reviewed included existing networks and data sources on food and feed consumption, and animal and human health. Initially, informal consultation was conducted to get an initial appreciation of the types of data collection programmes that may be available, and direct the internet based search. Consultation was conducted with academic institutions, those in the food industry and animal feed industries, and stakeholders from public institutions. Given the sensitivity of the topic we have kept all names confidential. After this consultation a web-based search, using search engines was conducted to source details on relevant programmes. For the purpose of this exercise, key search terms were not used due to the flexibility needed to find all possible programmes which may operate under different names (e.g. use company names, or have specific product names). Much of the information in this area is not documented or is confidential (such as grocery retailers approaches to traceability in their supply chains) and as such a large proportion of the evidence presented is based on the personal communications described above. 3.2. Analysis of programmes Data collection programmes sourced are described in the results section below. The programmes presented are only those relevant to the PMM of GM food and feed. EFSA supporting publication 2015: EN-739 17 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed RESULTS 4. WORK PACKAGE 1- REVIEW OF EXISTING POST-MARKET MONITORING PROGRAMMES: DISCUSSION OF LITERATURE REVIEW RESULTS The greatest number of abstracts and papers obtained were on Pharmacovigilance, followed by papers on Vaccinovigilance and statistical signal detection/evaluation methods e.g. disproportionality analysis. In 1968 the World Health Organisation (WHO) set up the Programme for International Drug Monitoring (PIDM) and since then many reports have been published with updated methodologies for monitoring of drugs in a post-market setting (Mahmood 2011). Although Pharmacovigilance is the oldest example of a Post-Market Monitoring scheme, there are a number of other similar initiatives that are currently undertaken globally, these include; Cosmetovigilance and Vaccinovigilance. PostMarket Monitoring of novel foods and herbal medicines are emerging sectors and therefore a limited number of papers regarding these topics are available. Another important area of research identified in the literature search were nutritional/food intake studies. Within the scope of our keywords there were a limited number of papers on nutritional uptake, as these often do not follow traditional Post-Market Monitoring methodologies. Of the results returned from the literature review there were more papers regarding human health, with very few relevant animal health studies identified. Each of the above schemes/studies are discussed in more detail below with common methodologies noted. The full list of reviewed results can be found in Annex x. 4.1. Pharmacovigilance Pharmacovigilance is defined by Talbot and Nilsson (1998) as, ‘the process of identifying and responding to drug safety issues’. The major aim of Pharmacovigilance is the discovery of new or rare Adverse Drug Reactions or (ADRs). Three main stages of Pharmacovigilance have been identified through the systematic review; data collection, signal detection/evaluation and the reporting of the signal (Bhosale & Gaur 2011). 4.1.1. Data Collection Data collection in Pharmacovigilance monitoring schemes can be split into two distinct categories; active and passive surveillance. Active surveillance for ADRs is that which is purposefully initiated, usually by the manufacturer of the drug to be monitored and can include work such as conducting questionnaires/interviews with patients or post-clinical trials. Passive surveillance utilises spontaneous reporting systems to pick up on unintended effects of drugs in general, using mediums such as consumer care lines and healthcare professional reporting card schemes e.g. the yellow card system operational in the UK to link adverse effects to specific products. 4.1.1.1. Active Surveillance The use of active surveillance methods, or surveillance which is purposefully initiated, for monitoring drugs and medicines has been gaining popularity with manufacturers over the last 20-30 years (Kay 1983, Talbot & Nilsson 1998 and McNeil et al. 1999), as further problems with drugs were discovered after the thalidomide tragedy6 (Waller & Evans 2003) and new methods of surveillance were felt to be 6 Thalidomide was used to treat nausea in pregnant women during the 1950-60s. There was limited or no preclinical/post-clinical testing of the drug, so when it reached the market the severity of side-effects had not been 18 EFSA supporting publication 2015: EN-739 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed necessary. There are a number of different simple trial designs to monitor adverse drug reactions actively. These include; observational studies e.g. cohort studies and case control studies and large simple safety trials e.g. post-marketing clinical trials (Talbot & Nilsson 1998 and Berlin et al. 2008). Cohort studies involve recruitment of individuals from a specific cohort e.g. all individuals taking a specific drug, and then monitoring the population over time. Case-control studies are retrospective trials comparing people who are taking a drug against those who are not, to assess whether the presence of the drug is causing a certain adverse event. Large simple trials or post-marketing clinical trials involve recruitment of subjects through broad selection criteria, after which they are then randomised for different treatments and any adverse events are recorded against the treatment method. A number of the studies analysed had used active surveillance methods to collect ADR reports. For example; Zancan et al. 2009 describe how they compared spontaneous reporting schemes with a pilot study, taking a more active approach. Three hundred patients were selected, from those discharged from participating hospitals, who were prescribed drugs in the following categories; non-steroidal antiinflammatory drugs (NSAID), oral anticoagulants and antihypertensive drugs. Patients were monitored passively for 6 months after discharge from hospital. Patient/healthcare professional reports were collected via an adverse event reporting phoneline which was accessible 24hr/day. Active surveillance occurred 30 days after discharge, in the form of a structured phone interview, which was completed with all patients who had given informed consent. No calls were made to the free phoneline during the entirety of the study, with data on adverse events collected only via the telephone interviews. Zancan et al. (2009) discussed the advantages of active surveillance finding it to be a useful tool in determining drug safety, but felt that the costs of conducting active surveillance trials, made it hard to foresee widespread usage of this method. Alemayehu et al. 2010, describe a case-control study undertaken in Zanzibar to determine the safety effects of multi-drug administration treatments in a resource constrained setting. They describe how children and adults meeting the eligibility criteria were allocated a treatment randomly based on the village they were from and monitored for reactions. Another example of active surveillance comes in the form of monitoring patients during their stay in hospital. Hospital monitoring of adverse reactions in patients undergoing treatment were reported in Germany, Mexico and India (Kapp et al. 1991, Juarez & Olguin 2007 and Khairnar & Gade 2011). Hospital monitoring schemes involved; increasing awareness of both doctors and patients about Pharmacovigilance and potential adverse reactions, and improving methods for validation of adverse events (Kapp et al. 1991), such as better expert review systems for reviewing adverse reaction reports. This led to improved quality and quantity of adverse event reports (Khairnar & Gade 2011). However, often these results were short-term only (Khairnar & Gade 2011) with further investment and incentives needed to encourage better reporting from the healthcare professionals in the future (Juarez & Olguin 2007 and Khairnar & Gade 2011). The benefits of an active surveillance method over spontaneous reporting, is that active methods will capture adverse events even if there is a delay between consumption and the adverse event (Wood 1991). Active surveillance also allows for the monitoring of multiple outcomes within the same scheme (McNeil et al. 2010). In some cases, cohort study data capture forms are created prospectively, discovered. This led to many babies being born with limb abnormalities and triggered implementation of more rigorous drug safety assessments (Kim & Scialli 2011). 19 EFSA supporting publication 2015: EN-739 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed before the trial begins. This means forms can be tailored so as to capture all relevant data that might later be required (Kay 1983). As with all methods there are limitations. In the main, the limitations of active surveillance are the time and cost it takes to perform (Kay 1983, Wood 1991 and Weaver et al. 2009). Another significant limitation, of active surveillance methods is the assumptions study directors have to make regarding variance between patients. The demographic background of each patient will vary considerably, and yet active surveillance methods have to assume, to a certain extent, that the only difference between patients is whether or not they have taken the drug. Therefore, the event is not always necessarily linked to taking the drug (Berlin et al. 2008). 4.1.1.2. Passive Surveillance Traditionally post-market surveillance has largely been done via passive schemes which utilise spontaneous reporting systems e.g. Consumer care lines and the ‘yellow card system’, for generation of adverse event signals (McNeil et al. 1999, Barnes 2003 and Zancan et al. 2009). Reporting systems vary across the globe, but generally information gathered from patient reporting, to dedicated support care lines, is sent directly from the manufacturer to the regulatory agencies such as the Food and Drug Administration (FDA) and the Medical and Healthcare products Regulatory Agency (MHRA). A more detailed example/case study of a consumer care line is given below in section 4.6.2. Differences in systems of collecting spontaneous adverse event reports becomes more noticeable when looking at national healthcare professional ‘yellow card’ type schemes. In countries such as India, Nepal, Sweden and France (Gogtay 2004, Palaian 2010 Balkrisnan 2001 and Dal Pan 2014) regional adverse drug reaction centres collect data for their region, and this is then sent to a centralised regulatory authority. The situation is different in the US and Germany (Dal Pan, 2014 and Talbot & Nilsson 1998), where reports are usually made directly to the manufacturer, who then informs the regulatory authorities, reducing contact between regulatory authorities and initial reporters. Countries who become members of the World Health Organisation (WHO) Programme for International Drug Monitoring (PIDM) WHO PIDM, will send their ADR reports to the WHO monitoring database ‘Vigibase’, in Uppsala Sweden, which compiles a global list of reported ADRs (Gogtay 2004, Palaian 2010, Dogra 2013 and Dal Pan 2014). Once adverse event data are collected, it must be reviewed. This is often done through crossreferencing to currently available literature on potential associated ADRs and also through statistical analysis. The most commonly used statistical analysis tool is disproportionality analysis. This involves checking the extent to which adverse events are likely to be related to a particular drug over another (Montastruc et al. 2011). Further detail on both literature review and statistical methods of signal evaluation are discussed in 4.1.2. A number of the reviewed papers stated that they believed spontaneous reporting was no longer sufficient to successfully monitor drugs in the post-market environment (Kay 1983, Waller & Evans 2003 and McNeil 2010). This is due to a number of limitations with the spontaneous reporting system, namely; large scale under-reporting of ADRs by the public and healthcare professionals (Inman 1981, McNeil 1991, and Berlin et al. 2008) and a lack of consistency between the information recorded about ADRs within and between countries. E.g. it is common for forms to be lacking required information, making it hard later to define causality (Bennett at al. 2000 and Bandekar et al. 2010). Other disadvantages to spontaneous reporting include; the lack of a control group making it hard to determine whether the adverse event was the result of drug consumption or coincidence (Begaud et al. 1994), and unreliability of the method to detect new, unsuspected or delayed adverse reactions (Talbot & Nilsson 1998, McNeil 1999 and Ahmad 2003). EFSA supporting publication 2015: EN-739 20 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed There are, however, a number of advantages to spontaneous reporting schemes. Spontaneous reporting can start immediately once a product is released and can be continued throughout the lifetime of the product (Talbot and Nilsson 1998, Begaud et al. 1994 and Ahmad 2003 and Ronaldson 2011). Reporting is not restricted to a specific cohort of the population, meaning that spontaneous reporting can allow for the early detection of rare and severe ADRs (Wood 1991 and Ahmad 2003). One of the main drivers for spontaneous reporting stated was that it remains the cheapest method of post-market surveillance in Pharmacovigilance (Begaud et al. 1994 and Ahmad 2003). 4.1.1.3. Combined Surveillance Methods A number of initiatives which aim to combine passive and active surveillance are now in place in Europe, the US, Canada, Australia and New Zealand. Commonly termed ‘Prescription Event Monitoring’ in the reviewed literature, these methods link prescription data to healthcare practitioner adverse event reports (Balkrisnan et al. 2001, Eguale et al 2010, McNeil et al. 2010 and Harpaz et al. 2013). All of the above countries and many more utilise electronic health record databases, with suggestions in the literature to make it mandatory for healthcare professionals to note changes to prescriptions. For example changes to the dose given or the discontinuation of a prescription, with any adverse events recorded on these systems (Balkrisnan et al. 2001 and Eguale et al. 2010). The hope is that this will make it easier to identify the risk and prevalence of ADRs. By noting changes to dose or the discontinuation of a specific drug treatment, the appearance of an ADR might be more easily linked to its potential cause (Dunn & Mann 1999). It is a general consensus among the reviewed papers that a combination approach in terms of data collection is almost certainly going to be the most effective method for Pharmacovigilance in the future. With many papers stating that tailor made Pharmacovigilance plans, depending on the situation, are best (Kelman et al. 2010). 4.1.2. Signal Evaluation and Causality Assessment Once adverse reaction reports have been filed, signals need to be evaluated and assessed for causality. There are generally four main features of assessing causality; time between challenge and adverse event, de-challenge or the impact of stopping treatment, re-challenge or the impact of restarting treatment and whether there are any other possibilities that could have caused the reaction (Bhosale & Gaur 2011 and Sharrar & Dieck 2013). The WHO general categories for separating signals are; Certain (definitely related), Probable/Likely, Possible, Unlikely, Conditional/Unclassified (data are not available, or is too limited to make a judgement) (Mahmood et al. 2011). Many countries have their own classification systems but all are similar to the WHO definitions (Bhosale & Gaur 2011). One initial method often employed to assess causality, is a review of available medical literature to look for similar reactions that have been reported previously (Talbot & Nielsson 1998, Ahmad 2003, Sharrar & Dieck 2013). The method of causality assessment by comparison to historical data, is unlikely to be available for use in GMO monitoring programmes as there is little/no previous literature/knowledge on any known adverse reactions, over and above general intolerances and allergies, otherwise the product would not have received authorisation. Recent technological advances in informatics have led to the development of several statistical tools, each of which can be used to extract data from electronic healthcare databases and look for associations between a drug and any adverse reactions experienced (Theophile et al. 2010 and Gagne et al. 2012). A popular method of data extraction was data-mining and more specifically a type of data-mining called disproportionality analysis. Disproportionality analysis is conducted with a two by two contingency table and can be used to compare the association between drug X and ADR Y. The analysis compares the observed number of reports of ADR Y linked to drug X with the expected EFSA supporting publication 2015: EN-739 21 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed number of reports if there was no association. This then gives a ratio of observed to expected events, on which a chi-squared analysis can be done to test for significance (Montastruc et al. 2011). This involves using statistics to determine if the reporting of a specific adverse event is occurring more frequently than the reporting of other known ADRs for that particular product. During the systematic review a number of the papers reviewed were specifically focussed on establishing new data mining/ statistical algorithms for signal detection (Egberts et al. 2002, Fram et al. 2003, Dasgupta & Scholl 2009, Caster et al. 2010, Fan et al. 2010, Chazard et al. 2011 and Du et al. 2013). Each method was highly detailed but one clear trend that came out of all these papers was that signal detection informatics tools needed to be tailored to the specific need (Gagne et al. 2012). Therefore, signal detection tools are important in the process but each method is not discussed in detail as its use would be limited in relation to monitoring of GM foods and feeds. 4.1.3. Signal Reporting Once signals have been evaluated and causality has been confirmed reports are sent to regulatory authorities or to the manufacturer of the country of origin. Where reports are inputted into a database e.g. AERS, WHO Uppsala Monitoring Database. Electronic forms have made reporting much easier. These systems tend to be lacking in middle to low income countries who still rely on hard-copy reporting forms. This means that there are often physical barriers that prevent timely reporting of adverse events (Olsson et al. 2010). There is a need therefore to bring all systems up to a better standard, which will require significant investment (Olsson et al. 2010). 4.2. Vaccinovigilance The monitoring of adverse events in vaccinations is very similar to the processes used in the monitoring of adverse drug reactions. Many countries operate similar surveillance schemes for both drugs and vaccines e.g. the yellow card scheme in the UK. Some countries e.g. the US, Vaccine Adverse Event Report (VAERS), Canada, Immunisation Monitoring Programme (IMP) and Brazil, National Immunisation Programme (NIP), have specialist centres dedicated to the reporting of vaccine adverse reactions (Davis et al. 2005, Zuber et al. 2009 and Monteiro et al. 2011). There are also a number of international monitoring schemes in place to try and coordinate vaccine safety research. For example the WHO set up the Global Advisory Committee on Vaccine Safety (GACVS) in 1999, to provide countries with timely advice on vaccine safety issues (Zuber et al 2009). The SANEVA network mentioned in the paper by Zuber et al. 2009, is a good example of international cooperation to improve safety surveillance networks. The SANEVA network was created in 2006 between; Argentina, Brazil, Mexico, Panama and Venezuela with the aim to create an adverse event reporting network for Latin American, where training and active surveillance initiatives could be harmonised. This system has been used as a guide for the recently (2012) set up Global Vaccine Safety Initiative (GVSI), which aims to help coordinate global vaccine safety data and Pharmacovigilance trials (Amarasinghe et al. 2013). Methods for data collection in vaccines are the same as for other drugs. Similarly, the consensus from the literature was that, as with drugs, spontaneous reporting of reactions was no longer considered an entirely adequate scheme (DeStefano 2001 and Tatley et al 2008). The majority of papers reviewed on Vaccinovigilance focussed on active surveillance methods, rather than spontaneous surveillance methods, like drug monitoring systems. Apart from the type of surveillance used, the methods themselves differed very little from those of Pharmacovigilance. Davis et al. 2005 and Tatley et al. 2008, discuss prospective cohort study methodologies. The Davis study used data from health maintenance organisations, to simulate a cohort study in children. Using data on adverse reactions in EFSA supporting publication 2015: EN-739 22 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed children before the vaccine was introduced as a control. In Tatley et al. 2008 the authors describe how they monitored children for four weeks after immunisation and recorded all consultations, including suspected adverse reactions. Electronic data linkage similar to prescription event monitoring was also recorded in studies by Farrington et al. 1995 and Destefano et al 2005. 4.3. Cosmetovigilance Methods to assess the causality of adverse reactions to cosmetics has been influenced by past experiences in the pharmaceutical industry (Bons et al 2010). Therefore, adverse reaction monitoring schemes for cosmetics are generally similar to those for drugs, although there tend to be fewer adverse reactions reported in these schemes (Berne et al. 2008). In 2005 the European Cosmetics Association issued guidelines on the management of un-desirable events (Bons et al. 2010), which provided specific Post-Market Monitoring guidance to the cosmetics industry. The guidelines remain very similar to those in place for drugs. Causality assessment criteria and scoring for Cosmetivigilance are similar to those used in Pharmacovigilance (Bons et al. 2010). Currently the only study into improving Cosmetovigilance that the systematic review identified is the study by Berne et al. 2008. The study was carried out in three Swedish dermatology clinics. Patients were enrolled in the study if they were under investigation for potential adverse reactions. Application of different product treatments occurred via patch testing, according to the Finn Chamber technique (Fischer & Maibach 1984). This technique involves application of liquid to a small paper disc which is then stuck to the skin. Patches remained on the skin for 2 days and the area was assessed by dermatologists on day 3 and day 5-7 for signs of adverse effects. Adverse reactions were recorded and assessed for causality (Berne et al. 2008). The WHO causality definitions were used to define causality. The study found that taking a more active approach to Cosmetovigilance could increase the number of adverse reactions recognised and identified and could help improve reporting rates (Berne et al. 2008). 4.4. Herbal Medicines WHO guidance on the safety monitoring of herbal medicines discusses the importance of including herbal medicines in Pharmacovigilance systems (WHO guidance, 2004). The amount spent on herbal medicines, by some 154 million US citizens in the year 2000 was $17 billion and there is currently a trend towards greater use of herbal medicines across the globe (WHO guidance, 2004). Herbal medicines are important to monitor for two reasons: 1) The high global levels of consumption of these medicines makes it important to know of any potential risks associated with taking the medicine; 2) When used in conjunction with other drugs there is the potential for herbal medicines to cause adverse reactions. In order for programmes monitoring herbal medicines to work properly the WHO recommends running any safety monitoring programmes in conjunction with current Pharmacovigilance techniques. A number of limitations were listed in the WHO guidelines (2004) which would need to be addressed in order to encourage and improve adverse event reporting in herbal medicines. Limitations that needed addressing included: the number of case reports, the high levels of under-reporting of adverse reactions to herbal medicines seen; the limited monitoring capacity; the lack of a standard classification scheme; no method for information exchange systems, within and between countries; EFSA supporting publication 2015: EN-739 23 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed and lack of communication and awareness within the general public that ‘natural’ does not always equate to safe, for example, Kava-kava (Piper methysticum) used for its sedative properties also caused hepatotoxicity issues and was eventually banned for use in the EU in 2002 (Barnes 2003). A number of methods are currently used to determine the safety of herbal medicines. These methods include: examining traditional usage data, conducting experimental studies e.g. clinical trials, and using other human data for example case studies. Spontaneous reporting seems to be the most common way of monitoring the adverse effects of herbal medicines (Bast et al. 2002, Barnes 2003, Hugman 2005 and WHO guidance 2004). Where herbal medicines are regulated as drugs (e.g. in Germany), traditional Post-Market Monitoring strategies e.g. healthcare professional adverse event form filling, and post-market clinical trials can be conducted (Barnes et al. 2003). Some of the adverse reactions to herbal medicines may already be captured on current Pharmacovigilance schemes if the adverse reaction is the result of an herbal medicine: drug interaction (Bast et al. 2002). However, many herbal medicines can be accessed ‘over the counter’, without prescription. This decreases the likelihood of adverse event reporting, due to the lack of healthcare professional supervision and patient understanding regarding reporting of adverse reactions to herbal medicines (Barnes et al. 2003). In the UK, to encourage increased reporting of adverse events from herbal medicines, a scheme was implemented in the early 2000s, which allowed nurses, midwives, health visitors, pharmacists and patients to report, in addition to doctors (Bast et al. 2002). Consumer reporting, is often the only way to receive safety data on non-prescription drugs (WHO guidance 2004). To maintain the quality and improve quantity of reports to help with detection of adverse reactions, further vigilance of reporting by the patient’s healthcare professional is recommended. (Barnes 2003, WHO guidance 2004). Manufacturer involvement is also crucial to the success of Post-Market Monitoring of herbal medicines (Barnes 2003, Bast et al. 2002 and WHO guidance 2004). By working with consumers and healthcare professionals, manufacturers can increase awareness not only of potential adverse reactions associated with the product through labelling, but also of the importance of patient reporting of suspected adverse events to a local general practitioner or relevant healthcare professional (WHO guidance 2004). Other methods to increase the levels of reporting of adverse reactions, to herbal medicines, was to make the forms available online for ease of use. Generally adverse event forms include a section titled ‘other drugs’ with reference to reactions thought to be related to herbal/traditional medicines (Barnes 2003). The paper by Barnes (2003) goes onto discuss other important details that should be included in future herbal medicine adverse event reporting forms. Specifically they focussed on gaps in current information captured by the form. For example forms should include information, where possible, on the formulation and identity of species found within the product and the specific processing involved in creating the product, as this can sometimes alter the chemical composition (Barnes 2003). Current EU Regulation on herbal medicines requires all member states to have a herbal medicine registration scheme in place, and manufacturers are no longer allowed to sell herbal medicines without first licensing the product7, by either holding: 7 http://www.mhra.gov.uk/Howweregulate/Medicines/Herbalmedicinesregulation/ (last modified 30th April 2014) 24 EFSA supporting publication 2015: EN-739 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed 1. A full marketing authorisation license, safety and efficacy proven (standard for regular medicinal products). Or 2. A traditional herbal registration license, safety and quality based on traditional usage information. There are a number of challenges related to the monitoring of herbal medicines which are listed below: 1. Regulation; different countries have different levels of regulation in place making it hard to globally understand the levels of adverse events associated with herbal medicines (Bast et al. 2002 and WHO guidance 2004). 2. Quality Control; if it has not been regulated properly contaminants could be an issue and result in more adverse events being experienced and therefore reported. Often multiple actives are used in a single product and the reverse is also true that single actives are used in multiple products. Knowledge of the potential implications of mixing products is vital to maintaining consumer safety. 3. Linking consumption and risk; as a high-proportion of herbal medicines enter the market as non-prescription remedies, it makes it hard to establish risks associated with consumption, as it is hard to determine how many individuals are taking the product and how much they are ingesting (Barnes 2003, Bast et al. 2002 and WHO guidance 2004). Some of these challenges can also be related to any potential monitoring programmes for GM food and feed. The need for monitoring of GM foods and feeds in the EU will be decided on a case by case basis according to the risk assessment and is likely to mean discrepancies in regulation between different countries potentially making it harder to compare safety data. The lack of clear consumption data will perhaps provide the major challenge in terms of monitoring of GM food and feed, as it will be very hard to determine how much and how many people are consuming. Bast et al 2002 and Barnes et al 2003 suggest the future of PharmacovigilancePost-Market Monitoring in herbal medicines is in more active surveillance initiatives, around pharmacy-record linkage and in areas of pharmacogenetics and increasing the awareness of the public about risks and how to report adverse events. 4.5. Veterinary Pharmacovigilance Comparatively fewer papers were available in the literature on veterinary Pharmacovigilance. Two papers progressed to the final review stage, as the rest were not in scope of the selection criteria. PMM of veterinary drugs has been based on human Pharmacovigilance systems. One difference between human Pharmacovigilance and veterinary Pharmacovigilance is that, veterinary Pharmacovigilance not only monitors animal health, but it also monitors the safety of animal-derived products e.g. meat and dairy products and animal owners/practitioners who come into contact with veterinary medicines (Iraguen et al. 2010). The International Cooperation on Harmonisation of Technical Requirements for Registration of Veterinary Medicinal Products (VICH) outlines a spontaneous reporting system for adverse drug reactions (Iraguen et al. 2010). Manufacturers, veterinary practitioners and owners of the animals are all encouraged to report any potential adverse reactions, to a medicinal product, that they observe (Iraguen et al. 2010 and Moore et al. 2005). Similarly to spontaneous reporting in human Pharmacovigilance, once the reports have been sent to the regulatory agency, they are reviewed for EFSA supporting publication 2015: EN-739 25 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed accuracy and completeness and any additional information required is obtained through follow-up interviews (Moore et al. 2005). In the paper by Iraguen et al. (2010) the authors present the results of a pilot Pharmacovigilance programme in Chile, which makes use of a combined surveillance approach. Veterinary practices and veterinarians were recruited and a list of the most commonly used drugs in dogs and cats were compiled. Once this was completed, a visit was scheduled to brief the veterinarians on what was expected of them and to provide information on the study. Vets were asked to report any ADRs they detected in their patients as a result of treatment with a drug considered in the study list, via an ADR reporting form. Phone, postal and email submission of an ADR report were accepted. Animal owners were also asked to participate in reporting any ADRs they noticed in their pets. They were instructed on potential reactions to watch for by their local veterinarian and that if they saw a reaction that they should bring their pet to their local clinic. Only veterinarians themselves completed the ADR forms. After the six month trial period the study organisers re-visited the clinics to review patient records and track the number of actual adverse reactions, compared to the number reported. Similar to human Pharmacovigilance there are a number of limitations and strengths to veterinary Pharmacovigilance. The strengths of Pharmacovigilance tended to remain the same whether veterinary or human. For example: The strengths of spontaneous reporting are that it is the most cost effective method, offering the widest breadth of surveillance. In comparison the strength of active surveillance is the ability to detect adverse events even if there is a delay between consumption and occurrence of an adverse reaction. Some of the limitations of the veterinary Pharmacovigilance surveillance methods are discussed. The study by Iraguen et al. (2010) found that there were high levels of under-reporting from veterinarians, although due to the pilot nature of the study, reporting rates may improve as veterinarians become more familiar with the system. The review by Moore et al. (2005) discusses the variability in reporting standards and that the number and type of reports are likely to be influenced by the reporter, which incurs bias. Moore et al. (2005) suggest using veterinary practice databases as a method of controlling variability in reporting standards. Standardised pull-down menus would reduce variability in entries and promote consistency, making analysis easier. A full history of patient information would be available and any clinical signs of an ADR as a result of a drug/vaccine treatment should be captured via this method. 4.6. Monitoring of Novel Foods Post-Market Monitoring in novel foods is required on a case by case basis where the outcome of the risk assessment deems it necessary (Alger et al. 2013). Post-Market Monitoring of novel foods is a useful method to clarify expected exposure to the novel food, or novel food ingredients in ‘real world’ populations (Butchko et al. 1994 and Alger et al 2013). Current Post-Market Monitoring methods for novel foods have been created using systems similar to those for drugs (Bons et al. 2010). In general Post-Market Monitoring of novel foods requires two distinct processes to occur to be successful. One of these is a food intake assessment and the other is the analysis of patient reported adverse effects (Hepburn at al. 2006). A number of studies have proposed methods for the Post-Market Monitoring of novel foods (Butchko et all 1994, Allgood et al. 2001, Simojoki et al. 2005, Welch et al. 2011 and Willems et al. 2013). Below the methodologies have been split by those for intake assessments and those for causality assessment of adverse events for reporting. EFSA supporting publication 2015: EN-739 26 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed 4.6.1. Food and Nutrient Intake Assessments Intake assessment before and during exposure is an important assessment to make, as it allows the elimination/determination of other potential triggers for an adverse reaction that might be seen (Welch et al 2011). Intake assessment in the analysed literature were obtained through active surveillance methods, in particular quantitative questionnaire formats (Butchko et al. 1994 and Simojoki et al. 2005) and food diaries (Butchko et al. 1994, Alger et al. 2013 and Willems et al. 2013). Questionnaires such as the US Menu Census Survey/ National Health and Nutrition Examination Survey (NHANES) collect consumption data from thousands of individuals. Households are asked to record all food eaten over a two week period and these two week surveys run consecutively throughout the year. There are other similar consumption surveys in Canada and Europe (Butchko et al. 1994, Hepburn et al. 2006). One such study by Simojoki et al 2005 used data from 15 independent health surveys to analyse consumption of phytosterol products e.g. ‘Flora Pro-Activ’ in Finland. Participants were selected randomly and consumption of phytosterol spreads was determined via questions on the purchasing choice of fat/spreads. Willems et al. 2013 summarise results from Post-Market Monitoring on the consumption of phytosterols e.g. Flora Pro-Activ in; Belgium, Germany, France, the Netherlands and the UK. In this study households were recruited to cover a wide demographic. They were then issued with barcode scanners, and every food item they bought was scanned. The scan data was stored electronically and used to calculate household and country intake data of phytosterols. One of the limitations of this particular study is that intake was based on overall household rather than individual consumption data and did not take into account that some of the product may not have been consumed at all e.g. the product was thrown away . This makes it is hard to determine how much of the purchased product the members of the household are eating. Work done by Neuhouser et al. 2001 describes a method for dietary assessment in individual participants. This involved an active approach where interviewers questioned randomly selected participants about their eating habits, requiring them to estimate portion sizes for various food groups. One of the major issues with intake assessments is the ability of the consumer to identify a particular novel food in a product they are eating (Kingston 2005 & Hepburn et al 2006). Unlike in the pharmaceutical industry where professionals prescribe a fixed product and dosage, with novel foods it is often hard for individuals to assess their level of consumption. Therefore it is much easier to monitor branded products as consumers are more aware of the presence of novel foods. It has been suggested that methods involving radio-tagging of un-branded products may help with these traceability issues (Hepburn et al. 2006). 4.6.2. Assessment of Reported Adverse Events Assessment of reported adverse events in novel foods is similar to that for pharmaceuticals. A combination of passive and active surveillance methods is the most commonly reported system for monitoring of adverse reactions. Welch et al. 2011 outline guidance on conducting human intervention studies to evaluate the health benefits of food. In relation to adverse reactions, the guidance presented states that all adverse reactions noticed by the study leader/healthcare professional should be reported, whether or not it is believed to be related to the consumption of the food product (Welch at al. 2011). Other studies that used spontaneous reporting systems e.g. charge-free product care lines and physician reports, to gather information on adverse drugs reactions include the Butchko et al. 1994 study on Aspartame and the Allgood et al. 2001 study on Olestra. Charge-free product care lines are used by manufacturers as the most rapid method of obtaining feedback on adverse reactions experienced by a consumer. Care lines provide extensive coverage of potential consumer groups (Wal EFSA supporting publication 2015: EN-739 27 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed et al. 2003), as unlike active surveillance approaches, care lines can cover entire populations rather than a demographic (Ronaldson 2011). Using Flora Pro-Activ manufactured by Unilever as an example, best practice methods for running a care line are discussed. Unilever developed a global charge-free customer care line to collect consumer views on the product in an unbiased manner. The staff on the care lines were given training so that they were able to distinguish calls that related to health complaints and to obtain detailed information from the caller on the nature of the potential adverse reaction. This could include information on: patient demographics, levels of consumption, the severity and duration of the reaction and if medical assistance e.g. a hospital visit was required (Hepburn et al. 2006, Allgood et al. 2001 and Wal et al. 2003). Once the information on the adverse event had been gathered, the data could be sent for internal and external review, by trained medical professionals e.g. toxicologists and clinicians (Wal et al. 2003). The reports were then coded based on the level of association between the consumption of the product and the reported symptoms (Lea & Hepburn 2006). Level of association was coded as follows: RED, an association between intake and the occurrence of symptoms can be explained by the known molecular properties of the product; ORANGE, an association between intake and the occurrence of symptoms cannot be explained by the known molecular properties but causation cannot be excluded; YELLOW, an association between intake and the occurrence of symptoms cannot be explained by the known molecular properties but causation can be excluded; GREEN, there is no association between intake and the occurrence of symptoms (Lea & Hepburn 2006). Two other codes were used to indicate reports that were not relevant and those which lacked information (Lea & Hepburn 2006). During the first year of marketing Unilever received 84,000 calls to the care line, of which <1% were related to health complaints. Of those 227 health complaint calls, none were coded as RED but 142 were coded as ORANGE (European Commission, 2002). The number of ORANGE coded reports was well within the expected levels of occurrence of symptoms, within a population. After reports had been coded, an outcome assessment summary was sent back to the consumer care line. Every call made to the care line was monitored to check for any unknown/unexpected side-effects and to decide whether further studies into unexpected potential adverse effects were necessary (Lea & Hepburn 2006). Other good examples of manufacturers utilising care lines are; Proctor and Gamble for their fat-replacement Olestra (Allgood et al. 2001) and the Nutrasweet Company for their sugar replacement Aspartame. Active surveillance for adverse reactions was usually conducted by the manufacturer of the brand after reports of adverse reaction to the product had been received e.g. The Nutrasweet company for Aspartame and Procter & Gamble for Olestra (Butchko et al. 1994 and Allgood et al. 2001). Active surveillance of novel foods in the above studies was designed as a postmarket clinical trial. In the Post-Market Monitoring of Olestra, three post-market clinical trials were designed. These were a; re-challenge study, an acute consumption study and a six week consumption study. The re-challenge study included patients who had previously reported an adverse reaction to Olestra to see if the effect could be replicated. The acute consumption study was used to assess the effect of level of consumption on potential adverse effects. Participants were allowed to eat as much or as little as they wanted and the adverse events were recorded. The final trial was the six week consumption study. This was a longitudinal study where households were asked to record daily chip intake to see if Olestra had any long-term effects (Allgood et al. 2001). All trials were randomised and contained a placebo group who did not consume any of the novel food, which is similar to the design of the studies to assess adverse reactions to aspartame mentioned Butchko et al. 1994. Outcomes of the Olestra trial found that there was no increased incidence of adverse events in the Olestra group over the control group. Reporting levels were also found to be highest just after the first release of the product (Allgood et al. 2001). A major difficulty when monitoring potential adverse reactions to novel foods is that it is often hard to establish whether a particular effect was the result of the consumption of the product in question (Lea and Hepburn 2006 and Butchko et al. 1994). For example, reports of adverse events to consumer care EFSA supporting publication 2015: EN-739 28 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed lines about Flora Pro-activ and Olestra, detailed a number of events where a causal relationship could not be excluded, but could also not be confirmed as a direct result of the consumption of the product. This is particularly true of gastrointestinal effects which could be due to a number of other factors (Lea and Hepburn 2006 and Butchko et al. 1994). Although these monitoring schemes were successful in confirming the safety of novel foods, a consensus among the literature is that, work to develop tailored monitoring schemes for novel foods is still required (Hepburn et al. 2006 and Alger et al. 2013) e.g. methods for defining causality (Lea and Hepburn 2006 and Butchko et al. 1994). Developing tailored schemes for GMOs would be arguably more difficult than for novel foods, because novel foods generally provide added value (to the consumer), are more contained in a fewer number of products and are recognised by consumers and vendors as a specific brand. As added value products, a premium price can be attached to the product and tends to mean the manufacturers will market the product as a brand e.g. Flora ‘Pro-Activ’ and Olestra. By branding the product, the manufacturer makes it much easier to track in the supply chain, and for consumers to identify in terms of consumption and adverse events. If, for example, a product contained GMO soybean oil in a blend with other oils, it would be much more difficult for a consumer to identify and therefore link any adverse events back to the product. Therefore monitoring of GMOs is potentially more complex and will require more active approaches to surveillance than novel foods as consumer are unlikely to know that they have ingested the product. EFSA supporting publication 2015: EN-739 29 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed 4.7. Summary of existing monitoring programmes Table 4 has been included to provide a brief summary of how methods of Post-Market Monitoring programmes vary for the different products that they are designed to monitor e.g. intake assessment in Pharmacovigilance for monitoring of drugs will differ considerably from post-launch monitoring for novel foods. Table 4: Summary of existing monitoring programmes Monitoring Method Pharmacovigilance Vaccinovigilance Passive Surveillance Active Surveillance Prescription Event Monitoring Intake Assessment Spontaneous reporting of adverse events by healthcare professionals e.g UK yellow card scheme and by patients e.g. consumer care lines to the relevant authority or license holder Spontaneous reporting is the most common method of Pharmacovigilance. Observational studies e.g. casecontrol studies (use of nontreated patients as the control group to compare to those of the drug), cohort studies (monitoring individuals from a specific cohort over time) and large simple safety trials, postmarketing clinical trials A combination method of passive and active surveillance which links drug prescription data to healthcare practitioner adverse event reports, potentially making it easier to determine causality. As most drugs are prescription only, intake should be straightforward to determine. Spontaneous reporting schemes are similar to those in Pharmacovigilance. Countries tend to have dedicated national vaccine reporting centres e.g. VAERS (USA) Most commonly described in the literature as the surveillance method of choice. Use of casecontrol and cohort studies mentioned. The design of the studies was similar to that of Pharmacovigilance. Similar process to Pharmacovigilance called ‘Electronic data linkage.’ Use of electronic data records to determine causality. As most vaccines are prescription only, intake should be straightforward to determine. EFSA supporting publication 2015: EN-739 30 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Monitoring Method Cosmetovigilance Herbal Medicines Veterinary Pharmacovigilance Passive Surveillance Active Surveillance Prescription Event Monitoring Similar to the reporting systems for drugs. Spontaneous reporting to Care line and by healthcare professionals does occur but generally reporting occurs at a much lower rate than for drugs. Trial design is similar to that of the cohort studies. Patients with potentially adverse reactions were recruited and assessed for dermatological skin reactions to products. Greater levels of active surveillance could improve reporting rates. Products are usually bought over the counter so this type of surveillance is generally not possible. N/A In countries like Germany where herbal medicines are regulated as drugs, traditional reporting systems e.g. spontaneous reporting or post clinical trials are in place In countries where herbal medicines are regulated as drugs, traditional reporting systems are in place e.g. Germany Usually bought over the counter and without a prescription determining the actual amount taken is hard. Similar to Pharmacovigilance. Veterinary practice databases used to provide patient information and treatment/prescription information which can be used to help determine causality Based on owners being able to dose the correct amount but as most drugs are prescription only intake, should be straightforward to determine. Most common method of reporting as drugs are usually available over the counter. Spontaneous reporting by healthcare professionals and patients. Under-reporting due to the lack of healthcare professional supervision and information on behalf of the patients. Spontaneous reporting systems are similar to those for Pharmacovigilance. Although animal owners can encouraged to report adverse events to the Veterinarian. Only the veterinarian can report the adverse events EFSA supporting publication 2015: EN-739 Intake Assessment 31 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Monitoring Method Novel Foods Passive Surveillance Active Surveillance Prescription Event Monitoring Intake Assessment Spontaneous reporting is the common form of monitoring. This usually occurs via consumer care lines. This information is processed by the manufacturer and then sent to the relevant regulatory authorities. Some reports are collected from healthcare professionals. Active surveillance takes the form of cohort and case-control trials and consumption questionnaires. Novel foods are not prescribed so this cannot be done, Food diaries and consumption questionnaires are used to determine intake. EFSA supporting publication 2015: EN-739 32 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed 5. WORK PACKAGE 2 - INVENTORY OF DATA COLLECTION METHODOLOGIES ASSESS FOOD CONSUMPTION/COMPOSITION AND HUMAN AND ANIMAL HEALTH TO The overall objective of Work Package 2 was to identify and describe programmes (survey, monitoring or surveillance) that would be relevant for PMM of GM food and feed. Our approach was to identify and describe existing data in the EU that would facilitate PMM, majoring on food composition and consumption data. We start by giving an overview of the regulatory requirements on food business operators for traceability and labelling, and for GMOs in particular to understand the extent to which ‘tracking’ GM traits is possible in food and feed supply chains. 5.1. Regulatory requirements for traceability and labelling To fully understand the extent to which PMM of GM food and feed is possible, the EU requires an understanding of how the requirements of other legislation can aid its implementation. 5.1.1. Traceability requirements Regulation (EC) 178/2002 aims to ensure the quality of foodstuffs intended for human consumption and animal feed, as well as the free circulation of safe and secure food and feed in the internal market. Operators are responsible for ensuring the traceability (Article 18) of substances incorporated into foodstuffs at all stages of the supply chain, including production, processing and distribution. The requirement relies on the ‘one step back - one step forward’ approach which details that food business operators (FBOs) must: Have in place a system enabling them to identify the immediate supplier(s) and immediate customer(s) of their products. A link must be established which gives information on which products are supplied from which suppliers. A link must be established which gives information on which products are supplied to which customers. Nevertheless, food business operators do not have to identify the immediate customers when they are final consumers. Figure 2: system of traceability under Regulation (EC) 178/2002 The traceability requirements under Regulation (EC) 178/2002 mean that in theory, through questioning, it is possible to trace products back to their origin. However, the following factors mean that traceability legislation could not currently ensure an accurate system of PMM: Regulation 178/2002 would not apply to all operators in third countries beyond the importer. As such the ability to trace back to source requires traders and processors importing raw materials to food businesses in the EU to have a robust understanding of the producers from which raw materials have come from. For a system of PMM to be possible on an individual trait level traders/processors must be able to inform the FBO in the EU which variety of plant they have purchased as raw material. EFSA supporting publication 2015: EN-739 33 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Under traceability requirements FBOs do not have to provide robust data on the provenance of their product, i.e. giving information on which GM trait is included within a batch of raw materials. Traceability requirements do not require FBOs to detail which customers have bought the product if these are final consumers, i.e. a retailer does not have to keep records on every customer which has bought a particular product. 5.1.2. Specific requirements for GMOs Regulations (EC) 1829/2003 and 1830/2003 set out specific requirements for controls on GMOs in food and feed. The regulation applies to GMOs for food and feed use, as well as food and feed produced from or containing ingredients produced from GMOs. All products covered by Regulation (EC) 1829/2003 are subject to compulsory positive labelling, indicating whether the food or feed contains, consists of or has been produced from GMOs (a ‘GM food’). For food, under Article 13 the name of the ingredient (e.g. ‘soya’) must be given, however more specific information is not required which would indicate the particular trait that has been used. The label must also mention where a GM food is different from its conventional counterpart as regards its composition, nutritional value or nutritional effects, intended use of the food, implications for the health of certain sections of the population and where a food may give rise to ethical or religious concerns. Under Article 25, similar labelling requirements are in place for feed including mentioning where a feed is different from its conventional counterpart in terms of its composition, nutritional properties, intended use, implications for the health of certain species or categories of animals and as specified in the authorization any characteristic or property where a feed may give rise to ethical or religious concerns. Under Regulations (EC) 1829/2003 and 1830/2003 wider traceability requirements for GMOs are in place to facilitate the withdrawal of products where unforeseen adverse effects on human health, animal health or the environment, including ecosystems, are established. Traceability requirements are also in place to facilitate accurate labelling of these products as detailed above. The legislation sets out the conditions for the transmission of information that products contain or consist of GMOs, and set out the conditions for the use of unique identifiers. Commission Regulation (EC) No 65/2004 of 14 January 2004, established a system for the development and assignment of unique identifiers for genetically modified organisms. The Regulation applies to all genetically modified organisms that will be imported into the Community for cultivation and for human food and animal feed, except medicinal products for human and veterinary use. The identifier is made up of 9 characters, including letters and numbers, combined in a uniform way. If GM content exceeds legal thresholds (0.9%), the identification code(s) must accompany shipments of GMOs. The code can be used to retrieve information about the respective GMO from international databases. Under Regulation (EC) 1830/2003 at the first stage of placing on the market (from producer to first third party i.e. trader) of a product consisting of or containing GMO (such as soybeans), including bulk quantities, operators must transmit the following information in writing: An indication that the products consist of or contain GMOs; The unique identifiers assigned to the GMOs. If the product is a mixture of GMOs, the operator must submit list of the unique identifiers assigned to all the GMOs used to constitute the mixture. At all subsequent stages of the placing on the market of these products the information above must be transmitted in writing to the operators receiving the products. As the unique identifier must label all GM traits within a batch of material, multiple identifiers may be placed on the same batch. Theoretically, an operator may also list multiple traits on EFSA supporting publication 2015: EN-739 34 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed a batch whether they are included or not, just to ensure that all possible traits that could be included are listed. For food and feed products produced from GMOs (e.g. oils and soya lecithin) the following information must be transmitted: An indication of each of the food ingredients which is produced from GMOs; An indication of each of the feed materials or additives which is produced from GMOs; In the case of products for which no list of ingredients exists, an indication that the product is produced from GMOs. As such, the requirements for a unique identifier which can define one GM trait from another ends at the stage a product is further processed to be ‘produced from GMOs’ rather than ‘consisting of or containing GMOs’. In order to track GMOs which require PMM down the supply chain, a system would have to ensure the unique identifier is transmitted at all stages. The legislation does not require the operator to stipulate the proportion of a GMO in each product. Requirements for labelling of products containing GM do not apply in isolation, and must also adhere to general EU food labelling laws. 5.2. Assessment of food consumption Data collection on food consumption can be broadly split into two main categories; (1) that collected by member state or third countries to monitor food consumption, nutritional status and nutrient intake at a national level, and (2) data collected by market research agencies and food retailers to monitor purchases of food, largely for commercial purposes. Table.5 gives a summary of all these programmes and their strengths and weaknesses for monitoring GM food and feed. 5.2.1. Food consumption data collected by member states and third countries Food consumption databases operated at a national level are surveys of consumption, nutrient intake and nutritional status of people in the host country. They vary in their level of detail, and extent of foods covered. As an example, the primary national survey of dietary intake in the UK is the National Diet and Nutrition Survey (see PHE, 2014). This is based on interviews and diet diaries recording food intake at the individual level and combined with urinary and blood biomarkers of nutritional status and exposure. Equivalents exist in other countries, but are not present in all member states, examples include the German Nationale Verzehrsstudie (see BMEL, 2009), and the French Enquête Individuelle et Nationale des Consommations Alimentaires (see ANSES, 2013). These surveys provide good detail on food consumed by a selectively representative sample of the population. They are cognitively demanding in that they require individuals to faithfully record foods consumed. The accuracy of the tools for collecting food intake data are well criticised and it is unrealistic to expect that accurate data can be pulled from such surveys reflecting the specific brand and variety of a food consumed. The nutrient intake data in these studies is largely approximated from the records of food intake coupled to established food composition tables such as McCance and Widdowson. Household budget survey data are available for each of the member states and collates data on household purchases. From a nutritional perspective, these data sets are used to estimate fruit and vegetable consumption in member states. The drawbacks of these types of survey are that limited detail is provided on the distribution of consumption of foods between family members and the levels of food wastage is not available. The data collection in this type of survey may however be supported EFSA supporting publication 2015: EN-739 35 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed by the collection of household receipts which would allow for some extrapolation back to the individual food items purchased for the approximation of the nutritional content of purchased food. Separate to the data on food intake and purchases collated by member states, there are also data available on food intake from large cohort studies through the EU, the European Prospective Investigation into Cancer and Nutrition (EPIC) study is an example of this and captures rich data on nutritional intake and status through the Eurozone which may be linked to disease outcome measures. The strength of the EPIC dataset is the common means of data capture used in each of the member states involved. The dataset does however suffer the same limitations as the national diet and nutrition surveys (see EPIC, 2014). The data collection and exposure unit of EFSA (DATEX) collect and analyse data on food consumption from the member states. The aim of analysing the food consumption data is to assess exposure to hazardous chemicals. A number of short-comings with some of the other food classification systems led DATEX to develop FoodEx in 2008 (see EFSA, 2011). FoodEx is a hierarchical food description and classification system containing entries on approximately 1,700 foods, taking into account legislative information on maximum levels of contaminants and residues allowed. The FoodEx system has helped to facilitate EU wide exposure assessments and accurate matching of datasets to determine causality. One of the main benefits of the system, is that it harmonises food consumption data entries across the EU allowing member state comparisons. It does however have a number of limitations with regards the foods included in the system, for example, no details are provided on branded products and very limited details are provided on food ingredients. The EU menu survey combines aspects of both the Household budget survey and the EPIC study (see EFSA, 2014). It is still under development, but the major aim of the survey is to standardise methods of collecting food consumption data across all member states to help in the analysis of food consumption data. Not all member states are currently reporting on the food consumption within their countries. The hope is that the EU menu survey will improve the quantity and quality of food consumption data coming from all EU member states. The reason for standardisation is because it is currently hard to compare different country’s nutritional information data as methods of collecting data differ. The EU menu survey will allow accurate, EU wide assessments, on the potential safety and exposure risks of food and the nutritional status of sub-groups within Europe. The real limitation of this survey is that it is not currently possible within this system to track brand ingredients and GM products into food. The food consumption data is collected by the private sector. 5.2.1.1. Data held by retailers/supermarkets Data on the food purchases of households are collected by major food retailers for commercial purposes. Many of the major retailers trading in Europe now operate loyalty or ‘club card’ systems, whereby consumers electronically scan a card when buying groceries in exchange for ‘points’ which accumulate to qualify the consumer for offers or money off future shopping. Consumers provide basic personal details and data on purchases made are held by the retailer. The data generated offers an exhaustive list of what has been purchased by the consumer, however, this does not indicate accurately the amount of the product consumed or hold demographic information such as the number of people in the household and their ages etc. Furthermore, whether data are collected depends on whether the consumer ‘scans’ his or her loyalty card at each visit to the supermarket. Card data would not necessarily give a complete picture of all items a particular consumer had purchased if that consumer shopped at multiple stores. Data held includes product names, which gives the possibility to work with manufacturers or the retailer to combine this with composition data, including GM ingredients. As in the national household budget surveys inferences regarding the distribution of dietary intakes amongst individuals within the household are hard to draw from these data as is approximating the levels of food wastage. EFSA supporting publication 2015: EN-739 36 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed 5.2.1.2. Data held by market research companies Independent third market research companies such as ‘Kantar’ perform market research on food purchases in some European member states (see KantarWorldpanel, 2014). Data are typically sold to private companies operating in the food sector to provide insights which will help their business. In the example of Kantar, 30,000 households which are demographically weighted are used to provide a nationally representative sample of UK food purchasing. The Kantar database holds data on the nutritional values of 100,000 products by category, manufacturer, retailer or individual product, assuming reference food composition data are available. Nutritional data for each product is then linked to a range of shopper demographics such as salary, region and number of children in the household. Survey subjects in the 30,000 households are asked to scan all food and drink products brought into the home. These data give a detailed analysis of food available in the home which can be linked back to individual food items, and therefore, to the provision of nutrients for the household. By the same reductionist process the purchasing of ingredients as part of complex foods might be identified with these datasets. In its present form the Kantar data does not give any information on provenance of a food product, or ingredients and this would have to be built in to give any information on the inclusion of GM food or feed. As with data held by retailers/supermarkets food wastage is not taken into account. The Kantar dataset only captures information on products brought for consumption in the home and has no facility to scan food consumed outside the home in the wider foodservice sector. Kantar operates the service in the UK and Spain, however other market research companies offer similar services which have the ability to record data on food purchases wider in the EU. 5.2.1.3. Data collected by private food manufacturers Outside of food purchase, and market research data, data may be held on the consumption of products by individual food companies. For many companies some level of consumption data may be collected routinely after the launch of new products to check that consumer use patterns are as expected (van Puijenbroek et al 2007). As this data is generally classed as commercial in-confidence no information is held on the extent to which this is available. Based on informal consultation with the industry the extent of more detailed consumption data are thought to be limited, as gathering it is costly, and in many cases provides no immediate gain. Data of this nature is generally not publicly available, and details are limited. EFSA supporting publication 2015: EN-739 37 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Table 5: Summary of data collected for food consumption in the EU and its positives and negatives for the PMM of GM food and feed Available tools Household budget surveys Geographic coverage By individual Member State and many third countries Positives Data on purchases can include identifiers for specific products Negatives Purchases of food eaten out of the home poorly captured No data on actual consumption By individual Member State and many third countries Good data on food consumption at the individual level Food intake data is usually only available for aggregate food items The data collected is reliant upon awareness of the consumer No harmony between data collection methods between national surveys Many of the surveys from individual states are now dated, not every Member State has a rolling programme Held at EU level Aggregation and collation of data held by member states Limitations are as per domestic national surveys National diet and nutrition surveys FoodEx Classification System No harmonisation of data collection methods between member states An aggregate list of food items with no detail on specific food brands Insufficient detail to capture data on food ingredients Very poor quality data on food eaten out of the home EFSA supporting publication 2015: EN-739 38 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Held at EU level Still in development Still in development Good data on dietary intake Food composition databases don’t currently keep information on brand ingredients No system for tracking GM into food ingredients Supplementary information on food brands may allow some deeper analysis of exposures based on ingredients EU menu Harmonisation between member states Worldwide Data in the private sector Supermarkets and market research groups have good data on household purchases The data is on purchasing and not on intake Data at a product and brand level may allow some deeper analysis of exposures based on ingredients There are few identifiers as to whom in the household is consuming what No data on food eaten out of the home Data only available from large retailers, and may miss purchasing habits of large sections of the community using independent retailers No harmony in data collection between member states EFSA supporting publication 2015: EN-739 39 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed 5.2.2. Current data gaps to calculate food consumption The diet and nutritional surveys are intended to monitor nutritional status, the potential for deficiency or toxicity disease in the population, and the adherence to dietary guidelines, or to justify new guidelines. The cohort study data are designed to assess links between dietary exposures and disease at the population level. The household budget surveys principally contribute to economic planning, whilst the private data are largely collected for market research purposes. Estimates of the intake of nutrients can be made from these surveys with reference to food composition tables, there is a case for integrating the data in these different types of survey to model dietary exposures where the data fails to capture these exposures. For example, household budget survey type data can couple food purchases to geographical regions or socioeconomic status, whilst the nutritional surveys can be used to identify who within the household is likely to be consuming particular items of the food purchased. This approach may also be valid for the purposes of assessing the consumption of GM foods but would require a significant re-evaluation of the food data available. For example the abundance of a GMO in the national diet could theoretically be estimated if data from household budget surveys allowed for an estimation of the purchases of food items containing that GMO, the national dietary survey could then be applied to predict who within the household was likely to be consuming that GMO. This approach may be of value from a public health perspective if consumption of the GMO is likely to induce population level changes in exposure to nutrients or non-nutritive components of the diet, particularly if there are likely to be vulnerable groups within the population, e.g. pregnant women, those vulnerable through morbidity or infants. It would not, however, provide useful direct data on acute adverse events associated with consuming the GMO. The principle barriers to this strategy are that no food composition database currently contains data on the GM content of composite food items and data capture on the consumption of whole foods is reliant on an educated consumer in its present format. It is unlikely that most consumers/survey respondents will universally recognise whole food GMOs and very unlikely that they will identify the GM components of composite foods. 5.3. Assessment of feed consumption 5.3.1. Feed consumption data Individual farms will, in some cases keep records of what feed, in what quantities have been fed to livestock. The EC Feed Hygiene Regulations require farmers that mix feed on farm (without additives) to record the source and quantity of feed used (e.g. through invoices, receipts, delivery notes and feed labels). Feed consumption databases recording nutrient intake, as are maintained for food, do not exist for large populations of animals in specific countries. In the UK high level information on raw material usage and the production of compound feeds are provided by a monthly survey of animal feed companies and of specialised integrated poultry units (see Defra, 2014). 5.3.2. Current data gaps to calculate feed consumption It is assumed that GM varieties developed as feed ingredients will target large market segments (e.g. broilers, or pigs). The GM variety may be used by a feed processor, or merchant as an ingredient in a ready mixed, or ‘compound’ feed, or may be used whole by the end user (the farmer) in his own feed mix. The level of data on consumption of feed that is available for specific farms, will largely be dependent on the nature of the farmer or the requirements of feed hygiene legislation. Whilst some EFSA supporting publication 2015: EN-739 40 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed individuals may keep diligent records, using technology such as feeder wagons that monitor the amount of feed given, and its composition, other farmers may work on the principles of tradition, simply doing business as they always have and not keeping comprehensive records. However comprehensive consumption data may be at a farm level, it is likely that this would be for a group of animals, rather than individuals. 5.4. Assessment of food composition 5.4.1. Publicly available food composition data The food composition tables such as McCance and Widdowson in the UK provide estimates of the composition of individual food items in terms of their nutritional and or physical composition (see FSA, 2010). The data within these tables is often based upon approximations of the mean nutrient content for amalgamations of a food item, which can be inaccurate. Nevertheless, inferences or approximations of nutritional intakes are extrapolated from these databases based on information collated in the food surveys on purchasing and intake. These tables are good for single foods (e.g. eggs, cheese, bread and fruit) but lack accuracy for more complex dishes due to the complexity in the number of ingredients included. As food composition tables list one generic product, they do not take into account the variances between different products within the same category, for example a prepackaged ready meal sold in a supermarket may vary in calorie content between brands and manufacturer. Efforts do exist at the European level to harmonise food composition data, and the EuroFIR project draws together food composition information from 26 compiler organisations in Europe, Australia, USA and Canada (see EuroFIR, 2014). Crucially however, in their current format the composition databases do not specifically identify the GM components of a food or varieties of plant included in the product and so provide limited value to PMM programmes. 5.4.2. Privately available food composition data Food composition data may also be held by private companies in the food sector, such as manufacturers, retailers and food-service operators. 5.4.2.1. Food retailers Food retailers typically use food composition tables to source nutritional data on their products to display on the packet. Where available, retailers may also utilise analysis of nutrients directly from manufacturers or other historical data. In terms of determining the varieties of GM food or feed in a product, the level of composition data held by the private sector is mixed. Under Directive 2000/13/EC (repealed by Regulation (EC) 1169/2011) food labelling and packaging laws require that if a food or drink product has 2 or more ingredients (including additives), these must be listed in order of weight. However, this is not required for catering businesses or those who sell food loose. Additionally labelling laws require that the product carries a notification if it contains GM ingredients (unless their presence is accidental and 0.9% or less). As such current labelling laws would not dictate that an operator would need to label the specific GM food or feed in their product. Major grocery retailers across the EU collect data on the provenance of their own-brand products. The level of information held varies from product to product, with primary products such as fruit and vegetables where a specific supplier code provides information on the exact location where the product is grown and information on the variety to more general product specification data (per comms). In order for a system of PMM to be successful further data would be required in terms of the variety of raw material used to determine its status as a GMO. Own brand foods make up a growing proportion of food and beverage products sold by retailers across Europe. EFSA supporting publication 2015: EN-739 41 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed For branded products (i.e. those carrying a brand other than the retailer’s own-label) less data are held by retailers on composition, this being left to the specific manufacturer to maintain records themselves. 5.4.2.2. Foodservice operators Under food labelling laws, catering businesses are not required to provide a list of ingredients on the food or drink they sell. The only information on composition that would be required is the name of the food, whether ingredients have been irradiated or are GM and additions of any food additives. As such, for foodservice operators there is likely to be a large scale of variability on the type of information that is held on products. Whilst major restaurant chains may have detailed composition information for specific products/meals, minor chains or single businesses are unlikely to keep or have the facility to obtain such information. 5.5. Assessment of feed composition 5.5.1. Feed composition data The composition of feed, fed to commercial livestock in many cases would be known either by a farmer, or a manufacturer. However, there exists no central data source which holds all these data. Where feed is mixed on-farm (with additives or premixes) the EC Feed Hygiene Regulations (183/2005) require farmers to record information on the source and quantity of each input of feed, for example a description of the feed used, produced or sold, the quantity, batch number, the date received and from which supplier. If the feed has been mixed by the farm itself, depending on the nature of the farmer, records will be kept of the proximate analysis (e.g. energy, protein, vitamin and mineral content), in order to measure its effect on animal performance. However, as provenance data on specific feed types are not generally known by the farmer these data would be of limited value, unless the farmer were purchasing a specific ‘value-added’ GM product which was distinct from other feed types. Where a farmer is buying ready mixed, or ‘compound’ feed the composition will be known by the manufacturer/processor and the farm would record the type of feed purchased, but may not record its ingredients (if these are known). For compound feed developed by a specific manufacturer, exact composition data on the proportion of ingredients included is usually commercially sensitive and not available. Where farmers are members of farm assurance schemes they may be required to record the composition of feed offered to their animals or adhere to an ‘allowed list’. Feed composition data for animal feeds do exist, such as the ‘Feedipedia’ project which contains information for particular feeds (such as ‘wheat’) in relation to descriptions, feeding recommendations, composition and nutritive value (see Feedipedia, 2013). However, these datasets much like food composition data are generic to general feed types (such as wheat) and do not include provenance information on whether GM traits are included. EFSA supporting publication 2015: EN-739 42 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Table 6: Data available by feed type Feed type purchased by farmer/animal owner Data available Compound feed (a feed composed of different Detailed composition data would be held by the raw materials) sold by a feed processor. feed processor, however this is likely to be commercially sensitive and not available to determine exact quantities of GM feed used. ‘Straight’ or concentrate feeds (feeds composed Provenance data on the product is unlikely to be of one raw material) known unless the feed bought was a GM variety with some added value (i.e. high oleic oil) in which case this information may be known to the owner. 5.6. Determining the inclusion of GM food and feed in products For a comprehensive system of PMM according to the requirements of Implementing Regulation 503/2013 to be possible (see Section 6.1), some degree of tracking GM traits through the feed and food chain would be required to determine which products they are included in. In order to track products through the food and feed chains, the co-operation of multiple stakeholders throughout the supply chain is a pre-requisite. GM traits that will require PMM are, in most cases sold as a seed to a farmer/grower for cultivation. For this example we assume a GM variety (soybean) is cultivated in a third country, and subsequently shipped to the EU where it has an approval for use as food and/or feed, and is further processed into multiple products before reaching the consumer. Figure.3 details the first stage of the supply chain, from farmer to trader and processor, green arrows indicate where information on the GM variety is passed through the supply chain, red indicates that keeping information on the GM variety is not currently practiced. It is assumed that an applicant company would keep records of seed sold to particular customers and that a farmer buying a GM variety would be aware of the variety that had been purchased, and later sown. After a GM variety has left the field as an agricultural raw material (such as soybeans or corn), under the requirements of Regulation (EC) 1830/2003 it must carry a unique identifier which details the trait that is included in the batch. Where multiple traits are included in the same batch all unique identifiers for the trait should be labelled (see Section 5.1.2). Traders may import the raw material to a processor in the EU who would turn the raw material into an ingredient (such as oil). Alternatively the processor may have the facility to process raw materials into ingredients themselves and do this in the third country, or the EU country where the commodity is imported to. As detailed in Section 5.1.2, once the raw material which is ‘consisting of or containing GMOs’ becomes an ingredient which is ‘produced from GMOs’ it no longer requires the unique identifier to be transmitted through the supply chain. These ingredients will still require segregation of GM and non-GM to facilitate the positive labelling of GM food and feed, but information would not be held on the specific variety. In the example of soybeans further identification of the GM components may be possible after the raw material becomes an ingredient if it has some higher value further down the supply chain. For example oil with high oleic properties derived from ‘high oleic soybeans’ may be kept segregated for their added value to users downstream, however it should be appreciated that this oil could consist of more than one variety of GM ‘high oleic soybeans’. For a GM trait that does not confer any added value further down EFSA supporting publication 2015: EN-739 43 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed the food chain (i.e. input traits) the GM component would be identifiable through labelling, however not at a specific variety level or with a known proportion of the product. Figure 3: The supply chain- producer to trader/processor Once imported into the EU, a GM plant variety destined as food or feed will pass through multiple stages before reaching the end-consumer. The two supply chains are discussed in detail below. 5.6.1. GM varieties used as feed Feed processors or merchants in the EU will typically purchase imports of a particular agricultural product (soybeans, corn etc) and further process this with other products into compound feed for different livestock. The final product could be as pellets, crumbles or meal and could include a variety of grains such as soybean, corn, oats and barley etc. This means that in effect one particular type of compound feed sold by a merchant/processor could contain more than one GM variety. In order for a system of Post-Market Monitoring to be successful, a merchant or processor would have the know exactly which GM varieties are contained within the finished product, and preferably at what proportion. The finished product would then go to a farmer who would need to keep records of which compound feeds had been fed to his or her livestock. In effect, after all these conditions had been obeyed it may be possible to confirm the effects of the GM variety in accordance with a PMM scheme. EFSA supporting publication 2015: EN-739 44 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Figure 4: The supply chain for feed- post import 5.6.2. GM varieties used as food Agricultural products will be bought by food processors in the EU for further processing, and in limited cases may also be bought in their current state (i.e. there is a limited food market for whole soybeans). In the case of soybeans, it is likely that further processing will extract multiple by-products such as soybean oil and lecithin which then could be sold to a final processor or manufacturer to be used as ingredients in multiple other food products. The ability of a system whereby consumption of particular GM varieties could be monitored will be dictated by the ability of the final manufacturer to know which variety of soybean has been used in a particular product. If this can be achieved then this information could be included in food composition data, and subsequently utilised in food consumption data (see Section 5.2). EFSA supporting publication 2015: EN-739 45 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Figure 5: The supply chain for food- post import 5.7. Data to understand adverse effects 5.7.1. Animal health reporting schemes Animal health monitoring is carried out by public agencies in the EU, and at an international level to monitor for emerging diseases and the trends with particular known diseases (such as mastitis). The data underpinning these schemes are often provided by vets that have coverage of a particular Member State. For schemes that operate at an international level, organisations that may provide information include High Commissions and Embassies overseas, reference laboratories for animal health, reference publications on animal health, the World Organisation for Animal Health (Office International des Epizooties) and veterinary administrations of Member States. These schemes have the potential to pick up instances of disease, or adverse effects which may have been triggered by consumption of feed containing GMOs, however it is not clear the extent to which the effect could be related to GMOs, or how many livestock would have to be affected to trigger a notification under such schemes. In addition, whilst Member States have a responsibility to report certain notifiable diseases (e.g. Bluetongue), it is uncertain the extent to which other diseases information is gathered on, and are reported. In commercial livestock farming, animal performance may be the best indicator of health status. If a farmer was using a feed mix, containing GMOs which had negative effects on the performance of his stock, there is always a risk that he would simply change the feed mix, rather than reporting the effects. As such the extent to which adverse nutritional effects of using GMO varieties would be recognised in animals is uncertain. Where a compound feed has been sold that has been produced by a large processor this may be sold direct through the processor themselves, or through an intermediary merchant. In all cases there is likely to be some channel for which the farmer purchaser can record complaints or comments. This may be through an individual sales representative of the processor or EFSA supporting publication 2015: EN-739 46 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed merchant, or could be to a central switchboard directly at the company from which the feed was purchased. If the processor is able to collate adverse effects and link this with detailed composition data of the compound feed sold then a system of cause and effect, such as that practiced in Pharmacovigilance, may be possible. However, the system would rely on accurate compositional and consumption data. For detection of unintended effects in animals, again this will largely be dependent on the individual farm. It is reasonable to conclude that most livestock farmers will utilise the services of a vet, however this may only be in response to particular issues such as prevalence of a ‘well known’ disease, rather than overall health monitoring. Technologies do exist for monitoring animal health on a farm level (see data collection sources database), however only a subset of farmers would likely to be using it. Overall it can be said that each farm is individualistic, and the amount of information held will be largely dependent on the individual farmer. Initiatives are underway to develop ‘sentinel’ surveillance networks for monitoring adverse effects in primary production. An external scientific report completed for EFSA by Mönkemeyer & Schmidt (2014) presents the results of a feasibility study to investigate whether farmer/producer associations/ federations can serve as sentinel surveillance networks for the detection of adverse events in the health of agricultural plants and animals and the safety of new agricultural products in primary production. The MARLON project aims to create an inventory of which epidemiological and monitoring initiatives exist, both within and outside the EU, which could provide useful data for the purpose of monitoring for health impacts of animal feeds, in particular those containing GM ingredients, on livestock animals (see http://web.spi.pt/marlon/about.html#sthash.AeCuUq6V.dpuf). 5.7.2. Human health reporting schemes Example monitoring programmes that are used to detect unintended effects have been presented in Section 2, and are applied for a number of drugs, vaccines and cosmetics as well as herbal medicines and novel foods. Methods for gaining data on the effects of the product in the wider population include actively initiated programmes by the manufacturer such as conducting questionnaires/interviews with patients or post-clinical trials. Surveillance is also in place to respond to safety issues that may occur at any time, and utilises methods such as consumer care-lines and professional reporting card schemes. For almost all of these programmes, the product which is being monitored is often recognisable to consumers, or has a controlled prescription, so causes are often linked more easily by consumers to specific products. For example, in the case of novel foods, plant sterols in yellow fat spreads were monitored by the applicant after product launch. However, the novel food was limited to a specific product (Unilever’s ‘Flora Pro-Activ’) which was easily identifiable by the consumer. For foods containing GMOs, the identification of adverse effects by consumers becomes more difficult, as the GMO would in most cases be an ingredient in a food product. In this case, whilst label information may state that the product contained GMOs, more detailed information on which GMOs may not be given. Additionally, the reporting of adverse effects would need to be underpinned by robust consumption and composition data. EFSA supporting publication 2015: EN-739 47 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed DISCUSSION 6. WP3 - THE ABILITY TO CONDUCT POST-MARKET MONITORING OF GM FOOD AND FEED IN THE EU 6.1. Requirements under Commission Implementing Regulation (EU) No 503/2013 Commission Implementing Regulation (EU) No 503/2013 set the conditions in which a proposal for PMM should be submitted by an applicant. It states that: “Post-Market Monitoring should only be considered in cases where, notwithstanding the fact that the safety of genetically modified food and feed has been demonstrated, it is appropriate to confirm the expected consumption, the application of conditions of uses or intended effects. This is for example the case when the genetically modified food or feed has altered nutritional composition or when that its nutritional value differs from the conventional food or feed that it would replace or when there is a likelihood of increased allergenicity due to the genetic modification8” The Regulation further elaborates on the role of PMM as an outcome of the risk assessment process. In accordance with the outcome of the risk assessment, it is appropriate to confirm: a) that specific recommendations of uses are followed by the consumer/animal owner; b) the predicted consumption of the genetically modified food or feed; or c) the relevance and intensity of effects and unintended effects detected during the pre-market risk assessment which can only be further characterised by post-market monitoring. PMM can therefore be split into two main sub-sections; (a) the calculation of consumption or use of a GM food or feed in either animals or humans, which would lead to information to satisfy whether recommendations of use are followed by the consumer/animal owner, and (b) to confirm any intended, or unintended effects which have been identified during the pre-market risk assessment. Please note that the scope of the legislation does not allow for monitoring of any unintended effects which have not been highlighted at the risk assessment stage. As the Implementing Regulation concerns requirements for specific applications it can be inferred that monitoring is required by specific trait, rather than overall product. For example where two different traits confer a similar outcome, such as high oleic oil derived from genetically modified soybeans, PMM would be required separately for both traits. Given that all questions posed by the Implementing Regulation are prompted by specific questions raised, and only focuses on monitoring effects and unintended effects which are highlighted in the pre-market risk assessment, it can be classified as case-specific monitoring. As the legislation does not allow for PMM to detect unexpected effects which are not detailed in pre-market risk assessment, general surveillance monitoring is not foreseen under this legislation. The Implementing Regulation does not make any mention of the length of time an applicant would be required to monitor GM traits for. 8 Commission Implementing Regulation (EU) No 503/2013 (19) EFSA supporting publication 2015: EN-739 48 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed The aim of this section is to determine the feasibility of conducting PMM of GM food and feed under the requirements of the Implementing Regulation within the existing framework of available data sources and programmes that currently exist in the EU. 6.2. GM traits that would require monitoring In order to assess the feasibility of PMM it is pertinent to suggest which GM traits would be covered by the Implementing Regulation, namely: 1. GM food or feed with an altered nutritional composition 2. GM food or feed where the nutritional value differs from the conventional food or feed it would replace 3. GM food or feed with an increased likelihood of allergenicity due to the genetic modification A previous review for EFSA by Tompkins et al (2013) identified a list of ‘novel’ GM traits9 that may require market authorisation in the EU as food or feed in the foreseeable future. These included both quality/output traits, likely to have an altered nutritional composition or complex/input traits that benefit the farmer/grower and as a result of the modification have an increased likelihood of allergenicity. For traits (1) and (2) as listed above these would largely be classed as quality/output traits and could include traits such as those with compositional changes to carbohydrates, proteins, fatty acid profile and secondary metabolites to benefit the consumer. In some cases more developmental traits such as those which have an altered maturation or growth may be found to have different nutritional profiles. Given that these traits benefit the consumer or end-market user it is likely that they may be more recognisable further down the supply chain as they confer a higher value to the user. For type (3) this could potentially be any GM trait, including agricultural/input traits which benefit the producer rather than end user. For these agricultural/input traits, as they do not primarily benefit the end user or consumer it is likely they will be less recognisable to users further down the supply chain and thus are harder to track. Informal consultation carried out as part of this project suggests that it is unlikely traits with a higher likelihood of allergenicity would request, or be granted an authorisation under the current EU risk assessment process and thus the likelihood of these traits requiring PMM programmes is minimal. Given the information above, it is reasonable to assume that the higher the added value or differentiation that a GM trait provides its end user (either consumer or animal owner), the more recognisable it will be within the supply chain, and therefore the easier it will be to conduct a PMM programme on the product. Table.7 gives examples of the types of GM traits and their ease of monitoring. 9 GM traits with substantial modifications to the composition, metabolism and physiology of the plant. EFSA supporting publication 2015: EN-739 49 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Table 7: Types of trait that may require PMM Ease of monitoring Trait Description ‘Flavr Savr’ Tomatoes/GM tomato paste. Tomato with delayed ripening. When sold the tomato was further processed into a single branded product sold in retailers under an own-brand label and recognisable to consumers. Soybeans with high oleic acid. Soybeans with a modified seed fatty acid composition. Trait confers higher value to end markets for its use in food applications. However soybeans are placed into multiple products with or without distinct branding and are thus harder to track. Agricultural/input traits Various agricultural input traits could potentially fall under the scope of Regulation 503/2013 if they are considered to have a higher likelihood of allergenicity. These traits are not recognised once further processed and would thus be much harder to monitor. Traits requesting authorisation as food and Some traits destined for nonfeed due to the possibility of adventitious food uses may require an presence. approval as food or feed in the eventuality of adventitious/accidental presence in the food chain. In this case it would be likely that presence would be unknown and thus monitoring would be impossible. EFSA supporting publication 2015: EN-739 50 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed 6.3. What is required for Post-Market Monitoring of GM food and feed In order to achieve the outcomes of PMM as detailed in the Implementing Regulation there are a number of factors which must be known: 1. The user must know which food and feed products contain the GM trait which is to be monitored (food and feed composition data). 2. The user must know the level of consumption of these products by humans and animals (food and feed consumption data). 3. The user must then have a system/methodology to identify the relevance and intensity of intended and unintended effects. 6.4. Monitoring consumption or use of a GM food or feed in either animals or humans To satisfy the requirements of Regulation 503/2013 it is necessary to confirm that specific recommendations of use of a GM food or feed are followed, and that predicted consumption as set out in the pre-market risk assessment is as expected. This requires the applicant to understand (1) which food and feed products their trait is included in, (2) the level of consumption of those products and (3) any qualitative details to prove whether users are following product recommendations (for example preparation guidelines or maximum daily allowances). These are discussed in turn below. 6.4.1. Inclusion of a GM trait in food or feed products Our analysis has shown that the current EU regulatory requirements surrounding traceability and labelling of GM food and feed, and food more generally goes some way to ensure information is known about which GM traits are in which products, however, there are gaps. The system of unique identifiers for GM traits is an internationally harmonised system which allows for traceability of GMOs throughout the supply chain. It requires all products consisting of or containing mixtures of GMOs to carry the unique identifier. This documentation must be transmitted in writing to all operators subsequently receiving the item. This system works in harmony with wider traceability requirements for all food, where each operator in the supply chain must know whom he has purchased material from, and who this has been sold to (unless this is to final consumers). For food and feed ingredients or products ‘produced from GMOs’ (such as oils) operators must only transmit information indicating which of the material or ingredient is produced from GMOs. As such written documentation on the unique identifier is transmitted through the supply chain until the point at which a raw material consisting of or containing a GMO becomes an ingredient or product produced from a GMO. This is for example the case where GM soybeans (the raw material) would be further processed into soybean oil (an ingredient); where soybeans consist or contain a GMO, and soybean oil is produced from a GMO. For PMM to be successful the final manufacturer of the food or feed product to be bought by consumers or animal owners must know exactly which GM trait is included in his particular product. Where the final manufacturer is purchasing raw materials consisting of or containing GMOs this would be possible under Regulation 1830/2003, however, where the manufacturer is purchasing in ingredient produced from GMOs, information on the unique identifier would not legally be required. As such, in order to fully understand which GM traits are included in which products to be sold to consumers or animal owners the unique identifier would need to be passed on at every step of the supply chain, even for ingredients or products produced from GMOs. Whilst operators may understand which GM traits are included in which products, regulatory requirements do not provide for information to be gathered on the amount of a GM food or feed EFSA supporting publication 2015: EN-739 51 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed included in a final product. This is particularly problematic where a product produced from GMOs is incorporated with another, for example high oleic oil derived from GM soybeans may be blended with other high oleic vegetable oils which are not GM. Additionally in the example above, the product may contain multiple GM traits of the same type. Current food and feed composition data held at the Member State level does not identify the GM components of a product, and is based on mean nutrient values for a range of products. Privately available food composition data, such as that held by grocery retailers, food or feed manufacturers is variable. For grocery retailers with ‘own-branded’ goods, data are held on provenance of the product, but the level of information varies by product (for example more data are held on primary produce than further processed products). Detailed composition data may be held by food manufacturers, however, the variability of this, above and beyond minimum labelling requirements is uncertain. For feed, composition data may be held by large feed manufacturers on specific products, however, this information is usually commercially sensitive and thus information is not held by the animal owner. Individual animal owners/farmers will likely understand what they have fed to their animals, however, this information is largely held on an individual animal owner basis. 6.4.2. Food and feed consumption data National dietary and nutritional surveys (NDNS) operated by competent bodies at the Member State level provide good detail on foods consumed by a selectively representative sample of the population. They are cognitively demanding in that they require individuals to faithfully record foods consumed. Data are gathered by broad food group such as ‘white bread’ or ‘fruit’, therefore in order for the data to be useful for PMM of GM food and feed more detail would be required on the specific food products monitored to understand which ones contained specific GM traits. As the NDNS is based on self-declared data on the types of product consumed, analysis at this level is currently not available as products are not further defined by participants than by broad type (e.g. fruit). The data underpinning the surveys is predominantly nutrient intake data, which is largely approximated from the records of food intake coupled to established food composition tables such as those developed by McCance and Widdowson in the UK. Of more value in the context of PMM is the food purchase data collected by grocery retailers and market research companies. In the UK, market research companies use sample households to record food purchases using handheld barcode scanners. The scanners contain nutritional data on 100,000 food products, either branded by manufacturers or own-brand retailer goods. Data on food purchases is also held by retailers where consumers use a loyalty card scheme, however, this only reflects what is purchased at that particular retailer. For the data collected by market research companies, demographics on the makeup of the household are collected, however, the exact level of consumption of the food by each family member is not recorded. Other organisations offer approaches whereby food purchase data are modelled by data held on nutrient intake in the NDNS surveys to approximate the level of intake by demographic group. In order for food purchase data to be useful for PMM, the data on food purchases would need to be linked to data on whether a particular trait is included in the food product, along with data or assumptions on the amount per packet/portion. Crucially, it is uncertain the level to which this market research data on food purchases occur in all EU countries, and thereby robust monitoring by Member State may not be possible. For feed, no equivalent consumption database such as the NDNS exist. Consumption data in the form of feeding records may be held by individual animal owners such as farmers, however there are no initiatives found during this project that have attempted to gather such information. Determining consumption data by individual animal may be possible for certain species, such as dairy cows where individual feed intakes are recorded electronically. Where livestock are kept extensively or in large quantities (such as pigs and poultry) determining the individual feed intake of particular animals EFSA supporting publication 2015: EN-739 52 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed would be difficult. If the scope of PMM includes fish then PMM by this group of animals is unlikely to be possible due to the unknown numbers of animals. 6.5. Monitoring the relevance and intensity of effects and unintended effects detected during the pre-market risk assessment To satisfy the requirements of Regulation 503/2013 it is necessary to identify the relevance and intensity of intended and unintended effects that are detected during the pre-market risk assessment. The literature sourced in the systematic review (Work Package 1) gives a comprehensive overview of existing PMM programmes, for products such as: drugs, cosmetics, vaccines, novel foods and herbal medicines, which are primarily used to report adverse reactions in those using the product. The examples give detail on how systems are operated, how reports of adverse effects are collected and how the cause of an adverse event can be attributed, or not, to the product in question. Both active (a study is initiated to test effects) and passive (spontaneous reports are collected) methods are used to collect adverse event data. In all programmes, unlike GM food and feed those conducting the monitoring have robust information on which products contain the item that is being monitored. For drugs and vaccines, and in some cases herbal medicines, these are prescribed products and as such, exact information is available on the level of consumption and composition. In all other instances (novel foods, herbal medicines and cosmetics) the item to be monitored is usually contained in a limited number of products which are distinctly branded to be recognisable to vendors and consumers. Consumer care lines are often utilised in these products, as a means by which consumers can report any adverse events they experience. Wellestablished systems, for healthcare professional reporting of adverse events, caused by drugs and vaccines are in operation in many countries. The major criticism of ‘vigilance’ PMM programmes for drugs, vaccines and cosmetics which use passive surveillance approaches, is the consistent level of under-reporting of adverse drug reactions (ADRs), by both consumers and healthcare professionals. The benefits of taking an active approach to monitoring are that these methods will capture adverse events even if there is a delay between product consumption and the event, and allow for the monitoring of multiple outcomes within the same scheme. As active surveillance generally involves establishing a robust study with more intensive monitoring, it is of course more time consuming and costly. The review showed that the consensus among authors was, that a combination between active and passive surveillance methods is likely to be of most benefit. A major barrier to the implementation of the types of schemes described above for GM food and feed is the scale at which inclusion of these traits occurs within these products. For the examples given above, all items whether medicinal or food based are only included in a limited number of products meaning that monitoring efforts can be relatively directed. For GM food and feed, the trait is often included in varieties of basic commodity crops e.g. soybean, which could be used as an ingredient in multiple food and feed products at different levels of inclusion. This makes establishing a reliable system of PMM more difficult. For animals the literature review found comparatively little evidence on the existence of PMM programmes. The few papers identified, focussed on veterinary Pharmacovigilance of medicines administered to animals. The International Cooperation on Harmonisation of Technical Requirements for Registration of Veterinary Medicinal Products (VICH) have developed guidelines for Pharmacovigilance in this context, however, given the number of papers found on PMM in animal situations it is reasonable to conclude that this is not a well-developed area and more evidence is required. More general animal health monitoring occurs at a national level to monitor for disease occurrence, and possible outbreaks of exotic diseases. These programmes are operated at a country level and use regionally based vets as reporters. These schemes have the potential to pick up instances of disease, or adverse effects which may have been triggered by consumption of feed containing EFSA supporting publication 2015: EN-739 53 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed GMOs, however, it is not clear the extent to which the effect could be related to GMOs, or how many livestock would have to be affected to trigger a notification under such schemes. In addition, whilst Member States have a responsibility to report certain notifiable diseases (e.g. Bluetongue), it is uncertain the extent to which other diseases information is gathered on, and are reported. Overall monitoring adverse or intended effects in an animal population has received much less focus than in human populations and existing programmes would most likely need focus in order to be a reliable method of reporting adverse effects in livestock due to the consumption of specific GM traits. CONCLUSIONS This project has provided a comprehensive review of the design of PMM programmes that exist across the world relating to food or feed intake, human and animal health as well as a review of existing data which is collected in the EU and could aid the implementation of PMM of GM food and feed. It is concluded that the largest barrier to conducting PMM for GM food and feed is the ‘unrecognisable’ nature of GM traits further down the food supply chain, that is GM food and feed is sold and branded as a seed to farmer/growers to be passed through a complex supply chain before being included in food or feed products. Through this supply chain the raw material has the potential to be mixed with other similar GM food or feed, or other conventional ingredients (such is the case with vegetable oils where there may not be one distinct source of raw material). The regulatory framework for traceability and labelling on GM traits does not allow for identification of specific traits once the raw material is further processed to become a product. The likelihood of being able to identify the GM food and feed after this point rests in its visibility to users further downstream. For example, soybeans with a high oleic oil profile may be recognised further downstream as ‘high oleic soybean oil’ and could be monitored as such. The ability to achieve this rests in how the product is used further downstream and its potential to be mixed with other products. Table.7 gives an overview of which type of GM traits may be easier to monitor than others, with those sold as a distinct and recognisable product being the easiest. A food or feed manufacturer may keep detailed raw material specifications on their products to understand the proportion of certain ingredients included, however, the information known on these ingredients in many cases may not extend to the specific GM trait included. For compound feeds produced by large manufacturers, detailed composition data other than a basic proximate analysis is generally not made available and is commercially sensitive information. This is a large barrier to the PMM of GM feed as potentially it is not possible to understand which GM traits are in which products, and to what proportion. For consumption data this project has shown that data held at the national level, collected by public bodies for food is of only limited use to a system of PMM for GMOs. This is largely as the data held is in reference to ‘generic’ products such as ‘white bread’, rather than specific products or branded goods. As a result of this, the extent to which the product referenced contains the specific GM traits to be monitored is unknown. Food purchase data held by market research companies and grocery retailers holds promise as a method to monitor consumption of GM food, however, these data are not nationally representative in most Member States. Widespread data on feed consumption are not generally available, and if held is often at an individual farm level. Where particular farms exist in which robust consumption data are available per animal, this may hold promise to carry out PMM of GM feed on a small scale. Given these barriers it is reasonable to conclude that widespread PMM of GM food and feed across multiple populations and for all products containing the trait is unlikely to be possible without changes to the requirements around traceability, and efforts to pull together additional data on products containing GM traits. These requirements are detailed below in Section 7. EFSA supporting publication 2015: EN-739 54 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed If reliable consumption and composition data are known, the monitoring programmes detailed in WP1 of this project give a basis for designing PMM programmes to characterise the relevance and intensity of effects and unintended effects detected during the pre-market risk assessment. Of all the examples presented, PMM programmes for novel foods are the most relevant for GM food and feed. These examples used a combination of approaches, such as spontaneous reports through consumer care line (passive surveillance) through to initiated cohort studies to test the occurrence of reported effects in order to determine the relevance to the product in question. Pharmacovigilance and similar programmes are not easily translated to GM food and feed as a) in the case of pharmaceuticals and vaccines the exact dose of the product is known, and b) they are designed to identify adverse effects which are not detected in any pre-market risk assessment. The project has found a large knowledge gap in terms of the experience in monitoring for adverse effects with regards to animal health. Veterinary Pharmacovigilance is not widely used, and comparatively little experience is found in this area. 7. WHAT EU WOULD BE REQUIRED TO CONDUCT PMM OF GM FOOD AND FEED IN THE Based on the findings from this project this section gives detail on what would be required to conduct PMM for GM food and feed in the EU according to the requirements of Implementing Regulation 503/2013. 7.1. Greater detail in requirements for traceability of GMOs In order to monitor the occurrence of specific GM traits in food and feed products, greater complexity in traceability requirements for GMOs would be needed. We have shown in this project that current traceability requirements only require the operator to detail which traits are in which batches of raw material, ingredients or products up until the point that it is further processed to become an item ‘produced from GMOs’ (i.e. not containing the LMO). In order to accurately know which traits are included in which final product, the unique identifier would be needed to be carried through the supply chain to this stage. This would require more complex traceability requirements, resulting in greater administrative burden on operators further down the supply chain. 7.2. A database of which food and feed products contain which GM traits, and at what proportion In order to accurately measure consumption of GM traits the user would need to understand at what proportion they are present in the final products. This would require a database (or similar) of products which contain GM traits, and at what level they are included in the product. For some products this may be easier than others. Of particular difficulty is determining this for products whose composition may change due to various external factors. For example a bottle of vegetable cooking oil may contain the oils of multiple vegetables, and the exact quantities of oil from each vegetable may change depending on the price of the commodity, and its quality at any given period. 7.3. Consumption data at the branded product level To accurately monitor consumption of particular GM traits, robust data would be required for all branded products which contain the trait. This would likely need to involve those further down the supply chain who are the ultimate vendors of the product (whether food or feed). In this report we have listed sources of consumption data where they exist, however for all data there are caveats on calculating exact consumption of a product. In many cases, where purchase data is known, exact consumption of the product by all members of the household/individual animals and the amount of wastage is uncertain. EFSA supporting publication 2015: EN-739 55 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed 7.4. A system for reporting the relevance and intensity of effects and unintended effects Under the requirements of Implementing Regulation 503/2013 the user must identify the relevance and intensity of intended and adverse effects which are detected during the pre-market risk assessment. This may involve the use of active or passive surveillance models which have been detailed in WP1 of this project. Of these the PMM strategies developed for novel foods are of most relevance, models for Pharmacovigilance and its equivalents can be helpful, but are not directly comparable as in the case of pharmaceuticals and vaccines the dose of the product is usually known to a precise level. The remit of the legislation does not require the user to monitor for unintended effects of a GM trait, which have not been highlighted at the pre-market risk assessment stage, and thus the passive surveillance models of Pharmacovigilance schemes to pick up Adverse Drug Reactions (ADRs) are of only limited use. Nevertheless, approaches such as the passive surveillance of novel foods using consumer care lines and active surveillance, with initiated studies may be useful to identify the relevance and intensity of intended or unintended effects of GM traits highlighted during the risk assessment. 7.5. An agreement on who is responsible for carrying out PMM Overall, it is clear that for a robust system of PMM to work, co-operation throughout the supply chain would be required. The wording of Implementing Regulation 503/2013, taken from Regulation (EC) 1829/2003 stipulates that a proposal for PMM must be submitted by the applicant. In many cases, applicant companies for GM traits are those engaged in the selling of seeds to farmers, and whilst the traits they develop may be intended to benefit a user further down the supply chain, these companies will often not be marketing the end-product. As co-operation is needed throughout the supply chain in order for a system to work effectively, clearly this will also have resource implications for stakeholders other than the applicant company (such as grocery retailers and food manufacturers). In the case of novel foods, those conducting PMM have been the ones who developed the novel food, but were also engaged in marketing it as a final product (an example being Unilever who marketed phytosterol-esters in the branded spread, ‘Flora Pro-Activ’). For PMM of GM traits to work, agreement would be needed on who is responsible for PMM, and who would pay. 8. PMM METHODOLOGIES CURRENTLY FEASIBLE IN THE EU The points above show what changes would be required to conduct effective PMM according to the requirements of legislation. These changes would likely take time to enact and as such the below sections give an overview of the design of PMM schemes that could be conducted within the constraints of existing data collected in the EU at the present time. The level of detail and granularity required in PMM will dictate its effectiveness, and the points below detail ways in which PMM could be carried out to a less detailed extent, but with less administrative burden. 8.1. Less detailed monitoring Determining which products contain which GM traits, and at what proportion, as well as calculating robust consumption figures are major difficulties in conducting a PMM programme. Less detailed monitoring could be carried out based on import figures of GM traits as raw materials, or ingredients into the EU. For example figures detailing the quantities of bulk soybeans or soybean oil from a particular GM trait could be presented, as at this stage the item would still hold the 9 digit unique identifier. These figures could be matched with data on the quantity of generic products such as vegetable oil consumed in the EU, including figures on the quantities of different oils consumed to give an indication of the total amount of the GM trait consumed. This monitoring would give no specific information on the amount of the GM trait consumed by individual humans or animals, and thus would not give robust information on questions such as whether the trait was replacing other products in the diet, or changing consumption patterns. This type of monitoring is foreseen to be EFSA supporting publication 2015: EN-739 56 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed possible within the constraints of existing data collected within the EU, and whilst it may not comprehensively meet all the requirements of Implementing Regulation 503/2013, could provide knowledge as a starting point. 8.2. Small scale monitoring of GM traits If large scale monitoring of all food and feed products containing GM traits was seen as unfeasible, small scale monitoring of a selection of ‘reference’ products could be carried out. This system could utilise a selection of products where robust information is held on their composition (the particular GM traits included and at what proportion), and their consumption. Data, such as that collected by market research agencies using hand held scanners in sample households could be used for this purpose. This system is similar to the type of monitoring carried out for novel foods, which utilises market research data. Small scale monitoring of GM traits could serve to provide a set of data and results which may inform the design of less detailed monitoring as discussed in Section 8.1. More work would need to be done to develop this area to ensure that a set of reference products could be included which were representative of the use of GM traits overall. For PMM of feed containing GM traits this would likely be more difficult, as data sources are not as prevalent for food. Additionally, this review has shown that market research data is collected more widely in some EU MS than others. EFSA supporting publication 2015: EN-739 57 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. 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EFSA supporting publication 2015: EN-739 68 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed APPENDIX/APPENDICES Appendix A. WP1 Paper Review Table The below table summarises the results of all papers that were included in the final review as part of Work Package 1, review of existing PMM programmes. Date Published Authors Title Location 1999 Abenhaim L, Moore N & Begaud B The Role Pharmacoepidemiology Pharmacovigilance 2009 Agorastos T, Chatzigeorgio u K, Brotherton JML & Garland SM Safety of human papillomavirus (HPV) vaccines: A review of the international experience so far EFSA supporting publication 2015: EN-739 of in Aim Global To look at the benefits and role of pharmacoepidemiology in Pharmacovigilance. Global To report on the international experience with the safety of prophylactic HPV vaccines Monitoring method Discusses spontaneous reporting and epidemiology studies. Spontaneous reporting case identification is described as investigator independent, whereas epidemiology study case identification is described as investigator driven. Pharmacoepidemiological methods discussed include field casecontrol studies, record linkage databases, practice databases and field cohort studies. Uses include: determining causality of an adverse event, assessing the risks in the absence of an epidemic e.g. reports occur spontaneously within the population and preemptively when there is no alert e.g. a new drug or when there are suspicions. Literature review looking for reported adverse effects. Most systems in vaccine surveillance are passive, relying on selfinitiated reporting. These systems can be influenced by things e.g. media attention which could affect reporting rates. Active surveillance can be conducted, by extracting safety information from health systems databases and reviewing the scientific literature to confirm cases. The report then showed examples of how different countries monitored the HPV vaccine. Australia, the USA, Europe and Canada all used passive surveillance monitoring methods, where data was collected (regionally or centrally) and reviewed by experts to determine causality. In Canada active surveillance was also recorded on certain paediatric wards in several hospitals. 69 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published Authors Title Location Aim USA Describe the FDA's PMS program and highlight the importance of physicians in this task, with the hope of increasing reporting. 2003 Ahmad SR Adverse Event Monitoring at the Food and Drug Administration 1986 Alberman E Post-marketing surveillance of oral contraceptives UK effects on reproduction of preconceptional oral contraception 2010 Alemayehu D, Andrews EN, Glue P & Knirsch CA Considerations for the Design and Conduct of a Pharmacovigilance Study Involving Mass Drug Administration in a ResourceConstrained Setting Tropical/ Resource Constrained Conduct and reporting of multi drug administration studies and the main features that distinguish these trials from typical clinical trials. EFSA supporting publication 2015: EN-739 Monitoring method Spontaneous reports from pharmaceutical companies and physicians/pharmacists on adverse events are collected and scrutinised by Food & Drug Administration (FDA) safety evaluators. Evaluators look for additional cases in (Adverse Event Reports) AERS database and medical literature. Then searches begin for common trends, patterns of events to identify risk factors. Confirmation of signals is done using large claims databases and through foreign regulatory agencies and World Health Organisation (WHO) Uppsala Monitoring Centre. Confirmation of signal is followed by regulatory action e.g. changing of warning label/ removal of drug from market Discusses routine monitoring of trends in mortality and morbidity; retrospective case-control studies and longitudinal studies. Longitudinal studies work by continuous follow-up of patients from the time of first exposure to a specific drug and by comparing the incidence and nature of adverse drug reactions in exposed and control patients. Little bit of information on the benefits of retrospective studies over longitudinal e.g. cheaper and easier to run. Pharmacovigilance- Randomized, open label, community based cohort trials. Both active and passive systems should be put in place, although passive systems may be easier in a resourceconstrained setting. Questionnaires and case-report forms should be simple and easy to use for efficient reporting and electronic records are preferable. It is the investigators responsibility to extract all the relevant information from the patient e.g. demographics and concomitant drugs to help inform causality assessment. 70 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published 2013 2001 2012 Authors Alger HM, Maffini MV, Kulkarni NR, et al. Allgood GS, Kuter DJ, Roll KT, et al. Amarasinghe A, Black S, Bonhoeffer J, et al. Title Perspectives on How FDA Assesses Exposure to Food Additives When Evaluating Their Safety: Workshop Proceedings Postmarketing Surveillance of New Food Ingredients: Results from the Program with the Fat Replacer Olestra Effective Vaccine safety systems in all countries: A challenge for more equitable access to immunization. EFSA supporting publication 2015: EN-739 Location Mainly US but did consider systems around the world USA Global Aim Monitoring method To discuss FDA's approach to assessing safety of food additives The paper is a report of a workshop attended by more than 70 experts from academia, government, industry, and public interest groups to discuss the U.S. Food and Drug Administration's (FDA's) approach to assessing safety of food additives. Participants generally agreed that there were opportunities for FDA to improve the current system for ensuring the safety of substances in food. 3 major topics emerged for improving exposure assessments: Food consumption data, Greater consideration of subpopulations and cumulative dietary exposure and better interagency communication, collaboration, and coordination. To describe the results of postmarketing surveillance program Proctor and Gamble were required to carry-out on Olestra as part of the approval process Three key methods: 1) spontaneous consumer reporting 2) info obtained was subject to in/external medical evaluation 3) Continuation of clinical studies in 'real-world' populations. Clinical studies included; a re-challenge study- those who had reported (Gastro-Intestinal) GI effect, were used to see if effect could be replicated, the acute consumption study- consumers could eat as much as they wanted to prove effects of level of consumption, six week-consumption study- households recorded daily chip intake to see if olestra had any long-term effects. To minimize occurrence of vaccineassociated adverse events, to provide care to those affected. Situation and landscape analysis, in-depth analysis of the vaccine safety landscape. Worked in four key steps: Situation analysis e.g. what’s already out there; developing a blue print (building on what’s already out there); reviewing and endorsement of the blueprint and finally the implementation of the improved system. Three key findings were the need to standardise signal detection and reporting, improve communication between stakeholders and also to better use active surveillance systems in the monitoring of vaccines. 71 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published 2007 2011 2001 2001 2001 2001 Authors Arimura K, Nakagawa M, Izumo S, et al. Arlett PR & Kurz X Balkrishnan R & Furberg CD Balkrishnan R & Furberg CD Balkrishnan R & Furberg CD Balkrishnan R & Furberg CD Title Safety and efficacy of interferon-α in 167 patients with human T-cell lymphotropic virus type 1– associated myelopathy Location Japan Aim Monitoring method A postmarketing surveillance study was undertaken to investigate the safety and efficacy of interferon-α for human T-cell lymphotropic virus type 1 (HTLV-1)-associated myelopathy (HAM) under routine treatment conditions Patients undergoing treatment invited to enrol in study, and when each patient was enrolled they were examined by a healthcare specialist and a standardised questionnaire was conducted with them to obtain information on their demographics, any other conditions they had and any other drugs they were taking. During the course of the drug treatment healthcare professionals from the patient’s hospital would collect data on any improvements or declines in the patients’ health. Including drug-related health events which were then assessed for causality. New approaches to strengthen pharmacovigilance EU Find adverse reactions Spontaneous adverse reaction (individual case safety) reports, observational data, clinical trials and meta-analyses. Discusses how spontaneous reporting was/is the traditional method of pharmacovigilance but now they are looking at developing some other methods. For example: using electronic healthcare databases, as sources of observational data, used for quick response to new adrs; large simple randomised trials which are useful because outcomes can be measured during routine care processes and epidemiological methods e.g. questionnaires on discharge from hospital. Developing an optimal approach to global drug safety Global NA Discusses the different methods of postmarket monitoring of drugs in different countries around the world. (see below entries) Developing an optimal approach to global drug safety France report adrs Pharmacovigilance Developing an optimal approach to global drug safety New Zealand report adrs The intensive medicines monitoring program (IMMP) Developing an optimal approach to global drug safety UK report adrs Prescription event monitoring (PEM) EFSA supporting publication 2015: EN-739 72 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published 2001 2001 Authors Balkrishnan R & Furberg CD Balkrishnan R & Furberg CD Title Monitoring method United States report adrs The adverse event reporting system (AERS) Developing an optimal approach to global drug safety Sweden report adrs Swedish drug surveillance efforts Global To study and analyse the suspected adverse reaction drug reporting form of different countries to assess if forms capture all data. Survey of Spontaneous ADR (adverse drug reaction) reporting forms. n/a Improve safety reporting by better incorporating the perspective of the patient Patient-reported outcome of adverse event (PRO-AE): A PRO-AE is any untoward medical occurrence, whether or not considered treatment/intervention related, which is reported or transmitted directly by the patient without interpretation by a clinician or anyone else. PRO-AEs may be collected by both structured and unstructured reports. UK Provide a critical overview of the current state of pharmacovigilance of herbal medicines in the UK, and to discuss the particular challenges that this area presents. Methods for Pharmacovigilance of Herbal Medicines include: spontaneous reporting schemes (e.g. UK national spontaneous reporting scheme; WHO/Uppsala monitoring centre traditional medicines project; Herbal sector initiated spontaneous reporting schemes; intensive monitoring schemes) and other Pharmacoepidemiological study designs. 2010 Quality check of spontaneous adverse drug reaction reporting forms of different countries. 2013 Banerjee AK, Okun S, Edwards IR, et al. Patient-Reported Outcome Measures in Safety Event Reporting: PROSPER Consortium Guidance Barnes J Aim Developing an optimal approach to global drug safety Bandekar MS, Anwikar SR & Kshirsagar NA 2003 Location Pharmacovigilance of Herbal Medicines EFSA supporting publication 2015: EN-739 73 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published 2002 2012 Authors Title Bast A, Chandler F, Choy PC, et al. Botanical health products, positioning and requirements for effective and safe use Beck-Peccoz P, Minuto F, Leal-Cerro A, et al. Rationale and design of PATRO Adults, a multicentre, non-interventional study of the long-term efficacy and safety of Omnitrope® for the treatment of adult patients with growth hormone deficiency 1994 Begaud B, Moride Y, Tubert-Bitter P, et al. 2009 Benchelkh RS & Benabdallah G False-positives in spontaneous reporting: should we worry about them? Medication errors: pharmacovigilance centres in detection and prevention EFSA supporting publication 2015: EN-739 Location Aim Monitoring method Global Summarise legislation of botanical products e.g. safe products which are non-toxic The report mentions that the use of epidemiological studies and patient case report data can be useful indicators of a safety issue. The report then discusses how operational systems of pharmacovigilance for herbal medicines still need to be developed. One of the challenges is that herbal medicines are often sold over the counter and therefore it is hard to determine how much product is actually being consumed and consumers are likely to report any adverse events directly to the manufacturer of the product. European Countries To describe the rationale and design of PATRO Adults, a postmarketing surveillance study of the long-term efficacy and safety. A postmarketing surveillance study of the long-term efficacy and safety of somatropin (Omnitrope®) for the treatment of adult patients with GHD. The study is part of the post-approval pharmacovigilance plan for Omnitrope. Eligible patients were adults receiving treatment with Omnitrope® and who provided informed consent. Theoretical The aim of this paper is to determine how likely coincidental associations are to occur in the postmarketing surveillance setting. Morocco International To develop an extended role for national centres of pharmacovigilance, to include the collection of information on the incidence of adverse events related to medication errors. / Spontaneous reporting. Pharmacovigilance system. Discusses some of the limitations of spontaneous reporting e.g. underreporting, difficulty in describing users and patterns of use in the reporting population. The paper used a statistical model to see if reports could be coincidental and the results suggested that this was not the case unless the symptom was very common among the population. Pharmacovigilance centres were sent questionnaires regarding medication errors and adverse drug reactions. Root-cause analysis can be used to determine if the adverse reaction is due to medication errors or not. It works by looking at the underlying causes and environmental context in which an incident related to a medication error occurred. Names the different types of rootcause and how pharmacovigilance centres can help to prevent medication errors occurring e.g. education of healthcare professionals. 74 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published 2005 2007 1992 2008 Authors Title Bennett CL, Nebeker JR, Lyons EA, et al. The Research on Adverse Drug Events and Reports (RADAR) project Bennett CL, Nebeker JR, Yarnold PR, et al. Evaluation of Serious Adverse Drug Reactions: A proactive pharmacovigilance program (RADAR) vs safety activities conducted by the food and drug administration and pharmaceutical manufacturers Bergman U Second Thoughts Pharmacoepidemiological Perspectives Berlin JA, Glasser SC & Ellenberg SS Adverse Event Detection in Drug Development: Recommendations and Obligations Beyond Phase 3 EFSA supporting publication 2015: EN-739 Location Aim Monitoring method USA RADAR focused on uncovering previously unrecognized adverse drug (and device events). After identifying a serious and unexpected clinical event, RADAR postulated clinical hypotheses and derived case series and incidence estimates from physician queries, published and unpublished clinical trials, published case reports, FDA databases, and manufacturer sales figures. United States Comparing safety efforts for evaluating serious ADRs conducted by the FDA and pharmaceutical manufacturers vs the RADAR project RADAR pharmacovigilance program, possible adr is reported, it is then reviewed by radar staff. After review if the adr is novel & significant it goes for further investigation e.g. additional FDA case reports. Case reports are reviewed to inform hypotheses and data collection tools. Once reviewed they are assessed for causality associations according to WHO criteria. Data is disseminated via FDA, manufacturers and journals. Global Discussion of potential methods of pharmacovigilance. Article based on a paper presented at the WHO Drug Research Group Meeting in Oslo, Norway, September 1987, discusses methods of pharmacovigilance e.g. pharmacoepidemiological studies (cohort and case control), post-market clinical trials and spontaneous reporting systems. Also discusses record-linkage databases, where patient data is anonymised and validation of exposure and diagnosis are then completed. Discusses the benefits of using record linkage e.g. speed and they provide objective patient history for use in causality assessments. Touches on prescription event monitoring in the UK. USA To review the strengths and limitations of postmarketing surveillance of drugs and to make recommendations for means of continued evaluation after marketing. Review of strengths and limitations of postmarketing surveillance including methods such as spontaneous reporting, electronic databases, observational studies and large simple safety trials. 75 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published 2008 2011 2011 2011 Authors Title Berne B, Tammela M, Farm G, et al. Can the reporting of adverse skin reactions to cosmetics be improved? A prospective clinical study using a structured protocol. Bhosale VV & Gaur SPS Adverse monitoring drug Location reaction Bian J, Topaloglu U & Yu F Towards Large-scale Twitter Mining for Drug-related Adverse Events Blake KV, Smeraldi C, Kurz X, et al. The European Network of Centres for pharmacoepidemiology and Pharmacovigilance: application to diabetes and vascular disease EFSA supporting publication 2015: EN-739 Aim Monitoring method Sweden To improve the reporting of adverse reactions to cosmetics. Structured standardized protocol during clinical investigation, including skin patch testing, followed by a causality assessment. Some examples of ADR in India Information on some recent label changes of drugs, withdrawals from the market and standard methods of adverse drug reaction (ADR) monitoring with examples. The National Pharmacovigilance Programme (NPP)12 encourages the reporting of all suspected drug-related adverse events, including those suspected to have been caused by herbal, traditional and alternative remedies. ADR monitoring involves: (i) collecting the ADR data, (ii) assessing the causality between drugs and suspected reactions, and (iii) reporting ADRs to pharmacovigilance centres/ADR regulating authorities. Global An approach to find drug users and potential adverse events by analysing the content of twitter messages utilizing Natural Language Processing (NLP) andto build Support Vector Machine (SVM) classifiers. They collected a stream of Tweets which was organized by a timeline. The raw Twitter messages were trawled using the Twitter’s user timeline API [29] that contains information about the specific Tweet and the user. Europe Provide a unique point of access for all involved stakeholders, including industry or regulatory authorities, who are seeking collaboration for the commissioning or the performance of post-authorisation studies. The European Network of Centres for Pharmacoepidemiology and Pharmacovigilance (ENCePP) is an initiative led by the European Medicines Agency (EMA) aimed at further strengthening the post-authorisation monitoring of medicinal products in Europe by facilitating the undertaking of multi-centre, independent, studies focusing on safety and on benefit/risk. 76 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published Aim Monitoring method Bond RA A proposal for a national program reporting beneficial drug responses, analogous to the existing program to detect adverse drug responses. Finding post-marketing additional beneficial uses for drugs using existing monitoring for ADRs. Use existing Government sponsored system for the reporting of adverse drug responses but looking at alternative forums for collecting information on adverse drug reactions e.g. web-based forums where off-label uses are often discussed. 2010 Bons B, Audebert F, Bitaudeau C, et al. Assessment of undesirable events in cosmetic market surveillance: Background, description and use of a causality assessment method in cosmetovigilance N/A Propose a pragmatic causality assessment method which has been developed by the cosmetic industry with the purpose to specifically address the case of cosmetic products. Causality assessment method in cosmetovigilance. Causality analysis started with a review of the presence of evocative symptoms. This then guided the cosmetovigilance practitioner to follow the decision tree in function of the available information on chronological criteria. The decision tree takes into account the need for additional investigations and re-challenges results prior to arriving at a final causality score. 2009 Bousquet P-J, Demoly P, Romano A, et al. Pharmacovigilance of drug allergy and hypersensitivity using the ENDA–DAHD database and the GA2LEN platform. The Galenda project European To highlight benefits of better collection of data and co-ordinated database The paper describes setting up databases for collection of data on allergy and hypersensitivity - not a report of trial 2006 Authors Title Location 2012 Brashier DBS & Sharma S An adverse drug reaction clinic: Breathing fresh life into the pharmacovigilance programme India Report ADRs 2008 Breckenridge A Post Marketing Strategies for Medicines (letter to the editor) NA NA EFSA supporting publication 2015: EN-739 Pharmacovigilance Programme of India (PvPI)- discusses setting up a national centre for pharmacovigilance which will deal with all adverse event reports. Passive surveillance and active surveillance methods are discussed. Passive surveillance systems are spontaneous reporting forms and active surveillance will be follow-up call with patients. NA - article is a letter to the editor discussing the concept pf a life-cycle approach to drug safety and risk management strategies which are used throughout the life of the drugs' use in clinical practice. 77 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published Authors Title Location Aim Monitoring method Adverse Event Reporting System (Food and Drug Administration Centre for Food Safety and Applied Nutrition). Will allow better reporting of adverse events for food and nutritional supplements. Complaint data received via telephone, email or fax will be inputted into the system and real-time reporting features will allow the quick dissemination of information. Spontaneous reporting systems such as MEDWATCH. Health care professionals are encouraged to report serious events suspected to be caused by medications, medical devices, special nutritional products, and other products regulated by the FDA. Serious events are those that lead to death, hospitalization, significant or permanent disability, or congenital anomaly or require medical or surgical intervention to prevent 1 of these events. 2003 Bren L FDA's response to food, dietary supplement and cosmetic adverse events. USA Determine cause of incidences and help prevent their recurrence 1999 Brewer T & Colditz GA Postmarketing Surveillance and Adverse Drug Reactions: Current Perspectives and Future Needs N/A General review 2002 Bright RA & Nelson RC Automated support for pharmacovigilance: a proposed system USA To develop a new strategy for the review and analyses of adverse event reports received by FDA Pharmacovigilance. It was considered vital to place pharmacovigilance first, with all else (filing, tracking, compliance, administration) secondary. All historical and new reaction data would be coded with the new MedDRA (Medical Dictionary for Regulatory Activities) scheme. 2007 Buchbinder R, March L, Lassere M, et al. Effect of treatment with biological agents for arthritis in Australia: the Australian Rheumatology Association Database Australia To describe setting up of database and report some preliminary results Briefly describes the Australian spontaneous reporting system and some of advantages and disadvantages of spontaneous reporting. Discusses the development of a database including information on data collection, data validity and recruitment of patients. EFSA supporting publication 2015: EN-739 78 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published 2013 1991 Authors Burk M, Moore V, P Glassman, et al. Butchko HH & Kotsonis FN Title Medication-use evaluation with a Web Application Acceptable Daily Intake vs Actual Intake: The Aspartame Example EFSA supporting publication 2015: EN-739 Location USA Global Aim Monitoring method Describing a web-based application for coordinating medication-use evaluation (MUE) initiatives within the veterans’ affairs (VA) health care system. VAMedSAFE- VA centre for medical safety, use of MUE (medication use evaluation) reports on patient pharmacotherapy. It is a national centre promoting medical safety and conducting pharmacovigilance. Uses spontaneous reporting systems and integrated databases. Uses electronic healthcare data to design MUE Tracker (MUET). This systems; collects, analyses, reports and responds (incorporating human response) to assess medication use. Database contain info on demographics, prescription data, diagnoses, provider encounters, hospitalisations, lab data and procedure codes. MUET is used to identify at risk groups of patients to aid pharmacovigilance. It is the purpose of this article to discuss the topics surrounding acceptable daily intake using aspartame (APM), a widely used food additive as an example. Five different methods, 2 USA, 1 Canada, 1 Germany and 1 Finland 1) USA- MRCA: Menu Census Survey, 14 day dietary intake diaries. All food eaten in and outside of the home are recorded for every member of the family. Intake= no. of times individual consumes product containing aspartame x portion size (age & sex) x amount of ingredient in product 2) USDA Survey of food intakes by individual: 1 day diary surveys of 1500 adult females 3) Canada: Survey of 5000 individual chosen as representative of Canadian population. 7 day consumption diary kept in winter and summer. 4)Germany: 1 day dietary survey of 2300 individual 5)Finland: Consumption by diabetic adolescents evaluated over 48hr period 79 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published Authors Title Butchko HH, Tschanz C & Kotsonis FN Postmarketing surveillance of food additives 2008 Butler SF, Budman SH, Licari A, et al. National addictions vigilance intervention and prevention program (NAVIPPROTM): a real-time, product-specific, public health surveillance system for monitoring prescription drug abuse 2010 Caster O, Norén GN, Madigan D & Bate A Large-Scale Regression-Based Pattern Discovery: The Example of Screening the WHO Global Drug Safety Database Castle GH & Kelly B Global Harmonization Is Not All That Global: Divergent Approaches in Drug Safety 1994 2008 EFSA supporting publication 2015: EN-739 Location Aim Monitoring method Summary of surveillance for consumption and medical effects, plus clinical trials e.g. menu census surveys, food diaries postclinical trials and toll-free care lines. Discusses menu-census surveys to determine levels of consumption, with surveys conducted over a 14 day period across 5000 households. It also discusses the use of food diaries in the UK and Canada as methods of determining consumption. They found more reports of adverse events close to the first release of the product and numbers reduced over time. The National Addictions Vigilance Intervention and Prevention Program (NAVIPPROTM) is a risk management program for scheduled therapeutics. NAVIPPROTM provides post-marketing surveillance, signal detection, signal verification and prevention and intervention programs. The focus of this paper is on NAVIPPROTM surveillance, the Addiction Severity IndexMultimedia Version1 (ASI-MV1) Connect. NAVIPPROTM is a continuous, real-time, national data stream which assesses pharmaceutical abuse by patients entering substance abuse treatment clinics. Data collection includes product-specific, geographically-detailed information. Mainly US but includes some global information To present consumption, safety data to indicate aspartame is safe and system used is applicable to other food additives National, USA The primary focus of this article is to describe the ASI-MV Connect, one of the system’s continuous, realtime data streams and to demonstrate its ability to effectively monitor product-specific prescription opioid abuse within a sentinel population. 82 countries, Worldwide Implement shrinkage logistic regression for large-scale pattern discovery and evaluate its usefulness in real-world data. Shrinkage logistic regression for large-scale pattern discovery and evaluate its usefulness in real-world data. Example used is the WHO Global Individual Case Safety Report database, VigiBase, maintained and analysed by the WHO Collaborating Centre for International Drug monitoring in Uppsala, Sweden. To highlight deficiencies in global systems General review of different pharmacovigilance systems, with definitions of adverse reactions, examples of implanting pharmacovigilance in Europe and the US e.g. spontaneous reporting directly to the healthcare professional (EU) or to the manufacturer (US). Global 80 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published Authors Title Location Aim Monitoring method Some European Aims at automatically discovering ADEs that occurred in inpatients. Data Mining, natural language processing. Data are extracted from several hospitals’ electronic health records and must include information on: patient demographics, diagnoses, medical procedures, drugs administered etc. Aggregation engines transform the data into a set of events, which can then be analysed by the data mining tools. This is supposed to simplify the process of pharmacovigilance. USA Explore the use of online health forums as a source of data to identify drugs for further FDA scrutiny Machine-learning classifiers to compare messages containing watch list drugs’, pre-regulatory action to other messages containing drugs with no regulatory action. USA Detection of abuse of OxyContin and other commonly prescribed opioid analgesics at the three-digit ZIP code level across the country utilizing a number of different detection systems. Proactive surveillance program to monitor and characterize abuse, named the Researched Abuse, Diversion and Addiction Related Surveillance (RADARS) System. Discusses that randomized clinical trials (RCTs) are usually designed to provide evidence of efficacy in a disease and population, compared with the control. Details the types of reactions usually captured during a trial and discusses some other alternative methods of pharmacovigilance currently available. This paper provides an overview of ongoing initiatives exploring data from electronic healthcare records (HER) for signal detection vis-a`-vis established spontaneous reporting systems (SRS) 2011 Chazard E, Ficheur G, Bernonville S, et al. Data Mining to Generate Adverse Drug Events Detection Rules 2011 Chee BW, Berlin R & Schatz B Predicting Adverse Drug Events from Personal Health Messages 2007 Cicero TJ, Dart RC, Inciardi JA, et al. The Development of a Comprehensive RiskManagement Program for Prescription Opioid Analgesics: Researched Abuse, Diversion and Addiction-Related Surveillance (RADARS) 2008 Clark DWJ, Coulter DM & Besag FMC Randomized Controlled Trials and Assessment of Drug Safety N/A Discuss randomized controlled trials and their effectiveness on the assessment of drug safety. 2013 Coloma PM, Trifirò G, Patadia V & Sturkenboom M Postmarketing Safety Surveillance: Where does Signal Detection Using Electronic Healthcare Records Fit into the Big Picture? Global coverage Review existing systems and make comments EFSA supporting publication 2015: EN-739 81 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published Authors Title Location 2006 Cook MN Estimating national drug consumption using data at different points in the pharmaceutical supply chain 2013 Crowther M Phase 4 research: what happens when the rubber meets the road? 2012 Curtis LH, Weiner MG, Boudreau DM, et al. Design considerations, architecture, and use of the Mini-Sentinel distributed data system 1997 Czarnecki A & Maciejczyk A Pharmacovigilance in Poland 2014 Dal Pan GJ Ongoing Challenges Pharmacovigilance EFSA supporting publication 2015: EN-739 in Aim Monitoring method Pharmaceutical companies with products on the European market are obligated to provide national competent authorities, particularly in the context of pharmacovigilance, with ‘all data relating to the volume of sales of the medicinal product, and any data in his possession relating to the volume of prescriptions’ Article 23a in Directive 2004/27/EC) Comment on need for improved Phase 4 (Post market surveillance) systems and databases, by discussing current systems including their limitations and detailing new innovative methods that could be used for data capture and provides examples. Global To describe present systems that drug companies use to collect data on drug usage and how could be improved North America To highlight need for better PM surveillance USA The objective of Mini-Sentinel is to inform and facilitate the development of an active surveillance system for monitoring the safety and safe use of medical products, including drugs, biologics, and devices. Mini-Sentinel is a major component of the Sentinel Initiative, the response of the US Food and Drug Administration (FDA) to a congressional mandate to create an active surveillance system accessing electronic health data for 25 million people by 2010 and 100 million people by 2012. Poland To increase awareness of the need for drug safety monitoring. Government reporting programme, including polish ‘yellow reporting card’ for spontaneous reports. Discusses the future of pharmacovigilance in Poland e.g. regional centres, based on the French pharmacovigilance system. Global To address ongoing challenges in pharmacovigilance N/A- some information on +ves & -ves of spontaneous reporting and information on the use of informatics in PMM methodologies. 82 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published Authors Title Location Aim Monitoring method Pharmacosurveillance of CNS drugs, with brief information relating to spontaneous reporting and its limitations, epidemiological studies and assessing drug abuse. USA The primary goal of postmarketing surveillance is to provide information for risk assessment of a drug. 2009 Dart RC Monitoring risk: Post marketing surveillance and signal detection 2009 Dasgupta N & Schnoll SH Signal detection in postmarketing surveillance for controlled substances USA focus on signal detection in the postmarketing setting 2005 Davis RL, Kolczak M, Lewis E, et al. Active Surveillance of Vaccine Safety: A System to Detect Early Signs of Adverse Events US To analyse existing data and suggest better surveillance 2013 de Vries ST, Mol PGM, de Zeeuw D, et al. Development and Initial Validation of a PatientReported Adverse Drug Event. The Netherlands To develop and test a generic questionnaire to identify adverse drug events. 2001 DeStefano F The Vaccine Safety Datalink Project USA Primary purpose of rigorously evaluating concerns about the safety of vaccines. 2008 Dikshit RK, Desai C & Desai MK Pleasures and pains of running a pharmacovigilance centre. India NA EFSA supporting publication 2015: EN-739 The design of surveillance systems and development of methods for signal determination begin with development of the specific goals and objectives of a risk management program. Used a database to simulate an active surveillance system, after vaccination children were followed for four weeks to look for any signs of adverse reaction. The vaccinated children were compared to children that had not yet had the vaccine and these acted as the control group. Outcomes were classified according to a standardised system. Generic questionnaire, content validation, causality scale, cognitive debriefing plus a reliability calculation (Cohen's kapp and proportion of positive agreement (PPA). Vaccine Safety Datalink (VSD) project, mainly discusses results of the project with a small section on methods. Data is collected on a computerised system from lots of different health maintenance organisation and evaluates vaccine safety hypotheses using spontaneous reporting and literature data under joint analytical protocol. Review article - review of the National Pharmacovigilance Program (NPVP). Discusses the role of the centre, organisation and running and measures taken to increase reporting by healthcare professionals. It also covers the highs and lows of creating the programme. 83 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published Authors Title Location Aim Monitoring method India Review of pharmacovigilance with specific relevance to India. Gives a detailed overview of pharmacovigilance in general including definitions and background details. Does discuss some of the methodologies for India specifically. States they are still quite backward in terms of development of pharmacovigilance. Mentions spontaneous reporting as the cornerstone of signal detection. Report forms would be filled out by healthcare practitioners and sent to the relevant authority e.g. national pharmacovigilance programme and monitored by the Office of Drug Controller General for India, who would encourage reporting of all suspected ADRs. The forms should be completed to the highest quality and returned to the same Pharmacoviglance centre they were obtained from. Once obtained the forms then need to be assessed for causality, with data-mining to show product-event linking. State there is a need for more active surveillance but don't go into much detail. The same is true for pharmacoepidemiological studies. USA The objective of this study was to develop a data-driven algorithm that will provide a valid, reliable, and easy-to-use tool for the detection of ADRs specific in the NICU population. Data-driven algorithm that will provide a valid, reliable, and easyto-use tool for the detection of ADRs specific in the NICU population. Review of post marketing surveillance of drugs, including spontaneous adverse drug reporting, prescription event monitoring, case-control studies, cohort studies, and use of the Drug Safety Research Unit database, record linkage and randomized clinical trials. Dogra R, Garg R, Kumar V, et al. Detection, Assessment, Understanding and Prevention of Adverse Effects: Pharmacovigilance: A Review Du W, Lehr VT, Lieh-Lai M, et al. An algorithm to detect adverse drug reactions in Neonatal Intensive Care Unit (NICU) – A new approach 1999 Dunn N Mann RD Prescription-event and other forms of epidemiological monitoring of side-effects in the UK. UK To review monitoring 1998 Edwards IR Safety monitoring of new antimalarials in immediate postmarketing phase Global Report ADRs 2013 2013 & EFSA supporting publication 2015: EN-739 prescription-event Spontaneous case reports- discusses advantages cost/simplicity and disadvantages e.g. under-reporting. e.g. 84 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published Authors Title Location Edwards IR Safety monitoring of new antimalarials in immediate postmarketing phase 2000 Edwards IR Spontaneous ADR Reporting and Drug Safety Signal Induction Perspective 2012 Edwards IR 2005 Edwards R, Faich G & Tilson H 2002 Egberts ACG, Meyboom RHB & van Puijenbroek EP 1998 2007 Egberts TCG Aim Monitoring method Report ADRs Pharmacoepidemiology: case control and cohort studies allow for controlled comparison. Also briefly mentions the use of prescription event monitoring in New Zealand and the UK. Global Improve public health Suspected ADR signal generation and formation of hypotheses; analysis of the signal (confirm hypothesis/size of risk/susceptible patients); changed benefit-to-risk issues in therapy; communicate to health professionals and patients; consequence evaluation. An agenda for UK clinical pharmacology pharmacovigilance. UK To review Pharmacovigilance in broad terms. Review of pharmacovigilance including pharmacoepidemiology, data mining, and use of communication and systems technology. Points to consider: the roles of surveillance and epidemiology in advancing drug safety Global To set out 10 principles important to monitor PMS The paper sets out 10 principles considered important to consider for PM Surveillance of drugs - arose from Workshop in 2003 Netherlands Present three Dutch examples of the use of a measure of disproportionality in quantitative signal detection in pharmacovigilance. Three Dutch examples are described in which a measure of disproportionality is used in quantitative signal detection in pharmacovigilance: (i) the association between a single drug and a single event; (ii) the association between two drugs and a single event (drug-drug interaction); and (iii) the association between a single drug and multiple events (syndrome). Report ADRs Discusses the development of signal detection from use of human intellect to newer techniques e.g. disproportionality analysis. Also discusses improvements to current signal detection methods e.g. selection of appropriate control groups and restriction to subsets of people/reports. Use of Measures Disproportionality Pharmacovigilance Signal Detection Background EFSA supporting publication 2015: EN-739 of in Historical Global Global 85 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published 2008 Authors Eguale T, Tamblyn R, Winslade N & Buckeridge D Title Detection of Adverse Drug Events and Other Treatment Outcomes Using an Electronic Prescribing System 2010 Eguale T, Winslade N, Hanley JA, et al. Enhancing Pharmacosurveillance with Systematic Collection of Treatment Indication in Electronic Prescribing 1999 Evans JMM and MacDonald TM Record-linkage for pharmacovigilance in Scotland EFSA supporting publication 2015: EN-739 Location Aim Monitoring method Canada To determine the accuracy of an electronic prescribing and drug management system in documenting orders for discontinuation and dose changes of prescription drug treatment, and in identifying the reasons for the drug discontinuation and dose change. Detail what prescription event monitoring is and how it is an improvement/good addition to spontaneous reporting. They prospectively assessed the accuracy of electronic prescription records for dose change and discontinuation by comparing them with changes in treatment that were documented by physicianfacilitated medical chart review. They propose using a real-time surveillance electronic prescribing systems. Canada 1) Determining the sensitivity and positive predictive value (PPV) of using an electronic prescribing system to document treatment indications at the time of prescribing 2) Investigating the use of treatment indication data to evaluate on/off label prescribing in primary -care practice Used electronic prescribing system MOXXI (Medical Office for the XXI Century). Trialling a system where it is compulsory for physicians to select one treatment indication for each prescribed drug. Treatment indications are specific to a drug and are used to populate patient health care records. This allows a physician to see and will give notifications of potential drug-drug and drugdisease interactions. Making it easier to track adverse reactions. Scotland The contribution of record-linkage in Scotland to medical research is described Collaborative project between Medicines Monitoring Unit (MEMO) and Information and Statistics Division (ISD), which draws upon MEMO's expertise in pharmacovigilance and ISD's experience in probabilistic matching. 86 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published 2008 2012 2010 Authors Title Faden LB & Milne C-P Pharmacovigilance Activities in the United States, European Union and Japan: Harmonic Convergence or Convergent Evolution? Faich G Morris J Adverse reaction monitoring and disproportionality analysis: an update & Fan K, Sun X, Tao Y, et al. High-Performance Signal Detection for Adverse Drug Events using MapReduce Paradigm EFSA supporting publication 2015: EN-739 Location Aim US, EU, Japan To compare system in US, UK & Japan USA, but also Globally Highlighting recent developments in signal detection and management as well as providing cautions related to biases that affect reporting and analyses of adverse event databases. USA To investigate the possibility of using MapReduce principle to speed up biomedical data mining tasks using this pharmacovigilance case as one specific example. Monitoring method The paper details the main features of the current pharmacovigilance systems in the U.S., the EU, and Japan, especially post-marketing surveillance (PMS), risk management, and post-approval research (PAR). It goes on to discuss efforts to harmonize these systems and then presents a comparison of pharmacovigilance in the three regulatory regions with an emphasis on PAR. Finally the paper provides some conclusions about how much the changes taking place are related to the world getting smaller (i.e., harmonic convergence) or the problem getting bigger (i.e., convergent evolution). Spontaneous reports are submitted by healthcare practitioners, industry and patients directly to regulatory authorities/manufacturers. Most reporting in the US occurs verbally via care lines. Reports are classed as signals and are used as a preliminary indication of causal relationship. Drugs are selected for adverse event evaluation based on suspicions of causality. Data mining is used as a technique to monitor and evaluate signals. Most commonly used technique is disproportionality analysis, or comparing the observed level of a drug-adverse event occurrence to the expected drug-adverse event occurrence in a comparison group. Events with a low (close to 1) disproportionality numbers are thought to be less likely to be linked to the drug. A parallel programming model, MapReduce has been introduced by Google to support large-scale data intensive applications. This study proposes a MapReduce-based algorithm, for common ADE detection approach to datamine for Adverse Drug Events (ADE) in FDA records. 87 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published 1995 2003 2002 Authors Title Farrington P, Pugh S, Colville A, et al. A new method for active surveillance of adverse events from diphtheria/tetanus/pertussis and measles/mumps/rubella vaccines. Fernandopull e RBM & Weerasuriya K What can consumer adverse drug reaction reporting add to existing health professionalbased systems? FleuranceauMorel P How do Pharmaceutical companies handle consumer adverse drug reaction reports? An overview based on a survey of French drug safety managers and officers EFSA supporting publication 2015: EN-739 Location 5 districts England in Aim Monitoring method New method for active postmarketing surveillance of vaccine safety based on patient records. New epidemiological and statistical method based on the linkage of routinely available computerised hospital admission records with vaccination records. An active surveillance method was used to assess the attributable risk of a convulsion after diphtheria/tetanus/pertussis (DTP) and Measles, Mumps & Rubella (MMR) vaccines and to investigate the relation between MMR vaccine and idiopathic thrombocytopenic purpura (ITP) in children under 2 years in five districts in England. Mainly developing world 1) To determine the limitations of the current system 2) Suggest potential for allowing consumer reports to inform drug withdrawals France Detailing results of the questionnaire sent to drug safety officers and discussion of active consumer adr reporting Currently physician spontaneous reporting. But they suggest setting up an online, independent consumer reporting system, so that patients can report their own ADRs. They use a number of case studies which illustrate how consumers have contributed to drug surveillance by getting drugs withdrawn which have caused adverse reactions. Case studies are from; Australia and Philippines. Detailed how pharmaceutical companies deal with ADR reports from patients. Drug Safety officers from different pharmaceutical companies were sent a short-survey on how they dealt with consumer adverse reaction reports. Initially the reports went through to the secretary who directed them to the relevant authority on that particular drug usually a drug safety officer. The drug safety officer would then collect adequate info on the patient, treatment and the event to be able to confirm the report. However it was felt that consumer reports could only be considered in the signal detection process if they were confirmed by a medical source. 88 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published Authors Title 2012` Fox B Closing the Information Gap: Informing Better Medical Decision making through the Use of Post-Market Safety and Comparative Effectiveness Information 2003 Fram DM, Almenoff JS & DuMouchel W Empirical Bayesian Data Mining for Discovering Patterns in Post-Marketing Drug Safety 2013 Frauger E, Moracchini C, Le Boisselier R, et al. OPPIDUM surveillance program: 20 years of information on drug abuse in France. Fujiwara Y & Kobayashi K Oncology drug clinical development and approval in Japan: the role of the pharmaceuticals and medical devices evaluation centre (PMDEC) 2002 EFSA supporting publication 2015: EN-739 Location Aim Monitoring method means of The paper discusses the need for this type of safety information, outlines various methods to generate and manage postmarket safety and effectiveness information. And discusses the communication of safety and effectiveness information to the medical community. US To set out better information gathering USA Report on the joint effort by Lincoln and GSK to define, design, implement, test, and deploy a web based visual data mining environment for pharmacovigilance. WebVDME data mining has been used to assist with safety screening as part of day-to-day pharmacovigilance and risk management practice, and to carry out special projects for hypothesis generation and refinement as an adjunct to formalized methods (clinical trials, pharmacoepidemiological studies). France To describe the OPPIDUM surveillance (Observation of Illegal Drugs and Misuse of Psychotropic Medications) Specific population surveys, collecting anonymous data from various regional drug centres using a questionnaire which patients fill out. Questionnaires include info on patient demographics and info on the type, frequency, ingestion method and amount of drugs taken by the patient. The reports are sensed checked and the results presented to the French drug agency. Japan Discuss the current system for drug approval, discuss the post-approval re-examination and re-evaluation system, conditions under which development and review may be expedited, and mechanisms for approval of off-label usage. Japan has instituted two systems for assessing the safety and efficacy of drugs in a wider postmarketing setting. 1) Drug reexamination (Sai-shinsa) system (post-approval phase III study), 2) Drug re-evaluation (Sai-hyouka) system. 89 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published Authors Title Location Aim Monitoring method US To test monitoring system based on algorithms Authors developed a semi-automated active monitoring system that uses sequential matched-cohort analyses to assess drug safety across a distributed network of longitudinal electronic health-care data. The approach involves (i) identifying new users of a medical product, (ii) matching them by PS to new users of a comparator product, (iii) tabulating results across the distributed databases, and (iv) applying an automated alerting algorithm selected from an earlier simulation study In this study, they evaluate whether the system would generate alerts for three drug–outcome pairs USA Simulated serially accruing matched cohort data and compared the performance of alerting algorithms. Compared the performance of five classes of algorithms in simulated data using a sequential matched-cohort framework, and applied the results to two electronic healthcare databases to replicate monitoring of cerivastatin-induced rhabdomyolysis. 2012 Gagne JJ, Glynn RJ, Rassen JA, et al. Active Safety Monitoring of Newly Marketed Medications in a Distributed Data Network: Application of a SemiAutomated Monitoring System 2012 Gagne JJ, Rassen JA, Walker AM, et al. Active safety monitoring of new medical products using electronic healthcare data: Selecting alerting rules. 2011 Ghosh AK, De A & Bala NN Current problems and future aspects of Pharmacovigilance in India. India Analytical study of current problems and future aspects of pharmacovigilance in India. 2003 Gogtay NJ, Dalvi SS & Kshirsagar NA Safety monitoring: An Indian perspective India Article is a review of the country's perspective of ADR monitoring. 2009 Griffin MR, Braun MM & Bart KJ What should an ideal vaccine post licensure safety system be? USA Article is summary of conference presentations. EFSA supporting publication 2015: EN-739 No specific methods discussed. General Review. Gives definitions of terms used in pharmacovigilance and details some of the current problems with pharmacovigilance in India and how they plan to develop pharmacovigilance in India in the coming years. Review of existing ADR and the background/history to it. Discusses the two post-market surveillance centres and details how intensive adr monitoring in hospital remains the major source of information on adrs. Discusses the need to improve levels of spontaneous reporting and also stricter monitoring of herbal/alternative medicines. Summary of conference presentations regarding post-license evaluation of vaccine safety, including active and passive surveillance. 90 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published 2012 Authors Title Location Aim Monitoring method Haerian K, Varn D, Vaidya S, et al. Detection of Pharmacovigilance-Related adverse Events Using Electronic Health Records and automated Methods New York Presbyterian Hospital, USA Assess the sensitivity and specificity of the method by comparing the classification results to a gold standard. ADR signal detection using a Medical Language Extraction and Encoding System (MedLEE), a clinical NLP system developed at Columbia University. Mentions US but could apply globally. Questioning the value of enhanced postmarket surveillance systems. Discusses the three different elements of pharmacovigilance very basically. 1) data collection: info input system, to detect risks not previously identified 2) data analysis: looking for patterns of issues, new issues and increasing frequency of anticipated events 3) field safety actions: once causality is defined what are the actions you take to keep the public safe e.g. withdrawals The paper then goes onto look at when PMM can cause harm e.g. unnecessary actions cause patients to stop taking a drug where the benefits of taking it outweigh the risks of not taking it. The paper states that an inappropriate field action e.g. inserting a black box onto the product can cause more harm than good by stopping people taking the product and getting worse as a result. USA Signal-detection strategy that combines the adverse event reporting system (AERS) of the Food and Drug Administration and Electronic Health Records (EHRs). Signal detection strategy - Leverage EHRs and explicitly combine them with spontaneous reports to facilitate uninformed, hypothesis-free signal detection. Conforming to standard practice in AERS-based analysis, used the MGPS DPA algorithm (via Oracle’s Empirica Signal V.7.3) to generate ADR signals in the AERS portion of this study. 2007 Hall RF The risk of reduction: Can Postmarket surveillance pose more risk that benefit? 2013 Harpaz R, Vilar S, DuMouchel W, et al Combing signals from spontaneous reports and Electronic health records for detection of adverse drug reactions. EFSA supporting publication 2015: EN-739 91 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published 2006 Authors Hepburn P, Howlett J, Boeing H, et al. Title The application of post-market monitoring to novel foods Location N/A Aim Monitoring method Review the literature on PMM methodologies for novel foods Contact Centres - established by food companies to interact with consumers via telephone, mail, email and face to face. Trends and signals can appear through this method when a particular subject is brought up repeatedly and contact centres can serve as early warning systems for possible product problems. In addition, contact centres can ask consumers to participate in surveys which enables information to be gathered on a specific topic, thus helping a product to detect problems after launch. 2011 Hilmer SN, Gnjidic D & Abernethy DR Pharmacoepidemiology in the Postmarketing Assessment of the Safety and Efficacy of Drugs in Older Adults. USA but could apply globally Providing an overview on the role of pharmacoepidemiological studies in determining the safety and efficacy of drugs in older adults. 1998 Hoffman A, Hippius M & Sicker T Adverse drug reaction monitoring in Jena experiences of a regionalized pharmacovigilance centre Jena, Germany Pharmacovigilance project to monitor adverse drug reactions at the wards 2003 Howlett J, Edwards DJ, Cockburn A, et al. The safety assessment of novel foods and concepts to determine their safety in use. Global Discusses best practice methods to ensure the safety of novel foods and ingredients EFSA supporting publication 2015: EN-739 Discussed many different methods of pharmacovigilance including: postmarketing trials e.g. randomized clinical trials, drug-drug interaction studies, case-control, observational, pharmacoepidemiology. Talked about using current pharmacoepidemiological methods and tailoring them for older adults. Gave the pros/cons for various pharmacovigilance methods. Use of three regionalised pharmacovigilance centres and monitoring admissions to the hospitals for potential adverse drug reactions. Suspicious cases are referred to a specialised physician. Cases assessed using a predefined set of screening criteria Talks mainly about methods of pre-marketing risk assessment, but does have a small section on PLM of novel foods. Details use of consumer care lines as the main source of information on adverse reactions, where consumers are directly in contact with the manufacturer. It also briefly discusses how the general care line questionnaire format for receiving consumer complaints can be modified to fit the purpose of adverse event monitoring. It also discusses the use of marketplace surveys as a good non-invasive method for discovering adverse reactions, as panel members are not aware which foods are monitored and it give a truthful look into consumer purchasing patterns. 92 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published Authors Title Location Aim 2005 Hugman B From the Uppsala Monitoring Centre A Review of Viewpoint Part 1 and Part 2 1981 Inman WHW Postmarketing surveillance of adverse drug reactions in general practice N/A Review the yellow card system and discuss the search for new methods 2010 Iragüen D, Urcelay S & San Martin B Pharmacovigilance in veterinary medicine in Chile: a pilot study Chile To carry out a validation type study to see if Veterinary PMM can be carried out in Chile. 2011 Isah AO, Pal SN, Olsson S, et al. Specific features of medicines safety and pharmacovigilance in Africa Africa Review of factors challenging pharmacovigilance in Africa 2004 Ishaq GM, Shah MY, Koul PA & Tanki SA Adverse drug reaction monitoring with a Kashmiri perspective- need for an urgent initiative Global To review current PMM and to suggest its use in Kashmiri EFSA supporting publication 2015: EN-739 N/A Review the 2 parts of Viewpoint Monitoring method The review of the two parts of the publication. Viewpoint represents a pioneering effort to provide easily accessible information on international pharmacovigilance for lay and specialist readers. Discusses the advantages and disadvantages of the Yellow card system. Covers topics such as under-reporting and therefore the possibility of a delay in discovering adverse reactions, but also, mentions the positives e.g. remains the cheapest and easiest method of postmarketing surveillance on the market. After identifying the most commonly prescribed drugs by interviewing veterinarians using a survey questionnaire, they then carried out a pilot PMM study in 19 practices across 14 districts in Santiago. Vets were given documents describing how to report an ADR and owners were given details on adrs from their vet. An ADR form was drawn up based on European standards and vets were asked to complete the form and send it to the authors of the study. Once the study was over a visit to the clinic was organised to collect data on the number of cats and dogs treated during the trial and also to check the records for potential ADRs which had gone un-reported. Review of factors challenging pharmacovigilance in Africa e.g. presence and use of many counterfeit/herbal medicines and a lack of resources. Majority of reporting in African pharmacovigilance schemes is done via spontaneous reporting UK Yellow card and black triangle schemes. Also state that it is hard to do PMM in Kashmiri due to off-label drug use and the availability of drugs that have not had formal approval. 93 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published Authors Title Location Aim 2010 Johansson S, Wallander MA, de Abajo FJ & Rodriguez LAG Prospective Drug Safety Monitoring Using the UK Primary-Care General Practice Research Database UK To assess the feasibility of proactive monitoring of an electronic medical record system, in combination with an independent endpoint adjudication committee, to detect adverse events among users of selected drugs. 2007 Juarez-Olguin H, PerezGuille G & Flores-Perez J Pharmacovigilance and pharmacoepidemiology of drugs in a Mexican paediatric hospital, A proposed guide. Mexico Proposed guide for monitoring in children’s hospital 1991 Kapp J-F, Zentgraf R, Widmer A & Schöpf E A Need to Intensify Drug Surveillance in Germany Germany Catch serious adverse effects via more intensive monitoring. 2003 Karande S, Gogtay NJ & Kshirsagar NA Improving Monitoring India To promote better surveillance for adverse drug effects in children EFSA supporting publication 2015: EN-739 Drug Safety Monitoring method Used patient information gained from the General Practice Research Database who had newly been prescribed amoxicillin/clavulanic acid during Oct 2005-march 2006. During Oct-march 3 monthly standing enquiries were set up and information inputted into the GPRD was sent to the Spanish Centre for Pharmacoepidemiological research (CEIFE), where the data was checked by an external board of experts who identified if patients had acute liver disorder. The number of new patients required to detect the signal was also calculated. This depended on the target incidence of a specific AE and the uptake of the study product in the database. Proposed guide for monitoring in children’s hospital. Data on the adverse response is collected in a report form including: patient data, time elapsed after consumption before reaction and other drugs administered etc. If the event was considered serious it was sent to the relevant information collection system and compared to a bibliography. Briefly discusses epidemiological studies too including a couple of sentences on analysis. Spontaneous reporting is still the most commonly used postmarketing surveillance tool. In the report they suggest that more intensive surveillance of 40% of hospital beds should be sufficient to detect adverse reactions. Discuss the need for pilot studies of this more intensive monitoring and give some details of how causality would be assessed. Examination of reports from others, mostly discussing specific adrs relating to certain drugs. Does have a section at the end of the report on improvements to the surveillance system e.g. more proactive management and encouragement for spontaneous reporting and the use of electronic healthcare databases for causality assessment and ease of use. 94 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published Authors Title Monitoring marketing 1983 Kay CR 2010 Kelman CW, Pearson S-A, Day RO, et al. 2011 Khairnar Gade PR A, 2012 Khattri S, Balamuralidh ara V, Pramod KTM, et al. of Location drugs after Evaluating medicines: let’s use all the evidence Interventional Improvement in Hospital Based Intensive Monitoring of Adverse Event Pharmacovigilance regulations in India: A step forward EFSA supporting publication 2015: EN-739 Aim Monitoring method UK To describe PMM system in 1980s Sets out basis of PMM as of 1980s, including information on study design of prospective cohort study, case-control study and retrospective cohort study. Also details advantages e.g. in prospective studies the ability to design reporting forms to ensure capture of all useful data and disadvantages e.g. cost and time. Australia Limitations of the current system of monitoring medicines and propose an updated method that takes advantage of the capabilities of information technology. Propose an expanded and integrated system of medicines regulation for Australia, based on a surveillance system that improves safety monitoring by complementing existing systems, making best use of routinely collected data, and leveraging the power of information technology. India Assessing the effect of training on drug safety monitoring. 2 parts: Part A: Data collection: During daily rounds physicians were asked to collect data on any adverse reactions their patients may have had. If a potential adverse event was found data on demographics, suspected drug, allergies and concomitant medicines was obtained. The causality and severity of reports was assessed using WHO guidelines. Part B: The data on patients suffering adverse reactions was evaluated, using lit reviews and studies of the adr, by a team of health practitioners supervised by a pharmacovigilance officer. Part B was run as a knowledge transfer scheme to encourage better physician reporting. India To discuss the areas of Indian pharmacovigilance that require reform, and recommendations for an improved reporting system. NA - review article discussing the areas of Indian pharmacovigilance that require reform, and recommendations for an improved reporting system. 95 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published 2005 2009 Authors Kingston R Kristal AR, Vizenor NC, Patterson RE, et al. Title Challenges in collecting, accessing and evaluating post market surveillance AERS in patients receiving dietary supplements Precision and Bias of Food Frequency-based measures of Fruit and Vegetable Intakes EFSA supporting publication 2015: EN-739 Location USA USA Aim Monitoring method Review Various types discussed with an emphasis on spontaneous reporting, this is because there is not the same surveillance system in place for dietary supplements as there is for drugs. Spontaneous reports are likely to be sent in by consumers to manufacturers, where there is no standardised adverse event reporting form. Often supplements will have multiple ingredients at unknown concentrations which makes it hard to attribute causality. The use of care lines or telephone reporting of adrs is also detailed with discussion on the advantages and disadvantages of this technique. Examining the bias and precision of the two commonly used food frequency questionnaire approaches to measuring fruit and veg intake. Looked at three different methods for evaluating consumption of fruit and vegetables. 1) The 5 A Day method: total veg/fruit intake calculated as servings of veg/fruit. All of those that took part completed a mailed questionnaire (recalling intake over the past month), with a subset selected at random to complete a telephone interview too (24hr recall). 2) Summation method: simple sum of all servings of all relevant foods. Participants asked to complete baseline 100/144-item food frequency questionnaire. 3) Four/24hr food records/dietary recall: multiple component foods are broken down into their relevant parts for nutritional analysis. Generally completed via phone call. Development of computer algorithms to determine consumption of fruit & veg eaten alone and as component parts. 96 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published Authors Title 1999 Kubota K A Design for PrescriptionEvent Monitoring in Japan (JPEM) 2011 Layton D, Hazell L & Shakir SAW Modified Prescription-Event Monitoring Studies EFSA supporting publication 2015: EN-739 Location Aim Japan (vs UK) To compare Japan with UK UK To review how Modified Prescription-Event Monitoring (PEM) system has benefitted surveillance Monitoring method Sets out PMM system in Japan as of 1999 as compared with UK, discussing strengths and weaknesses of both. The report also details a pilot prescription event monitoring project run in Japan. Pharmacists were recruited and asked to fill in patient forms for individuals prescribed a specific drug and send them to the centre of pharmacoepidemiology in Tokyo. Six months after first prescription, questionnaires were sent to the pharmacist and prescribing physician. The physician form also included questions on whether an adverse events were suspected/had occurred. Discusses traditional prescription event monitoring (PEM) and newer modified prescription event monitoring (MPEM). Traditional PEM studies work as non-interventional observational cohort designs. Six months after initially prescribing a drug, a questionnaire is sent to the prescribing physician requesting information on the patient and any significant events which might have occurred. The MPEM questionnaire is similar to the PEM questionnaire but includes more detailed questions on specific outcomes and can be tailored to the study. Current MPEM studies are listed. 97 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published 2006 Authors Lea LJ & Hepburn PA Title Safety evaluation of phytosterol esters. Part 9: Results of a European post-launch monitoring programme. 2011 Mahmood KT, Amin F, Tahir M & Haq IU Pharmacovigilance – A Need for Best Patient Care in Pakistan. A review 2007 Manifesto signed by many The Erice Manifesto For Global Reform of the Safety of Medicines in Patient Care EFSA supporting publication 2015: EN-739 Location Europe mainly but globally applicable Pakistan Global Aim Monitoring method Report their approach to PLM and to present the findings of the programme monitoring phytosterolester spreads in Europe. Done using consumer care lines and marketplace surveys to check consumer usage is what it should be. Used independent market research companies in; Netherlands, UK, Belgium, France and Germany. Consumers are asked to scan bought food items as they place them into cupboards, which then transfers the data to a centralised market research database. The company used their well-established product care lines (across all countries) to gather data on potential adverse effects. Care line staff were trained in order that they could identify and collect the relevant information. Data was then assessed by clinicians and toxicologists for causality according to a colour coded system. Red: there is an association, orange: there is an association but cannot be explained by known properties of product, causal relationship cannot be excluded, yellow: there is an association but cannot be explained by known properties of product, causal relationship can be excluded, green: no association. The present review paper is presented with the basic To highlight the significance and need of Pharmacovigilance, in Pakistan, for ensuring best patient care. Very little in the way of pharmacovigilance in Pakistan. They do have a standardised reporting form but do not have a national pharmacovigilance database and need to invest in better pharmacovigilance centres. The report does list the three main types of reporting; spontaneous reporting surveillance (mentions systems in other countries e.g. 'yellow card scheme' in the UK, voluntary reporting and mandatory reporting. Gives brief detail on signal detection methods although nothing specific. The rest of the report tended to focus on the background to pharmacovigilance rather than specific methods. report adrs Very broad discussion, only really details that it is important to develop new and innovative methods and to encourage involvement of patients and healthcare professionals in the pharmacovigilance process. 98 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published 1998 2010 2007 Authors Mann RD Markowitz LE, Hariri S, Unger ER, et al. MartinezFrias ML Title Prescription -event monitoringrecent progress and future horizons Post-licensure monitoring of HPV vaccine in the United States Postmarketing Analysis of Medicines Methodology and value of the Spanish casecontrol study surveillance system in preventing birth defects EFSA supporting publication 2015: EN-739 Location UK US Spain Aim Monitoring method To briefly review the methodology of PEM and the current/planned activities relating to this technique. PEM monitoring. Non-interventional observational cohort-study. Each PEM study begins as soon after drug approval in England as possible and must contain a min of 10,000 patients. 6 months after the start of treatment doctors are sent a green card which seeks information on any events the patient might have experienced. The green forms are sent to the DRSU (Drug safety research unit and an interim analyses are conducted after every 2500 patients. This includes monthly lists of any events reported. To review current system and identify improvements Review of existing systems of data collection of adverse effects. Immunisation information systems (IIS) and national immunisation surveys (NIS) provide sources of data regarding potential adverse reactions associated with vaccination. Discusses the passive surveillance vaccine adverse event reporting systems (VAERS), where reports are submitted voluntarily by patients, healthcare professionals and manufacturers. Also describes the vaccine safety datalink (VSD) and the clinical immunisation safety assessment as ways of monitoring vaccine safety. Describing the research programme on the potential effects of drugs taken during pregnancy run by the ECEMC The Spanish collaborative study of congenital malformations (ECEMC) used a continuous hospital-based, case control study and surveillance system to monitor the effect of drug use during pregnancy on congenital malformations. ECEMC consisted of the data-collecting group and the coordinating group. Paediatricians assessed new-borns for both case (all information on deformities recorded and described in detail) and control (next same sex baby born in the hospital) groups, interviewing mothers to collect demographic information. This information is then sent to the coordinating group in Madrid, with defects coded for analysis. Analysis of the potential impact of drugs during pregnancy was done using secular analysis methods comparing controls to cases. 99 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published Authors Title 2013 Mazzitello C, Esposito S, De Francesco AE, et al. Pharmacovigilance in Italy: an overview 2008 McClure DL, Glanz JM, Xu S, et al. Comparison of epidemiologic methods for active surveillance of vaccine safety Location Aim Monitoring method Italy To examine the legislative framework concerning pharmacovigilance in Italy NA - review article examines the legislative framework concerning pharmacovigilance in Italy. US To use simulation to identify most effective monitoring system This was a simulation study to compare four study designs [(matched-cohort, vaccinated only (risk-interval) cohort, case– control, and self-controlled case-series (SCCS)] in the context of vaccine safety active surveillance. PMM methodologies, describes PMM as three-stage process; signal generation, signal refinement and signal evaluation. Mainly goes into detail about the second stage or the signal refinement. Defined as 'the assessment of predefined exposure outcome pairs to determine whether there is evidence of association.' Key Steps: 1) Develop a product-specific assessment plan 2)Review data validity, descriptive stats and analytic computer programmes 3)Conduct secondary analysis 4)Consider quantitative bias analysis 5) Interpret and assess report Move onto signal evaluation... Paper advocating that 'spontaneous' reporting is inadequate and more robust PMM monitoring is required using systematic monitoring of cohorts 2014 McClure DL, Raebel MA, Yih WK, et al. Mini-Sentinel methods: framework for assessment of positive results from signal refinement Global but US To determine if a positive association can be explained by something other than a cause and effect relationship, such as, information bias, selection bias or confounding after conducting signal refinement. 1999 McNeil JJ, Grabsch EA & McDonald MM Postmarketing surveillance: strengths and limitations: The flucloxacillin-dicloxacillin story Australia but references to NZ & UK To promote surveillance EFSA supporting publication 2015: EN-739 better active 100 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published Authors Title Location 2010 McNeil JJ, Piccenna L, Ronaldson K & IoannidesDemos LL The value of patient-centred registries in phase IV drug surveillance 2014 Mehta U, Dheda M, Steel G, et al. Strengthening pharmacovigilance Africa 2006 Montastruc JL, Sommet A, Lacroix I, et al. Pharmacovigilance for evaluating adverse drug reactions: value, organisation and methods EFSA supporting publication 2015: EN-739 in South Aim Monitoring method Global To highlight benefits and limitations of drug registries South Africa To outline findings and recommendations from a national pharmacovigilance workshop held in South Africa in 2012. France To give an overview pharmacovigilance in France of Presents review of drug registries to provide better surveillance than just spontaneous surveillance and gives the advantages and disadvantages of drug registries. Registries facilitate prospective cohort studies and allow the researchers to determine the incidence of multiple outcomes at once. Good at determining drug safety in specific populations but to avoid bias control groups must be chosen carefully. Improvements to the current pharmacovigilance programmes running in South Africa. Currently they have targeted spontaneous reporting (specific drugs or patient groups) and some active surveillance using cohort studies and cohort event monitoring. Confirmed that they needed: a national and centralised pharmacovigilance system, which should contribute to policy decision making. The system should incorporate both active and passive surveillance and understand the importance of both. Investment in training and communication with stakeholders to ensure the success of the programme. Current progress in national system for targeted spontaneous reports with all spontaneous reports reviewed by sub-district health teams. The paper describes a number of different methods including; spontaneous reporting (in France this is mandatory), active surveillance including, longitudinal cohort studies and case control studies and it also mentions the use of electronic prescribing databases to improve detection and quantification. It also details the roles of regional pharmacovigilance centres in collecting, evaluating (causality assessed using probabilistic approaches e.g. intrinsic and extrinsic causality) and exploiting data on ADRs. Reports are then sent to a national centre for collation before being sent to the WHO. 101 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published Authors Title 2011 Monteiro SAMG, Takano OA & Alves Waldman E Evaluation of the Brazilian surveillance system for adverse events following vaccination 2005 Moore GE, Frana TS, Guptil LF, et al. Postmarketing surveillance for dog and cat vaccines: new resources in changing times 2012 Mutebi A Patient- reported outcomes in the post-approval environment: Opportunities and challenges EFSA supporting publication 2015: EN-739 Location Aim Monitoring method Brazil To describe and evaluate the Brazilian system of passive surveillance of adverse events following immunization (PSAEFI). Collection of data from health professionals followed by analysis. Evaluation was done by analysing reported adverse events to vaccines, using a methodology developed by the centre for disease control. Mainly US Discussing current PMM methods for vaccines and discussing potential future surveillance methods for vaccines. Discussing spontaneous reporting methods and epidemiological follow-up investigations. Discusses using veterinary practice databases to provide information for postmarketing surveillance. Also discusses strengths and weaknesses of surveillance methods. USA Exploring the opportunities and challenges of collecting and using patient-reported outcomes in the post-approval environment. Looks at utilising Patient Reported Outcomes (PRO) data. Gives a few examples of where this might be useful e.g. comparing new therapies with existing therapies because you have real-time patient data and using PRO data with existing claims data to potentially confirm signals, meaning PRO data could become a very useful tool for practitioners, researchers and policy makers. 102 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published Authors 2012 N/A 2000 Neuhouser ML, Patterson RE, Kristal AR, et al. Title Pharmacovigilance communicating information Location and safety Do consumers of savory snacks have poor-quality diets? EFSA supporting publication 2015: EN-739 Aim Monitoring method Europe-wide (UK focus) Providing an explanation of the on the process of pharmacovigilance and how new information on adverse events is communicated to healthcare professionals. Post-marketing trials, prescription event monitoring, pharmacoepidemiological studies, spontaneous reporting e.g. Yellow card scheme in the UK, literature reviews. Healthcare professionals and the public report adverse effects to the MHRA where it is added to the MHRA drug database. The MHRA monitor the database and the literature to determine if any new adverse reactions are being reported and can have causality attributed to a specific drug. Previously in the UK drugs that required more intensive monitoring had a black triangle placed on the label. Use of the Eudravigilance database (European database on adverse effects) as a centralised adverse event reporting centre across Europe to reduce complexity. Mandatory additional monitoring programmes and scope of reporting using 'yellow card scheme' extended to include overdose, medication errors, occupational errors etc. US Purpose of this report is to assess associations of overall diet quality with consumption of high-fat, reduced fat and fat-free savoury snacks. Used Telephone surveys and clinic questionnaires to work out nutritional intake and snack food questionnaires. Diet quality was calculated based on scoring against Diet and Health recommendations for healthy eating. Score 0 was healthy score 3 was unhealthy. 103 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published 2000 2010 2010 Authors Title Location Aim Monitoring method Neuhouser ML, Patterson RE, Kristal AR, et al. A brief dietary assessment instrument for assessing target foods, nutrients and eating patterns. USA To develop and validate the new dietary assessment tool, focussed recall. Used focussed recall methods in a large population based study to assess intake of olestra. Participants were asked to take part in focussed recall questionnaires and a larder inventory. The focussed recall was split into 6 sections corresponding to different times of the day and interviewers asked whether participants has eaten fruit or veg during the day. Trying to get portion sizes for those items where a mixed level of different fruits or vegetables may have been consumed. After completion of the focussed and larder questionnaires a 24hr dietary recall was administered. Interviews were trained and used a standard script, fruit and veg consumption was calculated using automated food grouping systems. Olsson S, Pal SN, Stergachis A & Couper M Palaian S, Ibrahim MIM, Mishra P, et al. Pharmacovigilance Activities in 55 Low- and Middle-Income Countries: A QuestionnaireBased Analysis Global To assess current and planned pharmacovigilance activities in low and middle-income countries Questionnaire to representatives from 114 countries to gather information on pharmacovigilance activities within those countries. Pharmacovigillance activities in Nepal Nepal NA NA - Letter to the Editor EFSA supporting publication 2015: EN-739 104 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published 2007 2010 Authors Payne DC, Franzke LH, Stehr-Green PA, et al. Prabhakar U & Edwards B Title Development of the Vaccine Analytic Unit's research agenda for investigating potential adverse events associated with anthrax vaccine. Postmarketing safety surveillance Issues with Data Collection for Postmarketing Pharmacovigilance EFSA supporting publication 2015: EN-739 Location USA Global Aim Monitoring method To describe the development process the VAU used to research the anthrax vaccine safety A collaboration between the Department of Defence (DoD) and the Centres for disease control and prevention (CDC) with input from the FDA, formed the Vaccine Analytic Unit (VAU). They wanted to look at potential adverse effects experienced after administration of anthrax vaccines in military personnel. They used the DMSS a longitudinal surveillance database to collect historical health data on the military personnel and decided on a list of potential adverse reactions which could be associated with the vaccine. This list would then be prioritised using 6 criteria for further areas of research. The 6 criteria were; Feasibility, Frequency of Occurrence, Severity of effect, Programmatic interventions, Likelihood of association and public health concern. One criteria were established the adverse effects were reviewed and the top 11 priority considerations were decided during independent review by VAU staff. Next steps will be to monitor these 11 more closely for signs of possible association. Discussing spontaneous reporting, methods, current issues and improvements Discusses spontaneous reporting in detail, although not much on actual collection of reports. Talks about reporting forms and differences between UK (reports mainly go to regulatory authorities) and the US & Germany (reports mainly go to manufacturers first.) Mentions yellow card scheme and adverse incident reporting schemes, although doesn't detail what the forms entail. When interviewers are going through forms with patients, structured questioning should be encouraged by providing a structured questionnaire to make sure all the relevant information is obtained including; drug-food interactions, medication errors, drug-use in pregnancy, abuse and misuse, drug withdrawal, dose escalation or reduction and lack of efficacy. 105 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published 2011 Authors Reynolds RF, Lem JA, Gatto NM & Eng SM Title Is the Large Simple Trial Design Used for Comparative, Post-Approval Safety Research? Location US Aim Monitoring method Consider if large simple trial is most suitable study design To evaluate whether large simple trials (LSTs) are used for comparative safety evaluation and if the design is, in fact, advantageous compared with other designs, a review of the published literature (1949 through 31 December 2010) was conducted and the ClinicalTrials.gov registry (2000 through 31 December 2010). Thirteen ongoing or completed safety LSTs were identified. The design has rarely been used in comparative drug safety research, which is due to the operational, financial and scientific hurdles of implementing the design. The studies that have been completed addressed important clinical questions and, in some cases, led to re-evaluation of medical practice. It concludes that the design has demonstrated utility for comparative safety research of medicines and vaccines if the necessary scientific and operational conditions for its use are met 2012 Robb MA, Racoosin JA, Sherman RE, et al. The US Food and Drug Administration's Sentinel Initiative: Expanding the horizons of medical product safety. USA Give an overview of the minisentinel initiative. Mainly discusses the introduction of the mini-sentinel scheme by the FDA and how they will use data currently collected for claims databases or electronic health databases to actively monitor for adverse drug reactions in real-time. The process involves three stages. 1) Signal generation- using statistical methods to identify drugadverse effect associations. 2) Signal Refinement- identified potential safety signals are further investigated 3) Signal evaluation- implementing full epidemiological analysis to fully evaluate causality. Spontaneous reporting is briefly mentioned as the previous cornerstone of pharmacovigilance. 2011 Ronaldson KJ Maintaining and enhancing the value of spontaneous reporting programmes Global To discuss the benefits and potential future benefits of using spontaneous reporting systems. Spontaneous reporting programmes (SRPs). Discusses the general benefits and potential future uses of spontaneous reporting in combination with other reporting systems. EFSA supporting publication 2015: EN-739 106 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published 2009 2008 2009 2008 Authors Title Location Ronaldson KJ The new age pharmacovigilance Sautebin L Understanding the Adverse Effects of Cosmetics A pilot project in cosmetovigilance Savage RL, Kunac DL & Johansson J Appraising the post-marketing safety of medicines: A description of national and international pharmacovigilance with a focus on medicines used in chronic pain Schuchat A & Bell BP of Monitoring the Impact of Vaccines Postlicensure: New Challenges, New Opportunities EFSA supporting publication 2015: EN-739 Aim Monitoring method Looking at improving/ supplementing pharmacovigilance passive surveillance systems in Australia by using additional information gained from active surveillance forms e.g. epidemiological approaches like randomised-control trials, registries of new drugs, data-linkage and case-control studies. Does discuss spontaneous reporting as the major mechanism for adverse drug reaction reporting. Dermatologists and pharmacists were enrolled to help develop a standard reporting form for adverse effects for cosmetics. Once the form was completed they were asked to notify the study directors using the form of any adverse events that were reported to them by their patients/consumers. Reports were then validated and evaluated by the study directors for completeness and relevance with any extra info required obtained from the pharmacists/dermatologists. Australia Give an opinion on the TGA strengthening pharmacovigilance, without implementing strategies to encourage the conduct of epidemiological research Italy To trial a pilot project testing the effectiveness of a notification system for adverse events from cosmetics. New Zealand To describe the role of pharmacovigilance in detecting and evaluating evidence of adverse drug reactions. Voluntary reporting systems, cohort event monitoring, specific monitoring of medication error, data-mining, health care databases, general practice records. Address key aspects of postlicensure surveillance for VPDs with an emphasis on the US experience Postlicensure surveillance for vaccine-preventable diseases (VPDs). Surveillance can be carried out by either passive or active methods. Passive surveillance constitutes the default for most public-health systems and may be sufficient for evaluation of trends in disease and characterization of clinical and epidemiologic features of illness. Active systems generally involve soliciting case reports from all participating components of the system (e.g., laboratories, hospitals, clinics or schools) and typically involve reporting of zero cases when no episodes have been detected. USA 107 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published Authors Title Sharrar RG & Dieck GS Monitoring product safety in the postmarketing environment Global Review of pmm Review- details methods for active and passive surveillance. Also contains information on disproportionality analysis. Gives pros and cons of spontaneous reporting. No specific methodologies. 2005 Shuren (FDA) International Conference on Harmonisation (ICH); Guidance on E2E Pharmacovigilance Planning; Availability EU, Japan and US Conference summary. Not much information but discusses observational studies. 2005 Simojoki M, Luoto R, Uutela A, et al. Finland Purpose of this post-marketing study is to characterize users of plant stanol ester margarine with and without cardiovascular disease. Fifteen independent health surveys conducted by the National Public Health Institute in Finland between 1996 and 2000 were combined into study cohort. Subjects who reported myocardial infarction, stroke, hypertension, heart failure, angina pectoris or intermittent claudication were classified as having cardiovascular disease. To examine the 35 years of phase IV trial obligations. Long report covering: pre-marketing approval, history of phase IV, and the authority of the FDA over regulations in drugs safety and persuading drugs companies to run trials. Talk about spontaneous reporting and how legally manufacturers are required to pass on any reporting forms, from healthcare professionals which detail the adverse event experienced by the patient. Talk about different phase IV studies that could be undertaken: additional studies to capture other adverse effects, large scale and long-term studies to see the impact of the drug on mortality and morbidity, additional clinical trials as supplementary information, clinical trials in patient groups not well studied in phase III and clinical trials where there is an indication that once the drug is approved it will be used in those areas. 2013 2006 Steenburg C J Use of plant stanol ester margarine among persons with and without cardiovascular disease: Early phases of the adoption of a functional food in Finland The Food and Drug Administration's Use of Postmarketing (Phase IV) Study Requirements: Exception to the Rule? EFSA supporting publication 2015: EN-739 Location USA Aim Monitoring method 108 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published Authors Title 2009 Talati AR & Gurnani AK Dietary Supplement Adverse Event Reports: Review and Analysis 1998 Talbot JCC & Nilsson BS Pharmacovigilance in Pharmaceutical Industry 2008 Tatley MV, Kunac DL, McNicholas A, et al. Location the The Intensive Vaccines Monitoring Programme (IVMP): An electronic system to monitor vaccine safety in New Zealand EFSA supporting publication 2015: EN-739 Aim Monitoring method USA Importance of tracking serious adverse events with respect to dietary supplements that have already been marketed. The MedWatch Adverse Event Reporting (AER) procedure. A serious adverse event must be reported to FDA by manufacturers or distributors of dietary supplements using Form 3500A. Voluntary reporting of an adverse event may be done using MedWatch Form3500. EU/USA Discussion of current pharmacovigilance methods and the future of pharmacovigilance Reviews a number of current methods including: spontaneous reporting, published case reports, cohorts studies, post marketing clinical trials New Zealand An electronic system to monitor vaccine safety in New Zealand. The main aims of the IVMP were to provide an early alert mechanism of unexpected adverse events occurring with the meningococcal vaccine and to measure the incidence of clinical conditions requiring a health care consultation in the 6-week period following vaccination with the meningococcal vaccine and/or other routine childhood immunisation schedule vaccines. Intensive Vaccines Monitoring Programme (IVMP). Adverse Events Following Immunisation (AEFIs) were monitored in a cohort of children receiving vaccinations in primary care. The IVMP cohort was established from 30 general practitioner led medical centres, known as ‘sentinel practices’, recruited from 1000 such practices across New Zealand. Details of all vaccinations in the sentinel practices are routinely recorded in the practice management system. 109 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published 2010 Authors Theophile H, Arimone Y, MiremontSalamé G, et al. Title Comparison of three methods (Consensual Expert Judgement, Algorithmic and Probabilistic Approaches) of Causality Assessment of Adverse Drug Reactions An assessment using reports made to a French pharmacovigilance centre. EFSA supporting publication 2015: EN-739 Location France Aim Monitoring method The aim of the study was to compare this novel method, an operational algorithm and consensual expert judgement taken as reference. Compared three different causality assessment methods: expert opinion, evaluation using the algorithm and evaluation using the logistic method. 1) Expert opinion: A panel of 26 experts was set up to evaluate the adverse event reports. A panel of three experts per pair of reports was set up (picked on their specialisms) and assessment of reports was done independently. If the results didn't match a second group of experts would reanalysis to come to a consensus. 2) The French algorithm uses, evaluation of seven criteria belonging to 2 groups (chronological (C) and semiological (S)) to assess causality. Each criteria category has a score once both C & S scores have been added together they form the intrinsic score. These relate to whether the likelihood of association is, not related to highly likely. 3) The logistic method uses seven causality criteria, but unlike the French algorithm it tries to replicate the expert opinion. The weight given to each criteria is therefore computed by linear regression. A lack of relevant information gives a middle score which means causality can't be accepted or rejected. 110 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published Authors Title 2011 Theophile H, Laporte J-R, Moore N, et al. The Case-Population Study Design An analysis of its application in pharmacovigilance 2011 Torvi JR & Hunashal R Pharmacovigilance 2003 van Grootheest K, de Graaf L and de Jongvan den Berg LTW Consumer Adverse Drug Reaction Reporting - A New Step in Pharmacovigilance? EFSA supporting publication 2015: EN-739 Location Aim Monitoring method Europe Multiple aims: 1) To present case-control studies to non-statisticians 2) To propose an easy method that can be used in pharmacovigilance 3) To propose a simple formulae for calculating OR confidence intervals 4) Applying the approach to real-life examples 5) Discussion of pros and cons (reallife context) Population based case-cohort study, comparing odds of exposure to a studied factor (consumption of a particular drug) in a caseseries. Contingency tables are used to calculate the odds of exposure. During the given study period, all or a highly representative sample of adverse reactions within the catchment population should be obtained to remove selection bias. You must first calculate the proportion of those exposed in the population and then the amount of exposed and not exposed person time. Once these have been calculated using the contingency table the estimation of relative risk can occur. The control group are the not exposed members of the catchment population. India To prepare a plan to improve pharmacovigilance in India. Review of national programme of pharmacovigilance in India. Spontaneous reporting is listed as the main method of collecting postmarketing safety information. Discusses issues with underreporting and gives some useful definitions on pharmacovigilance. Various Overview of experiences with consumer reporting in various countries of the world. Many countries have set up national pharmacovigilance systems, which, as a rule, function on the basis of spontaneous reporting by physicians and pharmacists. This paper looks at the advisability of direct reporting of potential adverse drug reactions by patients. 111 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published Title Location Aim Monitoring method van Hunsel, Härmack L, Pal S, et al. Experiences with Adverse Drug Reaction Reporting by Patients Australia, Canada, Denmark, Netherlands, New Zealand, Norway, Malaysia, Philippines, Sweden, UK, US To review the methods of patient reporting of Adverse Drug Reactions (ADRs) in 11 countries worldwide and to compare different aspects of their experiences. A survey based on telephone interviews, e-mail discussions and field visits of existing practices in consumer and patient reporting of ADRs was performed in the second half of 2010. 2006 Waller PC Making the Most of Spontaneous Adverse Drug Reaction Reporting Global Identify any adverse effects 1991 Waller PC Postmarketing surveillance: The viewpoint of a newcomer to Pharmacoepidemiology England Monitor all new chemical entities that are used in general practice in the United Kingdom. 2003 Waller PC & Evans SJW A model for the future conduct of pharmacovigilance UK To describe a model to improve the process of pharmacovigilance in the future. 2012 Authors EFSA supporting publication 2015: EN-739 Spontaneous Reporting (SR)- details the history and purpose of SR and how to carry out effective SR. It then goes onto to discuss current regulations and how the process of SR could be improved in the future. Prescription-event monitoring (PEM)- details the major aims of PEM. Data collection involved providing photocopies of prescriptions for the patients enrolled in the study and between 412 months after prescription green forms were sent out to their doctors and they are asked to detail any adverse reactions the patient may have experienced. Initial follow-up of serious reports occurred by the GP. Methods suggested include: observational research, randomized clinical trials, pharmacogenetics. epidemiological meta-analysis, 112 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published Authors Title Location Aim Monitoring method UK To identify and investigate methods of drug safety problems Spontaneous reporting data, drug usage data, post-marketing safety studies, record linkage, marketing authorization holders, periodic safety updates, links with other regulatory authorities, published literature, registries/mortality statistics, signal generation procedures, intensive monitoring, screening procedures and literature monitoring. Discusses a number of methods of pharmacovigilance: spontaneous reporting forms, large simple safety trials, epidemiological studies e.g. case-control and cohort studies, and discusses the use of registries as a data source for cohort studies. 1996 Waller PC, Coulson RA & Wood SM Regulatory Pharmacovigilance in the United Kingdom: current principles and practice 2009 Weaver J, Grenade LL, Kwon H & Avigan M Finding, evaluating and managing drug-related risks: approaches taken by the US Food and Drug Administration. USA To provide examples of approaches taken by the FDA in identifying and managing risks associated with the use of marketed pharmaceuticals. 2011 Welch RW, Antoine J-M, Berta J-L, et al. Guidelines for the Design, Conduct and Reporting of Human Intervention Studies to Evaluate the Health Benefits of Foods N/A To provide guidelines for the design, conduct and reporting of human intervention studies. The paper provides suggestions for guidelines of what should be included in health studies and provide guidelines for the design, conduct and reporting of human intervention studies. Westerholm B Westerholm B Westerholm B Westerholm B Westerholm B The rationale for marketing surveillance The rationale for marketing surveillance The rationale for marketing surveillance The rationale for marketing surveillance The rationale for marketing surveillance Some countries. Identify any adverse effects Spontaneous reporting Some countries. Identify any adverse effects Intensive monitoring Some countries. Identify any adverse effects Health registers can be used to trace cases for case-control studies. Some countries. Identify any adverse effects Prospective studies is an informative way to obtain results. Some countries Identify any adverse effects Data on drug utilization. 1987 1987 1987 1987 1987 EFSA supporting publication 2015: EN-739 a post- a post- a post- a post- a post- 113 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published Authors Title Location Aim Monitoring method Global To give details on how to apply pharmacovigilance practices to herbal medicines. World health organisation document which gives definitions on herbal medicines and also discusses pharmacovigilance generally. The report then moves on to talk about pharmacovigilance of herbal medicines, including the different reports that can be obtained on adverse reactions to herbal medicines and some of the challenges involved in collecting reports on herbal medicines. It also discusses the WHO coding systems for case reports and provides details on how to use the different codes to assess adverse event case reports for herbal medicines. 2004 WHO WHO guidelines on safety monitoring of herbal medicines in pharmacovigilance systems 2012 Wiktorowicz M, Lexchin J & Moscou K Pharmacovigilance in Europe and North America: Divergent approaches Global Identify safety issues through epidemiologic analyses of healthcare databases 2013 Willems JI, Blommaert MAE & Trautwein EA Results from a post-launch monitoring survey on consumer purchases of foods with added phytosterols in five European countries Netherlands, Belgium, United Kingdom, France and Germany Reports findings from the 2011 post-launch monitoring survey on consumer purchase behaviour of foods with added phytosterols. 1991 Wood SM Postmarketing surveillance: viewpoint from a regulatory authority UK Review of Postmarket surveillance EFSA supporting publication 2015: EN-739 Discusses the differences between pharmacovigilance systems in the US/Europe, including regulatory policy and regulatory processes. Suggest that in the EU (mainly UK and France) they remain too driven by industry designed surveillance strategies. Post Launch Monitoring (PLM)- data was collected by two independent market research companies. Once recruited panellists were asked to scan purchases (via a household barcode reader provided during the study) when they returned from the supermarket to provide information on purchases. Products included in the study had to contain phytosterol esters and included; yoghurt drinks, salad dressing and spreads. Data from the households was scaled up to country level. Using the estimated phytosterol concentration of the product, the household purchase data and the estimated daily intake of phytosterols per household, intake was determined per country. Methods are reviewed very briefly and their importance discussed. Methods mentioned include; spontaneous reporting, published literature, registries, cohort studies, prescription event monitoring and record linkage. The most information is provided about spontaneous reporting giving limitations of different systems. 114 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published 2012 2009 Authors Zakaryan A & Martin IG Zancan A, Locatelli C, Ramella F, et al. Title Location Regulation of Herbal Dietary Supplements: Is There a Better Way? A new model pharmacovigilance? A study EFSA supporting publication 2015: EN-739 of pilot Various Italy Aim Outlines the importance of herbal dietary supplements regulation by providing a brief overview of history of supplement regulation in the US with emphasis placed on passage of the 1994 Dietary Supplement Health and Education Act (DSHEA) Aim of the present study was to build a procedure to actuate the new model of pharmacovigilance and to compare the ADR incidence recorded using the two different models Monitoring method Review of the Dietary Supplement Health and Education Act (DSHEA) and post-DSHEA enforcement actions. Identification of risk by the FDA relies primarily on post-market surveillance practices such as monitoring serious adverse event reports. Manufacturers of dietary supplements, unlike manufacturers of pharmaceuticals, are not required to provide evidence of safety and efficacy based on rigorous pre-market clinical testing. Compared traditional method of spontaneously reported ADRs, with active surveillance methods. Patients were followed after discharge from hospital for 6 months. After 30 days out of hospital a telephone questionnaire was completed and files logged in patient data tracking. Passive surveillance ongoing throughout study. 115 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed Date Published 2009 Authors Zuber PLF, Autran B, Asturias EJ, et al. Title Global safety of vaccines: strengthening systems for monitoring, management and the role of GACVS EFSA supporting publication 2015: EN-739 Location Various Aim Monitoring method Review the models and systems that have been developed to monitor and respond to concerns regarding vaccine safety Brief review on a number of methods of passive and active surveillance. Passive surveillance systems include: 1) The UK Yellow Card system which is a mechanism for reporting a broad spectrum of suspected safety issues related to use of medicines, including vaccines. 2) In the USA, the Vaccine Adverse Event Reporting System (VAERS). 3) In Australia, the Adverse Drug Reactions Advisory Committee database is a well-established AEFI surveillance system. 4) In Brazil, the national immunization program coordinates an adverse events reporting system. 5) The WHO collaborating centre for international drug monitoring. The Global Advisory Committee on Vaccine safety (GACVS) was set up 10 years ago and charged to provide the WHO with independent advice on vaccine safety issues. 116 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors. Strategy support for the Post-Market Monitoring of GM Food and Feed GLOSSARY OF ABBREVIATIONS ADR- adverse drug reaction EFSA – European Food Safety Authority EU – European Union EU MS – European Union Member States GACVS- Global Advisory Committee on Vaccine Safety GM – genetically modified GMO – genetically modified organism IMP- Immunisation Monitoring programme LMO – living modified organism MS - Microsoft NIP – National Immunisation programme NSAID – Non-steroidal anti-inflammatory drugs PIDM - Programme for International Drug Monitoring PMM – Post-Market Monitoring VAERS- Vaccine Adverse Event Reporting Scheme VICH - International Cooperation on Harmonisation of Technical Requirements for Registration of Veterinary Medicinal Products WHO – World Health Organisation EFSA supporting publication 2015: EN-739 117 The present document has been produced and adopted by the bodies identified above as author(s). This task has been carried out exclusively by the author(s) in the context of a contract between the European Food Safety Authority and the author(s), awarded following a tender procedure. The present document is published complying with the transparency principle to which the Authority is subject. It may not be considered as an output adopted by the Authority. The European Food Safety Authority reserves its rights, view and position as regards the issues addressed and the conclusions reached in the present document, without prejudice to the rights of the authors.