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Pharmacovigilance and Risk Management Writing

Risk Management Plan Writing for Marketing Authorisation Holders

Pubrica writes EU risk management plans for marketing authorisation holders, for new applications and for updates to existing plans. Our pharmacovigilance writers prepare RMPs to GVP Module V, covering the safety specification, the pharmacovigilance plan, and risk minimisation measures with their effectiveness assessment. Each risk minimisation measure becomes an obligation with an owner, a budget and an effectiveness assessment, so we size every commitment before it is included and reconcile the plan with your labelling.

  • A safety specification that distinguishes important identified risks, important potential risks and missing information, which carry different obligations
  • A pharmacovigilance plan proportionate to the risk, with routine activities distinguished from additional activities
  • Risk minimisation measures sized before they are proposed, because each one becomes a commitment with a cost and an owner
  • Effectiveness assessment specified for each additional measure, which is the section most plans leave underdeveloped
  • Consistent with the labelling, because any difference between the RMP and the SmPC in describing the same risk will be questioned
Scope of Risk Management Plan Writing What is included and what is excluded

Safety specificationIncluded

Pharmacovigilance planIncluded

Risk minimisation and effectivenessIncluded

RMP updates and versionsIncluded

Operating the safety databaseYour PV function

Safety data → specified → planned → minimised → RMP

Included in every plan
  • Risk categories correctly assigned
  • Activities proportionate to risk
  • Commitments sized before they are proposed
  • Effectiveness measurement specified
  • Reconciled with the labelling
Quoted per planBased on product, risk profile and version
Updates on a defined cycleUpdate cadence set in the plan
GVP Module VWith the current EU RMP template
ISO 9001:2015Quality management certified · cert. H3CR9TCU20251212INDQM10N

Deliverables

Four Core Elements of Every Risk Management Plan

Each plan covers one product and its safety profile, and the data available defines what the plan must manage.

A Safety Specification With Correct Risk Categories Important identified risks, important potential risks and missing information are different categories with different obligations, and assigning the wrong category has costly consequences.

Example from a safety specificationHepatotoxicity — identified risk.Important potential risk: a signal from two cases with confounding, insufficient for identified. Categorised as potential, with the characterisation study in the pharmacovigilance plan. The category determines the obligation.

A Pharmacovigilance Plan Proportionate to Risk Routine activities are used for most concerns, and additional activities only where routine activities will not answer the question, because each additional activity is a study that must be funded.

Example from a pharmacovigilance planProposing additional pharmacovigilance for every listed risk leads to a plan the company cannot deliver. GVP Module V treats proportionality as a requirement.

Deliverable Risk Minimisation Measures Each measure is costed and assigned an owner before it is proposed. Educational materials, controlled access programmes and pregnancy prevention programmes are substantial ongoing commitments.

Example from a commitment reviewA physician education programme will be implemented.Flagged before submission as unbounded in scope, territory, duration and cost, and rewritten as a specific, costed programme with an owner and a defined review point.

Effectiveness Assessment for Each Measure For each additional risk minimisation measure, we specify the indicator, its source and the timing of assessment. Most plans leave this section underdeveloped, and regulators increasingly expect it in full.

Example from an effectiveness sectionA measure with no stated effectiveness indicator cannot be shown to work, so it also cannot be withdrawn. Specifying the indicator supports both decisions.

The samples shown are illustrative and anonymised. Hover over a sample to replay it.

Compliance and Standards

Regulatory Guidelines and Standards for Risk Management Plans

Where your agency or your safety function has a stated position, we follow it.

GVPModule V

Good pharmacovigilance practices (risk management systems)

Sets the structure and content of the EU risk management plan, the proportionality principle and the expectations for effectiveness assessment.

ICHE2E

Pharmacovigilance planning (safety specification)

Provides the basis for the safety specification and for distinguishing routine from additional pharmacovigilance activities.

SmPCand PIL

Product information (consistency requirement)

The RMP and the labelling describe the same risks. Any difference between them will be questioned and may become a finding.

ISO9001:2015

Quality management (cert. H3CR9TCU20251212INDQM10N)

Our quality management system governs how each document is drafted, reviewed, version-controlled and released.

Responsible Use of AI

Responsible Use of AI in Regulatory Writing

Regulatory reviewers trace each decision back to its evidence and to a named individual. For this reason, source traceability takes priority over speed in our regulatory writing, and every statement must be traceable to its source.

How We Use AI ToolsWe use AI tools to locate source material across a document set, to check the consistency of terms, figures and cross-references between documents in a submission, and to draft highly templated sections that a writer then verifies line by line against the source.
Where We Do Not Use AIWe do not use AI tools for text that enters a submission as drafted, for clinical or benefit-risk interpretation, safety narratives or literature appraisal for a clinical evaluation, or for any statement an assessor would expect to trace to a named, qualified individual.
What Your AI Declaration Should IncludeYour declaration should name the tool, the stage at which it was used and the human oversight applied. Journals, funders, regulators and the ICMJE January 2026 update now expect this, and an undeclared tool found later is treated as an integrity matter.

Why We Do Not Publish an AI Accuracy Figure

Accuracy figures for AI tools are usually reported by the companies that sell them.

Pubrica therefore does not quote a self-generated accuracy figure, because it would carry the same conflict of interest. Instead, we tell you which tool was used on your project, at which stage, and what a specialist changed afterwards.

Methodology

How Our Risk Management Plan Writing Process Works

We categorise each risk first, because its category determines the obligations that follow.

Step one

Safety Data Review and Risk Categorisation

We assess the clinical and post-market safety data and categorise each concern as an important identified risk, an important potential risk or missing information.

Step two

Pharmacovigilance Planning

We propose routine and additional activities in proportion to the risk, and scope and cost any additional study before it is included in the plan.

Step three

Risk minimisation and effectiveness

We select, size and assign an owner to each measure, and specify the effectiveness indicator, source and timing for each additional measure.

Step four

Reconciliation and Release

We check the plan against the SmPC and package leaflet so that each risk is described consistently, then release it with the update cadence set.

Our Experts

Your Risk Management Plan Writing Team

A named team of regulatory specialists stays with your project from scoping to delivery. Your project coordinator introduces each team member by name before work begins.

Regulatory medical writerAuthors the document to the applicable template and guidance

Writes the document against the governing template and regulatory guidance, keeps every statement traceable to its source data, and maintains the version history and comment log through each review round.

Responsible forDrafting and source traceability
Reviews againstICH, EU MDR/IVDR or FDA guidance, as applicable
OutputSubmission-ready document
Subject matter expertClinical or scientific expert matched to your product area

Reviews the clinical and scientific content for accuracy and confirms that each conclusion is supported by the data. Each expert is matched to your therapeutic or device area.

Responsible forScientific accuracy and interpretation
Reviews againstSource data and the current literature
FieldMatched to your product
BiostatisticianStatistical review where the document reports analysed data

Checks that statistical methods, tables and conclusions are consistent with the analysis plan, and reviews how the data are presented before the document reaches regulatory review.

Responsible forStatistical accuracy
Reviews againstICH E9 and the statistical analysis plan
ToolsR, SAS, Stata
Regulatory QC reviewerIndependent quality check before delivery

Performs an independent check of the final document against source data, the template and the applicable regulatory checklist. Findings are logged and resolved before delivery.

Responsible forIndependent quality control
Reviews againstSource data and regulatory checklists
Signed off byProject lead

Packages

Risk Management Plan Service Packages

Pricing depends on the product, the number of important risks and whether additional activities and measures are in scope.

RMP

Risk management plan

For marketing authorisation applications and new products

Quoted per projectBased on product and risk profile

Delivery By scope

  • ✓Safety specification with categories justified
  • ✓Proportionate pharmacovigilance plan
  • ✓Risk minimisation measures sized and owned
  • ✓Effectiveness measurement specified
  • ✓Reconciled with the SmPC and leaflet
  • ✓Two review cycles

We review commitments for deliverability before they are included in the plan.

Deliverables Request a quote
Update

RMP update

For products with an existing plan

Quoted per projectBased on what has changed

Delivery By scope

  • ✓New safety data assessed and risks recategorised where warranted
  • ✓Completed activities closed out
  • ✓Effectiveness results incorporated
  • ✓Measures reconsidered where effectiveness is demonstrated
  • ✓Version and change summary for the agency

An update is also the point at which a measure that has achieved its purpose can be withdrawn, provided its effectiveness indicator was specified.

Deliverables Request a quote

Send your current RMP and we will review the risk minimisation section at no cost for commitments that are unbounded in scope, territory, duration or cost.

FAQs

Risk Management Plan FAQs

If your question is not answered here, ask an expert. No quote is required.

Because the category determines the obligation. An important identified risk carries different pharmacovigilance and minimisation expectations from an important potential risk, and missing information carries different ones again.

Categorising a signal as an identified risk when the evidence supports a potential risk adds obligations you did not need to take on, and the reverse is likely to be challenged.

Proposing additional activities for every risk often leads to a plan the company cannot deliver. GVP Module V expects proportionality, and a plan that proposes additional activity for every listed risk will be questioned.

Routine pharmacovigilance is adequate for most concerns. Additional activity should be proposed only where routine activity will not answer the question.

For each additional risk minimisation measure: what indicator will show whether it is working, where that indicator comes from, and when it will be assessed.

Most plans leave this section underdeveloped, and regulators increasingly point this out. Specifying it also provides the basis on which a measure can later be withdrawn.

No. Case processing, the safety database, signal detection and the QPPV function sit with your pharmacovigilance organisation or a provider that holds those obligations.

We write the plan those functions operate against, and the aggregate safety reports produced from them.

Related Services

Related Regulatory Writing Services

The RMP draws on the safety data and must be consistent with the labelling.

Request a Free Review of Your RMP Risk Minimisation Section

We review the measures for commitments that are unbounded in scope, territory, duration or cost, which is where plan commitments become expensive.

Get a free quote

Regulations

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