European Medicines Agency

June 2008
EMEA/CHMP/ICH/309348/2008

ICH Topic E2F

Development Safety Update Report

Step 3

NOTE FOR GUIDANCE ON

DEVELOPMENT SAFETY UPDATE REPORT
(EMEA/CHMP/ICH/309348/2008)

TRANSMISSION TO CHMP June 2008

TRANSMISSION TO INTERESTED PARTIES June 2008

DEADLINE FOR COMMENTS December 2008

Please forward your comments to the following email address: ich@emea.europa.eu

7 Westferry Circus, Canary Wharf, London, E14 4HB, UK

Tel. (44-20) 74 18 85 75 Fax (44-20) 75 23 70 40
E-mail: mail@emea.europa.eu http://www.emea.europa.eu
© European Medicines Agency, 2008. Reproduction is authorised provided the source is acknowledged
 TABLE OF CONTENTS

1. INTRODUCTION................................................................................................................ 4
1.1 OBJECTIVE OF THE GUIDELINE ..................................................................................... 4
1.2 SCOPE OF THE DSUR.................................................................................................... 4
2. GUIDANCE....................................................................................................................... 5
2.1 WHEN SHOULD A DSUR BE PREPARED? ...................................................................... 5
2.2 PERIODICITY AND DSUR DATA LOCK POINT ............................................................... 5
2.3 CHANGE OF DSUR DATA LOCK POINT ........................................................................ 5
2.4 INTERRUPTION OR DISCONTINUATION OF CLINICAL TRIALS ......................................... 6
2.5 FINAL DSUR ................................................................................................................ 6
2.6 RESPONSIBILITIES FOR PREPARING AND SUBMITTING A DSUR .................................... 6
2.6.1 Sponsor’s responsibilities ........................................................................................ 6
2.6.2 Shared responsibilities............................................................................................. 6
2.6.3 Non-commercial sponsor responsibilities................................................................ 6
2.6.4 Responsibilities of multiple sponsors in formal agreements.................................... 6
2.7 DSURS FOR COMBINATION PRODUCTS ........................................................................ 6
2.8 REFERENCE SAFETY INFORMATION .............................................................................. 7
2.9 FORMAT AND PRESENTATION OF DSUR....................................................................... 7
2.9.1 Format...................................................................................................................... 7
2.9.2 Table of Contents ..................................................................................................... 7
2.10 GUIDANCE ON CONTENTS OF DSUR............................................................................. 8
3. UPDATE ON ACTIONS TAKEN IN THE REPORTING PERIOD FOR SAFETY9

4. CHANGES TO REFERENCE SAFETY INFORMATION ................................... 10

5. STATUS OF CLINICAL TRIALS ONGOING AND COMPLETED DURING

THE REPORTING PERIOD................................................................................................ 10

6. ESTIMATED EXPOSURE............................................................................................ 11
6.1 CUMULATIVE SUBJECT EXPOSURE IN DEVELOPMENT PROGRAMME .................................. 11
6.2 PATIENT EXPOSURE FROM MARKETING EXPERIENCE ........................................................ 11
7. PRESENTATION OF SAFETY DATA FROM CLINICAL TRIALS ..................... 11
7.1 GENERAL CONSIDERATIONS ............................................................................................. 12
7.2 INTERVAL LINE LISTINGS OF SERIOUS ADVERSE REACTIONS (SARS) ............................. 12
7.3 CUMULATIVE SUMMARY TABULATIONS ..................................................................... 12
7.4 DEATHS IN THE REPORTING PERIOD ........................................................................... 12
7.5 SUBJECTS WHO DROPPED OUT IN ASSOCIATION WITH ANY ADVERSE EVENT IN THE
REPORTING PERIOD ................................................................................................................ 13

8. SIGNIFICANT FINDINGS FROM CLINICAL TRIALS DURING THE

REPORTING PERIOD ......................................................................................................... 13
8.1 COMPLETED TRIALS AND ANY INTERIM ANALYSES ..................................................... 13
8.2 ONGOING CLINICAL TRIALS ........................................................................................ 13
8.3 OTHER THERAPEUTIC USE OF INVESTIGATIONAL DRUG ............................................. 13
8.4 NEW SAFETY DATA RELATED TO COMBINATION THERAPIES ..................................... 13
9. RELEVANT FINDINGS FROM NON-INTERVENTIONAL STUDIES ................ 13

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10. RELEVANT FINDINGS FROM OTHER SOURCES............................................ 13

11. SAFETY FINDINGS FROM MARKETING EXPERIENCE................................ 14

12. OTHER INFORMATION.......................................................................................... 14

12.1 NON-CLINICAL DATA.................................................................................................. 14
12.2 LONG-TERM FOLLOW-UP ............................................................................................ 14
12.3 LITERATURE ............................................................................................................... 14
12.4 OTHER DSURS ........................................................................................................... 14
12.5 SIGNIFICANT MANUFACTURING CHANGES................................................................... 14
12.6 LACK OF EFFICACY ..................................................................................................... 14
12.7 PHASE I PROTOCOL MODIFICATIONS ........................................................................... 14
13. LATE-BREAKING INFORMATION ...................................................................... 15

14. OVERALL SAFETY ASSESSMENT....................................................................... 15

14.1 EVALUATION OF THE RISKS......................................................................................... 15
14.2 BENEFIT-RISK CONSIDERATIONS ................................................................................. 16
14.3 CONCLUSIONS ............................................................................................................ 16
15. SUMMARY OF IMPORTANT RISKS .................................................................... 16

16. APPENDICES TO THE DSUR ................................................................................. 16

17. APPENDICES TO GUIDELINE............................................................................... 16

APPENDIX A ......................................................................................................................... 17
GLOSSARY ............................................................................................................................. 17
APPENDIX B.......................................................................................................................... 20
TABLE 1 - EXAMPLES OF TABLE HEADINGS FOR CLINICAL TRIAL STATUS
LISTINGS ............................................................................................................................ 20
TABLE 2 - EXAMPLES OF DEMOGRAPHIC DATA TABLES....................................... 21
TABLE 3 - EXAMPLES OF HEADINGS FOR INTERVAL LINE LISTINGS OF
SERIOUS ADVERSE REACTIONS ................................................................................... 22
TABLE 4 - EXAMPLES OF CUMULATIVE TABULATIONS OF SERIOUS ADVERSE
EVENTS............................................................................................................................... 23

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 1. INTRODUCTION

1.1 Objective of the Guideline

The periodic analysis of safety information is crucial to the ongoing assessment of risk to trial
subjects during the clinical development of an investigational drug. 1,2,3 It is also important to
notify regulators and other interested parties (e.g. ethics committees) at regular intervals of the
evolving safety profile of an investigational drug and actions proposed or being taken to
address safety concerns. Currently, regulations in some countries or regions require
submission of a periodic report to regulatory authorities to address these issues. However,
significant differences in the content and format of these reports highlight the importance of a
common standard to promote a consistent approach, and enhance efficiency. The
Development Safety Update Report (DSUR) proposed in this guideline is intended to be the
common standard for annual clinical trial safety reporting among the ICH regions and can be
submitted instead of existing reports including the US IND Annual Report and the EU Annual
Safety Report. This comprehensive, thoughtful annual review can provide an additional level
of assurance of protection for subjects in clinical trials. In addition, by harmonising the
format, content and timing of annual safety reports, regulators in the three ICH regions can
receive the same information at the same time, thereby reducing the number of reports
generated.

The main objective of a DSUR is to present an annual review and evaluation of pertinent
safety information collected during the reporting period to: (1) summarise the current
understanding and management of identified and potential risks; (2) describe new safety
issues that could have an impact on the protection of clinical trial subjects; (3) examine
whether the information obtained by the sponsor during the reporting period is in accord with
previous knowledge of the product’s safety; and (4) provide an update on the status of the
clinical investigation/development programme. This guideline defines the content and format
of a DSUR and provides an outline of points to be considered in its preparation and
submission.

1.2 Scope of the DSUR

The main focus of the DSUR is data from interventional clinical trials (referred to in this
document as “clinical trials”) of investigational drugs including biologicals, with or without a
marketing approval, whether conducted by commercial or non-commercial sponsors.
However, other findings that impact the safety and welfare of clinical trial subjects, (e.g.
significant safety findings from non-clinical studies, safety findings from clinical trials
conducted by a co-development partner in a licensing agreement, or relevant findings from
non-interventional studies/compassionate use) should also be included where appropriate.
Some of the information contained in the DSUR, such as safety findings, inclusion of serious
adverse reactions in line listings, and discussion of relevant articles from published literature
can also be provided in Periodic Safety Update Reports (PSURs) for marketed products that
are the subject of ongoing clinical trials. Therefore, some overlap is expected between the
DSUR and PSUR because of the different periodicities for submission and objectives.

The DSUR should provide safety information from all ongoing clinical trials that the sponsor
is conducting or has completed during the review period including:

1
The term investigational drug is used in this guideline to indicate only the experimental product under study or development.
2
For detailed discussion see: The Development Safety Update Report (DSUR): Harmonizing the Format and Content for Periodic Safety
Reporting During Clinical Trials: Report of CIOMS Working Group VII, Geneva 2007.
3
ICH Topic E6(R1). Guideline for Good Clinical Practice http://www.emea.europa.eu/pdfs/human/ich/013595en.pdf

© EMEA 2008 Page 4/23

• clinical trials conducted using an investigational drug whether with or without a
marketing approval, i.e., human pharmacology, therapeutic exploratory and therapeutic
confirmatory trials (Phase I – III); 4
• clinical trials conducted using marketed drugs in approved indications, i.e., therapeutic
use trials (Phase IV);
• other therapeutic use of an investigational drug; and
• comparability trials conducted to support changes in the manufacturing process of
medicinal products.

The DSUR should focus primarily on the investigational drug, providing information on
comparators only where relevant to the safety of trial subjects. A DSUR should be concise
and provide information to assure regulators that sponsors are adequately monitoring and
evaluating the safety profile of the investigational drug. It should not contain initial
notification of any significant new safety issues, as these should have been communicated to
regulatory authorities via expedited reporting.

2. GUIDANCE

2.1 When Should a DSUR be Prepared?

A sponsor overseeing more than one clinical trial of a single investigational drug should
prepare one DSUR for that drug with a single data lock point (DLP) wherever possible. If this
is not possible, an explanation should be provided in the covering letter.

2.2 Periodicity and DSUR Data Lock Point

The DSUR is intended to be an annual report that should be submitted to regulatory
authorities, as appropriate, for as long as the sponsor conducts clinical trials with the
investigational drug, or for as long as appropriate to satisfy local requirements. Where local
authorities ask for periodic submission of safety information on an investigational drug to
ethics committees, institutional review boards, or investigators, the DSUR Executive
Summary should suffice, supplemented with line listings of serious adverse reactions as
warranted.

The DSUR should be submitted no later than 60 calendar days from the DSUR data lock
point. The data lock point of the DSUR should be based on the date of the sponsor’s first
authorisation to conduct a clinical trial in any country. This date is termed the “Development
International Birth Date” (DIBD). 5 For administrative convenience, if desired by the sponsor,
the DIBD can be designated as the last day of the month of authorisation.

Where clinical trials are ongoing in one country and are later initiated in another country(ies),
one DSUR based on the same DIBD should be used for all countries.

2.3 Change of DSUR Data Lock Point

Once a drug has received a marketing approval 6 in any country or region, and clinical trials
continue or are initiated, both a PSUR and a DSUR should be prepared in accordance with
directions from local authorities. The sponsor should change the DSUR data lock point to
coincide with the International Birth Date (IBD) so that the DSUR and the PSUR can be
synchronised. In synchronising the data lock points for the DSUR and PSUR, the period
covered by the next DSUR should be no longer than one year.

4
For classification of clinical trials see ICH E8 General considerations for clinical trials.
5
This is analogous to the International Birth Date (IBD) for a PSUR, defined as the date of first marketing approval worldwide.
6
For the purposes of this document, we use the term “authorisation/ authorised” to refer to approvals of clinical trials, and “approved/
marketing approval” to refer to marketing authorizations.

© EMEA 2008 Page 5/23

 2.4 Interruption or Discontinuation of Clinical Trials
A DSUR should be prepared and submitted as indicated by local authorities, even when the
clinical trials are interrupted or discontinued. If the sponsor has not collected any further data
pertinent to the clinical development programme in the period of the DSUR, a letter stating
this can replace the DSUR.

2.5 Final DSUR

When an annual report of clinical trials is no longer required in an individual country or
region, the DSUR should be accompanied by a cover letter indicating that the report serves as
the final DSUR for the investigational drug in that country or region. The letter should also
indicate whether or not clinical trials are continuing elsewhere.

2.6 Responsibilities for Preparing and Submitting a DSUR

2.6.1 Sponsor’s responsibilities

The sponsor of a clinical trial, whether commercial or non-commercial, should be responsible
for the preparation, content and submission of a DSUR.

2.6.2 Shared responsibilities

Where individual clinical trials or a drug development programme involve collaboration with
public or private institutions, business partners or other parties, a written agreement should be
in place clearly detailing the responsibilities for preparation and submission of the DSUR.
The same principle applies in situations where the sponsor delegates the preparation of the
DSUR to a third party, e.g., a contract research organisation.

2.6.3 Non-commercial sponsor responsibilities

Non-commercial sponsors should be responsible for the preparation of the DSURs for the
clinical trials they conduct, in accordance with local requirements. Sections of the DSUR that
are not applicable to non-commercial sponsors (e.g., manufacturing issues, non-clinical data,
and marketing status) should be identified as such.

2.6.4 Responsibilities of multiple sponsors in formal agreements

When there is more than one sponsor, e.g., when a sponsor is in a formal co-development or
licensing relationship with one or more partners, or more than one partner is a sponsor of a
clinical trial(s) of the investigational drug, the parties should arrange to prepare a single
DSUR whenever possible. Written agreements should be in place specifying how safety data
will be exchanged so that a single DSUR can be produced by one sponsor on behalf of all
parties.

When unavoidable, multiple sponsors can agree in writing to prepare separate DSURs for the
same investigational drug. This can include situations where different indications, routes of
administration, or formulations are being investigated. The rationale for separate DSURs
should be provided in each report.

2.7 DSURs for Combination Products

Given the potential complexities of clinical development involving combination therapies, it
is not possible to provide guidance that addresses all such situations. The sponsor should
select the most appropriate option based on judgement, taking into account patient population,
indication, formulation etc., as well as the circumstances in which the clinical trials are being
conducted and local regulatory requirements. The rationale for this decision should be
provided in the report.

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In general, a single DSUR should be prepared for clinical trials involving a fixed combination
product.

For trials involving drug combinations that are not fixed, it can be appropriate to prepare a
stand-alone DSUR. Alternatively, information on the multidrug regimen trials can be included
in the DSUR of one or all of the components.

Although medical devices are outside the scope of the DSUR, specific local regulations can
require a DSUR for certain drug-device combinations, depending upon whether the principal
therapeutic effect is achieved by the drug or the device.

2.8 Reference Safety Information

A single document containing the reference safety information should be used to assess
whether the safety information received during the reporting period remains consistent with
previous knowledge of the safety profile of the investigational drug.

The Investigator’s Brochure (IB) in effect at the start of the reporting period should serve as
the reference safety information for the DSUR for an investigational drug whether or not the
drug has a marketing approval. The report should clearly indicate the version number and date
of the IB used for this purpose. If the IB has been revised during the reporting period and not
previously submitted to the relevant regulatory authority, the sponsor should provide a copy
of the revised version of the IB as an attachment to the DSUR. When an IB is not required for
the trial by local regulations (e.g., non-commercial sponsors conducting a clinical trial with a
marketed product) the applicable local product label 7 or another suitable document should be
used as the reference safety information.

2.9 Format and Presentation of DSUR

2.9.1 Format
The format and content of the DSUR should follow the table of contents below. For each
heading where information is available, the information should be presented concisely; when
no information is available, this should be stated. Guidance on the content of each section is
provided below. Note that the section numbers below reflect the numbering in the DSUR.

2.9.2 Table of Contents

Title page
Executive Summary
Table of Contents
1. Introduction
2. Worldwide Marketing Authorisation Status
3. Update on Actions Taken in the Reporting Period for Safety Reasons
4. Changes to Reference Safety Information
5. Status of Clinical Trials Ongoing and Completed During the Reporting Period
6. Estimated Exposure
6.1 Cumulative subject exposure in clinical trials (Phase I-IV)
6.2 Patient exposure from marketed setting
7. Presentation of Safety Data from Clinical Trials
7.1 General considerations
7.2 Interval line listings of Serious Adverse Reactions (SARs)

7
In the EU this would be the Summary of Product Characteristics (SmPC); in Japan this would be the Japanese Package Insert; and in the
US this would be the US Package Insert.

© EMEA 2008 Page 7/23

 7.3 Cumulative summary tabulations
7.4 Deaths in the reporting period
7.5 Subjects who dropped out in association with any adverse event in the
reporting period
8. Significant Findings from Clinical Trials During the Reporting Period
8.1 Completed trials and any interim analyses
8.2 Ongoing clinical trials
8.3 Other therapeutic use of investigational drug
8.4 New safety data related to combination therapies
9. Relevant Findings from Non-Interventional Studies
10 Relevant Findings from Other Studies
11. Safety findings from marketing experience
12. Other Information
12.1 Non-clinical data
12.2 Long-term follow-up
12.3 Literature
12.4. Other DSURs
12.5 Significant manufacturing changes
12.6 Lack of efficacy
12.7 Phase I protocol modifications
13. Late-Breaking Information
14. Overall Safety Assessment
14.1. Evaluation of the risks
14.2 Benefit-risk considerations
14.3 Conclusions
15. Summary of important risks
Appendices to the DSUR

2.10 Guidance on Contents of DSUR

Title page
The title page of the DSUR should include the following information:
• DSUR number (reports should be numbered sequentially);
• Investigational drug(s);
• Reporting period;
• Date of the report;
• Sponsor name and address;
• Confidentiality statement; and
• Note regarding the inclusion of unblinded information in the DSUR.

Executive Summary
This section should provide a concise summary of the important information contained in the
report. Together with the title page, it should serve as a “stand-alone” document suitable for
submission to ethics committees and other stakeholders, if required by local regulations.
Information on the following should be included in the Executive Summary:
• Introduction – report version and reporting period;
• Investigational drug – mode of action, class, indications, dose, route of administration;
• Estimated cumulative clinical trial exposure;
• Marketing authorisation(s)? (yes/no) – If yes, number of countries;
• Summary of overall safety assessment;
• Summary of important risks (based on section 15 of the DSUR);
• Actions taken for safety reasons including significant changes to IB;
© EMEA 2008 Page 8/23
• Conclusion.
All sections should be completed; when no information is available, this should be stated.

Table of Contents
Introduction
This section should include:
• Reporting period and sequential number of the report;
• Brief description of the drug, e.g., therapeutic class, mode of action, route of
administration, formulation;
• Whether the report covers a development programme or a single clinical trial. This
section should also note the scope of the trials covered by the report (e.g., all trials
with the investigational drug, or indication-specific trials);
• A brief description of the indications and populations being studied;
• A brief description and explanation of any information that has been excluded
(e.g., when written agreements with a partner company do not provide for
exchange of all safety data).

Worldwide marketing authorisation status

This section should be completed only if a marketing application for the product has
been submitted in one or more countries/regions. Cumulative information should be
provided where available, usually in the form of a table that provides the status of each
application. The content and format for this table is the same as that recommended for
PSURs, as outlined in ICH E2C, Table 1.

3. Update on Actions Taken in the Reporting Period for Safety Reasons

This section should include a description of significant actions related to safety that
have been taken by the sponsor, regulators, Data and Safety Monitoring Boards or
independent ethics committees that could have an impact on the conduct of a specific
trial or the whole clinical development programme. Any relevant updates to previous
actions should also be summarised in this section. Changes to the Investigator’s
Brochure should be discussed separately in the “Changes to Reference Safety
Information”, see section 4.
Examples of significant actions relating to safety issues include:
• Refusal of authorisation of a clinical trial for ethical or safety reasons;
• Partial 8 or complete clinical trial suspension or early termination of a clinical trial
due to lack of efficacy or safety issues;
• Resumption of a clinical trial after suspension;
• Failure to obtain marketing approval for a tested indication;
• Risk management activities, including:
o Protocol modifications due to safety or efficacy concerns (e.g., dosage
changes, changes in study inclusion criteria, intensification of monitoring);
o Restrictions in study population or indications;
o Changes to the informed consent document relating to safety issues;
o Formulation changes for safety reasons;
o Addition of a special reporting requirement;
o Issuance of a communication to investigators or healthcare professionals;
o Plans for new safety trials.
• Important specific advice for safety reasons from a regulatory authority that
involves a constraint on development (e.g., requirement to conduct long-term
8
“Partial suspension” may include several actions – e.g., suspension of repeat dose studies, but continuation of single dose studies;
suspension of trials in one indication, but continuation in another and/or suspension of a particular dosing regimen in a trial but continuation
of other doses.

© EMEA 2008 Page 9/23

 animal studies before initiating a long-term clinical trial; need for thorough
QT/QTc study prior to Phase III clinical trials). In addition a cumulative listing of
advice from regulatory authorities should be provided as a table in an appendix.

In addition to the above, for drugs with a marketing approval, examples of significant
actions due to safety reasons include:
• Failure to obtain a marketing approval renewal;
• Marketing approval withdrawal or suspension for safety reasons;
• Risk management activities including:
o Significant restrictions on distribution or introduction of risk minimisation
measures;
o Significant changes in labelling documents that could affect the development
programme, e.g., restrictions to indication or population or a new warning;
o Communications to health care professionals as a result of the above actions;
and
o New postmarketing study requirement(s) imposed by regional authorities.

4. Changes to Reference Safety Information

This section should list any significant safety-related changes to the IB within the
reporting period. This includes information relating to contraindications, warnings,
precautions, serious adverse drug reactions, adverse reactions of special interest,
interactions, and any important findings from non-clinical studies (e.g. carcinogenicity
studies). Specific information relevant to these changes should be provided in the
appropriate sections of the DSUR.

5. Status of clinical trials ongoing and completed during the reporting period
This section should refer to an appendix that presents a listing of each clinical trial in
progress and each clinical trial completed during the reporting period. Separate tables
can be provided by indication, formulation, and study population if appropriate. In
addition, where required by local authorities, similar information should be provided
for other therapeutic use of an investigational drug in the reporting period e.g.,
compassionate use or expanded access.
The table(s) should include the following information for each trial:
• Protocol number or other trial identifier;
• Clinical trial phase (I, II, III, or IV);
• Status:
o Ongoing (study has begun; study has begun but is currently on hold; study is
completed, but final clinical study report is not yet available);
o Completed (final clinical study report is available);
• Countries/regions where there is at least one investigational site for the protocol;
• Abbreviated study title ;
• Study design (uncontrolled, controlled, open, single blind, double blind, parallel,
cross-over, etc., including treatment arms);
• Dose and regimen of study drug and any comparators;
• Subject population as appropriate (age; sex; indication(s); specific patient groups,
e.g., trial subjects with impaired renal function or trial subjects resistant to
treatment);
• Date of first visit for first patient;
• Planned enrolment for study as a whole;
• Estimates of cumulative numbers of exposed subjects where available for each
treatment arm. The actual enrolment numbers for open or completed trials, and/or

© EMEA 2008 Page 10/23

 an estimate based on the randomisation scheme for blinded trials should also be
provided.
An example of the column headings for this listing is provided in table 1.

6. Estimated exposure
The sponsor should clearly explain in the DSUR the method used to estimate
subject/patient exposure.

6.1 Cumulative subject exposure in development programme

Data on subject exposure to the investigational drug and placebo/active comparators
should be included in the DSUR. The DSUR should provide summary tables including
estimates of the overall numbers of subjects exposed as of the DSUR data lock point,
using either number of trial subjects or patient-time, as appropriate.

When the data are available, the DSUR should provide cumulative exposure data
giving the number of trial subjects by age group, gender, and ethnic origin 9 for the
development programme. Tabulation of demographic characteristics for a single trial
can be useful if the trial is of particular importance, e.g., a pivotal phase III trial.

See table 2 for examples of these tables.

These exposure tables provide context for the cumulative summary tabulations of
serious adverse events (SAEs). Therefore, if the summary tabulations are presented by
indication, the exposure data should also be presented by indication where available.

6.2 Patient exposure from marketing experience

If the investigational product is marketed, the commercial sponsor should provide the
estimated patient exposure in the marketed setting based on the information provided
in the PSUR for that product or other suitable data source.

7. Presentation of Safety Data from Clinical Trials

The DSUR should contain both cumulative and interval (periodic) safety information
relating to the investigational drug. This section of the report should present important
clinical safety information through interval line listings of the serious adverse
reactions that arose during the period covered by the DSUR, and cumulative
tabulations of serious adverse events that have been reported to the sponsor since the
DIBD. If MedDRA is used for coding the adverse event/reaction terms, the Preferred
Term level should be presented in the line listings and summary tabulations.
In general, the tabulation(s) of serious adverse events should include only those terms
that were used in defining the case as serious. Non-serious and incidental findings
should not be included.

If important and appropriate, the report should also include adverse reactions of
special interest within the line listings and adverse events of special interest in
summary tabulations. The basis for selection of such events/reactions should be
explained.

Certain adverse events can be excluded from the summary tabulations and line
listings, but such exclusions should be explained in the report. For example, adverse

9
Ethnic factors are defined as those factors relating to the genetic and physiologic (intrinsic) and the cultural and environmental (extrinsic)
characteristics of a population as described in ICH E5(R1): Ethnic Factors in the Acceptability of Foreign Clinical Data.

© EMEA 2008 Page 11/23

 events that have been defined in the protocol as “exempt” from special collection and
entry into the safety database, and those that are integral to efficacy endpoints, can be
excluded (e.g., deaths reported in a trial of a drug for congestive heart failure where
all-cause mortality is the primary efficacy endpoint or disease progression in cancer
trials).

7.1 General considerations

This section of the DSUR should include the version of the coding dictionary used,
and the document and version used as Reference Safety Information for determining
expectedness for the tabulations, where required by regional authorities.

7.2 Interval Line Listings of Serious Adverse Reactions (SARs)

This section of the DSUR should include general information about the content of the
line listings, the criteria for inclusion, and reference to appropriate appendices.
The line listings should provide key information on all blinded and unblinded SARs
reported during the reporting period, organised by System Organ Class (SOC). They
can integrate data from all the trials being conducted with an investigational drug.
Alternatively, when useful and feasible, SARs can be listed by protocol, indication, or
other variables.
Where possible the line listing(s) should include each subject only once regardless of
how many SAR terms are reported for the case. If there is more than one reaction, they
should all be mentioned but the case should be listed under the most serious adverse
reaction (sign, symptom or diagnosis), as judged by the sponsor. It is possible that the
same subject could experience different SARs on different occasions (e.g., weeks
apart during a clinical trial). Such experiences can be treated as separate reports.
Under such circumstances, the same subject can be included in a line listing more than
once, and the line listings should be cross-referenced when possible.
The format and content of the line listings described in ICH E2C can be used with
appropriate modifications (e.g., addition of the clinical trial identification number). An
example of the headings for a line listing is provided in Table 3.

7.3 Cumulative Summary tabulations

This section of the DSUR should include general information about the content of the
tabulations, the criteria for inclusion, and reference to appropriate appendices.
Summary tabulations should present cumulative safety data from the DIBD to the data
lock point of the current DSUR. The summary tabulations in a DSUR should include
the number of serious adverse events, 10 organised by SOC, for the investigational
drug, as well as for the comparator arm(s) (active comparators, placebo, and treatment
unknown due to blinding) used in the programme. Data can be integrated across the
programme. Alternatively, when useful and feasible, tabulations of SAEs can be
presented by protocol, indication, or other variables.
An example is provided in Table 4.

7.4 Deaths in the Reporting Period

A list of subjects who died during participation in the investigation should be provided
as an appendix to the DSUR if required by regional authorities. The list should include
the following information at a minimum: case number, assigned treatment (could still
be blinded), and cause of death.

10
For DSURs to be submitted to an EU Member State, a regional appendix should be provided. It should contain a summary tabulation of
all SARs, specifying the number of SARs by: a) SOC, b) reaction term and c) treatment arm, if applicable. Unexpected adverse reaction
terms should be identified.

© EMEA 2008 Page 12/23

 7.5 Subjects who dropped out in association with any adverse event in the
reporting period
Tabulations and listings of information on drop-outs should be provided as an
appendix to the DSUR, if required by regional authorities. Any safety issues
identified from a review of these withdrawals should be briefly described.

8. Significant findings from clinical trials during the reporting period

The information in this section can be provided by indication, when appropriate, and
should address the following topics, when applicable:

8.1 Completed trials and any interim analyses

The DSUR should provide a brief summary of the clinically important safety findings
included in the final study reports from all clinical trials completed and any interim
analyses conducted during the reporting period. This information can be in narrative
format, or in the study synopsis format provided as Appendix 5 of the Report of
CIOMS Working Group VII.

8.2 Ongoing clinical trials

The DSUR should provide a concise summary of any preliminary safety findings from
ongoing trials, including safety issues that are the same or similar to those previously
identified, as well as evidence of new clinically significant safety signals.

8.3 Other Therapeutic use of Investigational Drug

The DSUR should include safety information from expanded access programmes,
compassionate use programmes and treatment INDs, because they each follow a
specific protocol.

8.4 New Safety Data Related to Combination Therapies

If the sponsor has prepared a separate DSUR for a multidrug regimen or fixed
combination product containing the single investigational drug that is the subject of
this DSUR, relevant findings from that DSUR should be summarised in this section.

Conversely, if this DSUR is for a multidrug regimen or fixed combination product,

important safety information arising from trials on the individual components should
be briefly summarised here.

Alternatively, the information specific to the combination can be incorporated into a

separate section(s) of the DSUR for one or all of the individual components of the
combination.

9. Relevant findings from non-interventional studies

This section of the DSUR should summarise relevant safety information that became
available in the reporting period from non-interventional studies, e.g., observational
studies, registries, active surveillance programmes or epidemiological studies.

10. Relevant findings from other sources

The DSUR should also discuss relevant safety findings from any other available
sources (e.g., results from pooled or meta-analyses of randomised clinical trials, lack
of efficacy from trials in high morbidity/mortality disease states and trials with
vaccines).

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11. Safety findings from marketing experience
If the investigational drug has been approved for marketing in any country, this
section should include a concise summary of key safety findings that have arisen from
marketing experience during the reporting period, particularly if the findings resulted
in changes to the labelling or amendments to the product’s risk management plan.

12. Other Information

12.1 Non-Clinical data

Major safety findings from non-clinical in vivo and in vitro studies (e.g.
carcinogenicity, reproduction, or immunotoxicity studies) initiated or completed
during the reporting period should be summarised, and any impact on the clinical
safety of the investigational drug should be discussed.

12.2 Long-term follow-up

This section of the DSUR should provide information from long-term follow-up of
subjects from clinical trials of investigational drugs, particularly advanced therapy
products (e.g., gene therapy, cell therapy products and tissue engineered products).
This section could be the only information presented in the DSUR when the clinical
trials are completed and long-term follow-up is the only ongoing activity generating
data for the DSUR.

12.3 Literature
The commercial sponsor is expected to review the scientific literature periodically for
new safety information. This section should summarise new and significant safety
findings from non-clinical studies and clinical trials that have been published during
the reporting period. When available, this section should also include relevant new
information on drugs of the same class. Significant new safety information published
as an abstract for a scientific meeting should be summarised and a copy provided if
possible.

12.4 Other DSURs

When available, a commercial sponsor should summarise significant findings from the
DSUR provided by another sponsor conducting clinical trials with the investigational
drug during the reporting period.

12.5 Significant manufacturing changes

When required by regional authorities, this section should include a summary of
significant changes to the manufacturing process and/or formulation of an
investigational drug during the reporting period and discuss potential safety issues
arising from these changes, if applicable.

12.6 Lack of efficacy

For investigational drugs intended to treat serious or life-threatening illnesses, lack of
efficacy could constitute a significant risk to clinical trial subjects. In this setting, data
received during the reporting period that indicates lack of efficacy relative to
alternative therapies should be summarised.

12.7 Phase I protocol modifications

This section should describe significant Phase I protocol modifications not previously
reported, as required by regional authorities.

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13. Late-Breaking Information
Information on potentially important safety findings that present while the DSUR is in
preparation after the data lock point should be included in this section. Examples
include clinically significant new case reports, important follow-up data, and clinically
relevant toxicological findings. Any action that the sponsor, a Data and Safety
Monitoring Board, or regulatory authority has taken for safety reasons should also be
included.

14. Overall Safety Assessment

The overall safety assessment should be a concise, integrated assessment of all new
relevant clinical, non-clinical, and epidemiologic information obtained during the
reporting period relative to previous knowledge of the investigational drug. It should
not summarise or repeat information presented in previous sections of the DSUR, but
should provide an interpretation of the information, and its implications for the clinical
trial population. If appropriate, separate assessments can be provided by therapeutic
area and/or indication.

14.1 Evaluation of the risks

When relevant, the following points should be considered:
• meaningful changes in previously identified reactions (e.g., increased frequency or
severity, outcome, specific at-risk populations);
• newly identified safety issues (detailed description of adverse reaction; associated
laboratory values; risk factors; relationship to dose, duration, time course of the
treatment; reversibility; factors that could be useful in predicting or preventing
reactions);
• particular emphasis should be placed on symptoms, signs, and laboratory evidence
of newly and previously identified, clinically significant:
o hepatotoxicity;
o cardiovascular effects, including QT interval prolongation and results from
thorough QT/QTc studies;
o bone marrow toxicity;
o renal toxicity;
o central nervous system toxicity;
o immunogenicity and hypersensitivity;
o reactive metabolites;
• deaths that are an outcome of an adverse reaction;
• withdrawals due to safety reasons;
• any specific safety issues related to special populations, such as the elderly,
children, patients with hepatic or renal impairment, or any other at risk groups
(e.g., slow or fast metabolisers);
• positive and negative experiences during pregnancy or lactation;
• overdose and its treatment;
• drug misuse and abuse;
• experience with long-term treatment;
• risks associated with protocol procedures, including administration of the
investigational drug and diagnostic procedures;
• evidence of clinically significant medication errors;
• potential impact of significant new safety issues identified with another drug in the
same class; and
• drug–drug and other interactions.

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 The overall safety assessment should also discuss other relevant findings such as: non-
clinical research, manufacturing issues, lack of efficacy and lack of patient
compliance, when available.

14.2 Benefit-risk considerations

This section is not meant to be a full benefit-risk assessment but should be a succinct
statement on the balance between the theoretical benefits and the identified risks,
focusing particularly on whether there have been any changes in this balance since the
previous DSUR. If there has been a change, the sponsor should provide an assessment
of the impact on the clinical development programme.

14.3 Conclusions
The section should present a brief conclusion, addressing any changes to the previous
knowledge of safety and risks resulting from information gained since the last DSUR.
Finally, the conclusion should describe how risks have been managed in the trials and
any additional actions that should be taken to address emerging safety issues.

15. Summary of important risks

This section should provide a concise cumulative list of important identified and
potential risks (e.g., those that might lead to warnings, precautions, or
contraindications in labelling). The information in this section could provide the basis
for the Safety Specification of a risk management plan (ICH E2E). The list should be
continuously evaluated and updated from DSUR to DSUR and include risks that
require further evaluation, as well as safety concerns that have been fully addressed or
resolved.

16. Appendices to the DSUR

The following are appendices that might accompany the DSUR:
1 Investigator’s Brochure (if required);
2 Cumulative Table of Important Regulatory Advice;
3 Status of Ongoing and Completed Clinical Trials;
4 Cumulative Summary Tabulations of Demographic Data;
5 Line Listings of Serious Adverse Reactions (SARs);
6 Cumulative Summary Tabulation of Serious Adverse Events (SAEs);
7 Scientific Abstracts (if relevant).

Regional Appendices (as required by regional regulatory authority):

1 Drop-outs in Association with Adverse Events;
2 Deaths;
3 Summary Tabulations of SARs.

17. Appendices to Guideline

Appendix A. Glossary

Appendix B Tables 1-4

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 APPENDIX A
Glossary
Throughout this guideline the Working Group has used terms previously defined by ICH and other groups e.g., CIOMS. Those terms that
were previously defined in ICH documents are not repeated in this glossary. However, the glossary includes terms defined by CIOMS and
other groups.

Item Glossary Term Source of Definition/Commentary

Definition
1. Adverse event of Based on CIOMS VII An adverse event of special interest (serious or non-serious) is one of scientific and medical
special interest concern specific to the sponsor’s product or programme, for which ongoing monitoring and
rapid communication by the investigator to the sponsor could be appropriate. Such an event
might require further investigation in order to characterise and understand it. Depending on
the nature of the event, rapid communication by the trial sponsor to other parties (e.g.,
regulators) might also be warranted.
2. Clinical Trial Based on EU Clinical The authorisation in writing by the relevant regulatory authority of a clinical trial(s) described
Authorisation Trials Directive in a valid application. Commentary: In this guideline the term “authorisation” is used to refer
2001/20/EC to permission to conduct a clinical trial and the term “approval” is used to refer to permission
to place a medicine on the market.
3. Other therapeutic use Therapeutic use of an investigational drug under a protocol. This can include
of an investigational Expanded Access Programmes, Compassionate Use, and Treatment IND.
drug
Synonym: Expanded Access Programme: IND-based programme in the US that allows a sponsor to
Expanded Access supply an investigational drug to patients with an indication for which benefit has been
Compassionate Use demonstrated.
‘Treatment IND’ Compassionate Use Programme: A programme in the EU to supply an investigational product
to patients with an indication for which benefit has been demonstrated.
Treatment IND: Allows the supply of an investigational drug to treat patients with serious or
immediately life-threatening disease for whom no satisfactory alternative is available.
Commentary: This term does not include “particular patient”, “named patient” prescribing
which do not require a protocol.
4. Data lock point CIOMS VII The date (month and day) designated as the cut-off for data to be included in a DSUR.
Commentary: It is based on the Development International Birth Date (DIBD) and should
usually be in twelve-monthly increments.

© EMEA 2008 Page 17/23

Item Glossary Term Source of Definition/Commentary
Definition

5. Development CIOMS VII Glossary Date of first approval (or authorisation) for conducting an interventional clinical trial in any
International Birth country.
Date
6. Identified risk Volume 9A Rules An untoward occurrence for which there is adequate evidence of an association with the
Governing Medicinal medicinal product of interest.
Products in the EU
Examples of identified risks include:
-an adverse reaction adequately demonstrated in non-clinical studies and confirmed by
clinical data;
-an adverse reaction observed in well designed clinical trials or epidemiological studies for
which the magnitude of the difference compared with the comparator group (placebo or
active substance or unexposed group) on a parameter of interest suggests a causal
relationship;
-an adverse reaction suggested by a number of well documented spontaneous reports where
causality is strongly supported by temporal relationship and biological plausibility, such as
anaphylactic reactions or application site reactions.
7. Important identified Volume 9A Rules An identified risk or potential risk that could impact on the risk-benefit balance of the product
risk; Governing Medicinal or have implications for public health.
Important potential Products in the EU
risk
8. Investigational drug The term investigational drug is used in this guideline to indicate only the experimental
product under study or development.
9. Non-commercial For the purposes of this guideline, examples of non-commercial sponsors include the
sponsor following: (a) university, (b) healthcare centre, (c) a public scientific organisation, (d) a non-
profit institution, (e) a patient organisation, and (f) an individual researcher who is responsible
for the design, initiation, conduct, recording and publishing of the clinical trial.
10. Non-interventional Based on EU A study where the medicinal product(s) is (are) prescribed in the usual manner in accordance
clinical study Directive 2001/20/EC with the terms of the marketing authorisation. The assignment of the patient to a particular
on Clinical Trials therapeutic strategy is not decided in advance by a trial protocol but falls within current
practice and the prescription of the medicine is clearly separated from the decision to include

© EMEA 2008 Page 18/23

Item Glossary Term Source of Definition/Commentary
Definition
the patient in the study. No additional diagnostic or monitoring procedures are applied to the
patients and epidemiological methods are used for the analysis of collected data.
11. Potential risk Volume 9A Rules An untoward occurrence for which there is some basis for suspicion of an association with the
Governing Medicinal medicinal product of interest but where this association has not been confirmed.
Products in the EU Examples of potential risks include:
• Non-clinical safety concerns that have not been observed or resolved in clinical studies;
• Adverse events observed in clinical trials or epidemiological studies for which the magnitude
of the difference, compared with the comparator group (placebo or active substance, or
unexposed group), on the parameter of interest raises a suspicion of, but is not large enough to
suggest, a causal relationship;
• A signal arising from a spontaneous adverse reaction reporting system;
• An event which is known to be associated with other products of the same class or which
could be expected to occur based on the properties of the medicinal product.
12. Registry ICH E2E A registry is a list of patients presenting with the same characteristic(s). This characteristic can
be a disease (disease registry) or a specific exposure (drug registry). Both types of registries,
which only differ by the type of patient data of interest, can collect a battery of information
using standardised questionnaires in a prospective fashion.

© EMEA 2008 Page 19/23

APPENDIX B
TABLE 1 - EXAMPLES OF TABLE HEADINGS FOR CLINICAL TRIAL STATUS LISTINGS

STATUS OF ONGOING AND COMPLETED CLINICAL TRIALS

OVERVIEW OF ONGOING [study drug] STUDIES
Study ID Phase Country Study Title Study design Dosing regimen Study population FVFP* Planned Subject
enrollment exposure**

* FVFP = first visit first patient

** based upon total number of patients recruited as of [date] and applied randomisation schemes

OVERVIEW OF [study drug] STUDIES COMPLETED DURING THE DSUR PERIOD

Study ID Phase Countr Study Title Study design Dosing regimen Subject Subject/patient exposure
y population per treatment arm (M/F)

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APPENDIX B
TABLE 2 - EXAMPLES OF DEMOGRAPHIC DATA TABLES
CUMULATIVE SUMMARY TABULATIONS OF DEMOGRAPHIC DATA
Estimated cumulative subject exposure to [study drug] clinical studies by age and gender*
Number of subjects
Age (yr) Male Female Total
<16
16 - 25
26 - 35
36 – 45
46 – 55
56 – 65
66 – 75
>75
Total
* data from completed studies as of [date]

Estimated cumulative subject exposure to [study drug] in all clinical studies by ethnic origin*
Ethnic origin Number of subjects
Caucasian
Black
Oriental
Other
Total
* data from completed studies as of [date]

© EMEA 2008 Page 21/23

APPENDIX B
TABLE 3 - EXAMPLES OF HEADINGS FOR INTERVAL LINE LISTINGS OF SERIOUS ADVERSE REACTIONS

INTERVAL LINE LISTINGS OF SERIOUS ADVERSE REACTIONS (SARs)

Study ID Case ID/ Country Serious ADR(s) Outcome Date of Onset** Suspect Daily dose Dates of treatment Comments
EudraCT Subject Gender Time to Onset** Drug Route Treatment duration
number number* Age Formulation

-------- -------- ------- -------- -------- -------- -------- -------- --------

* Study/centre/patient
** ‘Primary’ SADR only

© EMEA 2008 Page 22/23

APPENDIX B
TABLE 4 - EXAMPLES OF CUMULATIVE TABULATIONS OF SERIOUS ADVERSE EVENTS

CUMULATIVE SUMMARY TABULATION OF SERIOUS ADVERSE EVENTS (SAEs)

System Organ Class Total up to 31-Dec-07

Preferred Term [study Blinded Active Placebo
drug] comparato
r
Investigations 18 4 7 2
Alanine aminotransferase increased 9 2 4 1
Aspartate aminotransferase increased 9 2 3 1
Nervous System Disorder 2 2 4 7
Syncope 2 2 4 7

© EMEA 2008 Page 23/23