Ghana's FDA requires every registered product to have an active pharmacovigilance system behind it. Companies newer to the Ghanaian market — particularly those focused entirely on getting a product approved — often don't realise this until they are already out of compliance, because pharmacovigilance is an ongoing obligation, not a one-time submission requirement.
What FDA actually requires
Under FDA's guideline on safety monitoring of medicinal products, every Marketing Authorisation Holder must continuously monitor the risk profile of its registered products and maintain a functioning pharmacovigilance system. That system must be led by a named, FDA-approved Qualified Person for Pharmacovigilance (QPPV) — a specific accountable individual, not a generic company function.
Periodic safety reporting
The reporting cadence differs by product history:
- New chemical entities: Periodic Safety Update Reports (PSURs/PBRERs) every six months for the first two years post-registration, then at renewal, and on request at any time
- Other registered products: the most recent PSUR/PBRER submitted at the time of registration renewal
- Submission deadline: generally within 60 days of the relevant data lock point
Urgent safety signals
Outside the routine reporting cycle, urgent safety signals carry their own, much tighter timeline: FDA guidance points to immediate email notification, followed by a formal letter within seven days. This is not a process to build under pressure the first time a genuine signal arises — the pathway needs to exist and be understood before it's ever needed.
Risk Management Plans and post-market studies
Risk Management Plans are required for new chemical entities, major label changes, paediatric indications and new fixed-dose combinations. Where a company already holds a global or EU RMP, Ghana FDA requires it to include a Ghana-specific annex rather than being submitted unchanged. Where Post-Authorisation Safety Studies are underway, quarterly progress reports and a final study report carry their own defined submission windows.
Building the system before you need it
The companies that handle pharmacovigilance well set up the QPPV role, the reporting SOPs and the adverse-event intake pathway before their first product reaches the market — not after an incident forces the question. Retrofitting a PV system under regulatory pressure is a far harder position than building it as part of the original launch plan.
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