Generative Agent Architecture · 21 CFR Part 11 Human Gate

Pharmacovigilance ICSR Intake, MedDRA Coding & Safety Narrative Automation

Executive Architecture Summary

GxP Agents automates multi-channel adverse event intake, ICH E2B(R3) field extraction, MedDRA term coding, seriousness assessment support, and clinical case narrative drafting—reducing per-case processing time by up to 65% while safeguarding 7-day and 15-day expedited FDA/EMA reporting compliance.

65%
Reduction in ICSR Case Processing Time
Across intake, entity extraction, coding, and narrative drafting
15-Day
Expedited SLA Compliance Protected
Real-time seriousness triage under 21 CFR 314.80 and EU GVP Module VI
100%
Human Medical Reviewer Sign-Off
Every seriousness, expectedness, and causality determination signed by PV staff
Validated Orchestration Topology

How the Multi-Agent Workflow Executes

Connected Systems:Oracle Argus SafetyVeeva Vault SafetyArisGlobal LifeSphereMedical Information Call LogsGlobal Literature Feeds
01 · Multi-Channel Case Intake & De-Duplication

ICSR Intake Agent

Extracts patient, reporter, suspect drug, concomitant medication, and adverse event data from forms, emails, call transcripts, and literature.

Validated Output Artifact
Structured ICH E2B(R3) XML/JSON Candidate + Duplicate Check Log
02 · MedDRA & WHODrug Auto-Coding

Medical Terminology Agent

Maps verbatim reporter terms to current MedDRA LLT/PT hierarchies and WHODrug codes with explicit confidence thresholds.

Validated Output Artifact
Confidence-Scored MedDRA Coding Sheet with verbatim highlights
03 · Seriousness Triage & Case Narrative Drafting

Safety Narrative Agent

Evaluates IME/DME lists and IB/CCDS expectedness to flag 7/15-day expedited cases and generates a chronological clinical case narrative.

Validated Output Artifact
Draft Case Narrative + Expedited Clock Priority Alert
04 · Drug Safety Physician / QPPV Gate

21 CFR Part 11 / GVP Medical Gate

Routes coded case and draft narrative to the safety specialist and medical reviewer for causality evaluation and e-signature.

Validated Output Artifact
Signed Safety Case + E2B(R3) Gateway Transmission Record
21 CFR Part 11 (§ 11.50) Mandatory Human Signature Gate

Accountable Role: Drug Safety Physician / Qualified Person for Pharmacovigilance (QPPV)

Signature Meaning: Medical Review, Causality Assessment & Regulatory Expedited Submission Approval. Agents never execute autonomous GxP disposition or modify validated system-of-record state without human approval.

Operational Benchmark Comparison

Legacy Manual Process vs. Validated GxP Agent Workflow

Workflow DimensionLegacy Manual ProcessGxP Agent Validated Workflow
Case Intake & Data Entry45–90 minutes of manual transcription from PDFs, faxes, and emails into Argus/Vault< 3 minutes automated E2B(R3) extraction with source-span highlighting
MedDRA & WHODrug CodingManual dictionary browsing; inter-coder variability across global hubsStandardized MedDRA LLT/PT mapping with confidence routing to human coders
Clinical Narrative Writing30–60 minutes drafting chronological narratives from scratchStructured, template-compliant narrative drafted in seconds with lab & dose tables
Primary Regulatory Alignment

FDA, EMA, ICH & GAMP 5 Controls Built In

21 CFR 314.80 & 600.80Primary Regulator Source ↗

Postmarketing Reporting of Adverse Drug & Biologic Experiences

Prioritizes serious and unexpected adverse events immediately at Day 0 intake to protect 15-day Alert Report timelines.

Management and Reporting of Adverse Reactions to Medicinal Products

Maintains complete auditability of case intake, duplicate detection, and QPPV oversight.

Electronic Transmission of Individual Case Safety Reports

Outputs schema-validated E2B(R3) data elements ready for EudraVigilance and FDA FAERS.

Frequently Asked Questions: PV & ICSR Case Automation

Does the AI determine causality or submit ICSRs directly to FDA FAERS or EudraVigilance?

No. Causality assessment, final seriousness/expectedness confirmation, and regulatory gateway transmission always require review and electronic signature by a qualified pharmacovigilance professional or Drug Safety Physician.

How are MedDRA dictionary version updates handled?

Semiannual MedDRA and WHODrug dictionary updates are managed under controlled configuration management with automated regression testing across a gold-standard validation set before promotion to production.