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ICH E2F DSUR: data cutoff and integrated safety review

Combining tables from different cutoffs can obscure the meaning of a DSUR.

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Combining tables from different cutoffs can obscure the meaning of a DSUR. An E2F-focused data-close plan helps teams define the reporting interval, coordinate contributions and explain how important information received after the cutoff will enter medical review.

Establish the reporting interval

ICH E2F describes recommended content and format for periodic safety reporting during development. A DSUR supports evaluation of interval and cumulative information rather than merely listing individual cases. Verify regional submission conditions and reporting calendars separately so a common report does not obscure jurisdiction-specific obligations.

Plan data contributions

Create a contribution calendar assigning owners, cutoffs and deliverables for clinical studies, marketing status, literature and other relevant sources. Check that study inventories, exposure and serious-event summaries cover the same scope. Document information-sharing responsibilities where parties are jointly developing the product and contributing different parts of the safety record.

Apply a closeout checklist

Define in advance how important information after cutoff will be handled. A reconciliation record can show unresolved discrepancies and their interpretive effect. When a table changes late, route the change to the decision owner to determine whether the medical assessment also requires review before approval.

  • Reconcile the study inventory with exposure scope.
  • Assign a cutoff and data owner to each contribution.
  • Define late-information and medical rereview pathways.

Preserve integrated interpretation

The report’s conclusion should connect new and ongoing risks to the investigation plan. A DSUR does not delay required expedited reporting. A comment log showing how issues were closed among author, medical reviewer and approver reduces inconsistent final versions and preserves the reasoning behind important safety conclusions.

Frequently asked questions

Is a DSUR only a case listing?
No. It includes integrated evaluation of interval and cumulative safety information.
Can information after cutoff be ignored?
Assess important late information through the predefined process and applicable requirements.

Sources

  1. FDA — ICH E2F Development Safety Update Report
  2. FDA — ICH E2F, full guidance