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Covid 19 Vaccine

  • 1.  Covid 19 Vaccine

    Posted 01-Dec-2020 14:23
    Edited by Lance Tovar 01-Dec-2020 15:40
    Hi everyone,

    For discussion purposes only... What does everyone think about this vaccine? Are companies really following the regulatory guidelines? Are we going to see safe, efficacy ,and quality in this vaccine? 

    ------------------------------
    Lance Tovar
    RA/QA Specialist
    Roy UT
    United States
    ------------------------------


  • 2.  RE: Covid 19 Vaccine

    Posted 01-Dec-2020 15:09
    Personally, I have more faith in the efficacy of the EUA-candidate vaccines than the safety. Normally, the safety of a vaccine is assessed through long-term nonclinical toxicity studies (9-18 months) before the vaccine's safety/efficacy can be assessed in humans. I don't think the long-term safety profile of a vaccine can be fully established in the time that has elapsed, but we should have decent understanding of the short-term, acute adverse effects.

    ------------------------------
    Jeffrey Freedman
    QA/RA Specialist III
    Lowell MA
    United States
    ------------------------------



  • 3.  RE: Covid 19 Vaccine

    Posted 02-Dec-2020 00:25
    I agree with you specifically regarding the mRNA vaccines!!!

    ------------------------------
    GRSAOnline
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  • 4.  RE: Covid 19 Vaccine

    Posted 02-Dec-2020 06:56
    I think the vaccine candidates are following the regulatory guidelines.  The difference between an EUA and a BLA are significant, but the safety and efficacy profiles presented thus far do not cause me any concern that those benchmarks cannot be reached.  I don't know much about Moderna, but I am sure that Phizer and Astra-Zeneca are well aware of the quality requirements expected.

    Regards,
    James

    ------------------------------
    James Bonds J.D.
    Director Regulatory Affairs
    Atlanta GA
    United States
    ------------------------------



  • 5.  RE: Covid 19 Vaccine

    Posted 02-Dec-2020 06:44
    I personally don't believe there has been enough time time to study the safety of this vaccine. We don't know what an RNA vaccine can do to a human's immune system. It basically is triggering an autoimmune response. A vaccine that is 94% effective for a disease that has a 98+% survival is in my opinion, not necessary, especially for people under 50 years old.

    ------------------------------
    Linda Payne
    Regulatory Affairs Manager
    Winter Springs FL
    United States
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  • 6.  RE: Covid 19 Vaccine

    Posted 03-Dec-2020 04:14
    Great point, which is something I have been wondering myself. Logically they do antigen testing to see whether the vaccine triggers an immune response, but if the clinical trial subjects also remained in quarantine/social distancing, how do they know if there was exposure? How do you separate vaccine efficacy to not being exposed?

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    Luis Peña-Ortiz
    Jena
    Germany
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  • 7.  RE: Covid 19 Vaccine

    Posted 04-Dec-2020 14:33
    Edited by Christopher Horoszko 04-Dec-2020 14:43
    The thing that lots of people fail to transparently convey to the public, is that due to those post-WWII hearings in Europe, human experiments where the variable of "challenge" is introduced are very rare. i.e. to show efficacy, you 'challenge' the subject with the putative disease causing thing.

    That wasn't done, and isn't done for the vast majority of vaccines.

    Therefore, we are left with "sample interpolation" based on an inhomogeneous population 'dosed' with a vaccine; said vaccine is tested for its ability to cause antigen presentation and an immune response; END.

    The assumption is that, when the human subjects are "sent back into the wild", they will mix with the rest of the population and get exposed to covid19, wildtype.

    That is the main caveat here -- assuming an inhomogeneous test population will mix homogeneously with the "infected" population and eventually get infected themselves.

    So the statistical efficacy numbers are packed with some fudge.

    ------------------------------
    Christopher P. Horoszko, Ph.D.
    Risk & Tech Consultant
    CPLT Consulting LLC
    West Palm Beach, FL
    USA
    ------------------------------



  • 8.  RE: Covid 19 Vaccine

    Posted 03-Dec-2020 09:08
    Edited by Julie Omohundro 03-Dec-2020 12:42
    I am taking the efficacy data with a grain of salt, due to the diversity of the patient population enrolled in the trial. The results represent the combined results of its efficacy in numerous subpopulations defined by gender, race, age, and occupation.  To the extent that it is representative of the US population, its results are applicable to the "average" member of that population, i.e., someone who doesn't exist.

    The irony here is that, to the extent that efficacy differs across these subpopulations, the less applicable the overall efficacy result is to members of those subpopulations, and, to the extent that efficacy does not differ across subpopulations, the diversity was pointless, at least from a scientific perspective.  At the same time, the sample sizes for each subpopulation are too small for those results to have much scientific validity.

    The trial serves as a good illustration of the difference between public health and individual health. Public health agencies seek to protect the health of "the public" (aka the community, population, herd), not individuals.  A trial that measures efficacy in a sample that is representative of the herd as a whole is exactly what is needed for public health purposes.  However, for doctors, who are interested in how well a vaccine might protect the health of their individual patients, and for individuals who are interested in how well it will protect them and their family members, not so helpful, unless it turns out that differences in gender, age, race, etc, don't affect efficacy.

    CBER should require a justification for pooling the data across these subpopulations.  I will be interested to see if it does and, in that case, what the results seem to show.

    ------------------------------
    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Mebane, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com
    ------------------------------



  • 9.  RE: Covid 19 Vaccine

    Posted 10-Dec-2020 13:30
    Hi Julie, 
    Just heard your comment at the VRBPAC meeting, and you brought up good points! Thanks for raising these issues, though I'm afraid their course of action has already been decided.

    ------------------------------
    Kat Crowder
    Lake Zurich IL
    United States
    ------------------------------



  • 10.  RE: Covid 19 Vaccine

    Posted 04-Dec-2020 11:06
    Keep in mind that 98% survival would still mean more than 5 1/2 MILLION deaths in the US alone. A 94% effective vaccine will save more than 5 million lives in the US and at the same time allow relaxation of the masking, social distancing, and lockdown measures that are impacting all of us.
    These numbers are for mortality but don't take into account the additional morbidity that is now being reported that can be debilitating and might affect a significant additional proportion of the population. We're less than a year into the emergence of this virus and cannot know its full long term impact on individual health.

    I agree that there is only limited safety data. As with any pandemic vaccine, the general public becomes trial subjects but if this can save 5 million lives (and maybe 100 million worldwide as US is 5% of the world population), then the risk/benefit becomes acceptable. That said, everyone must make their own decision between the risk of the vaccine and the hope that herd immunity will protect them. Also, keep in mind that there are additional vaccines still being tested that use different platforms from mRNA, some already in use for other vaccines

    ------------------------------
    Sam Simons
    Director, Regulatory Affairs
    Westerly RI
    United States
    ------------------------------



  • 11.  RE: Covid 19 Vaccine

    Posted 04-Dec-2020 14:41
    Edited by Christopher Horoszko 04-Dec-2020 14:48
    Agreed.

    My only walk-back is that you wouldn't necessarily call this an "auto-immune" inducing therapy. Auto-immunity is a very specific biochemical cascade, whereas with a vaccine and native virus, you are talking about a foreign exogenous pathogen being 'recognized' by the innate/adaptive immune system. This doesn't involve the system 'recognizing' the host's own cells.

    RNA is from the wildtype virus, so when the wt virus injects it's genetic material into your cells, your cells are responding the same as they would to most viruses. This is not "auto-immune". The RNA vaccine just skips the step where a live virus fuses with your cells and replicates.

    Now -- the million dollar question you are probably probing. Given the very odd systemic effects of the disease, which DO look auto-immune like, how much will the vaccine simply presenting the immune system with the wt viral genetic material to adapt to -- ALSO cause/replicate the auto-immune-like features noted with infection by the wt viron.

    (being infected by a live wt virus causes many different things to happen, whereas presenting a small piece of the virus may not)

    Who knows yet.


    ------------------------------
    Christopher P. Horoszko, Ph.D.
    Risk & Tech Consultant
    CPLT Consulting LLC
    West Palm Beach, FL
    USA
    ------------------------------



  • 12.  RE: Covid 19 Vaccine

    Posted 04-Dec-2020 14:50
    We also have to keep in mind that the mortality rate (defined as case-fatality rate) is completely dependent on environmental factors. If the health care system becomes overwhelmed such that not everyone gets needed treatment, then the mortality rate will go up. We may start to see the mortality rate go up over the next few months w/o the vaccine.

    ------------------------------
    Rachel Thornton
    Associate Director
    Smyrna GA
    United States
    ------------------------------



  • 13.  RE: Covid 19 Vaccine

    Posted 04-Dec-2020 17:41
    Re: overwhelmed. Why? Results from the first and second (or 1.5, depending on who you ask) "wave" of cases in the U.S. showed that practically all healthcare/clinical operations were fine, operational, and last time I checked, free of any scenario remotely akin to the predicted "overwhelmed and saturated" scenario....even where I am here in NYC.

    Re: environmental factors. The above wouldn't be considered environmental, but "care" or "infrastructure". Environmental are the things everyone is overlooking: personal health, sun, pollution, diet, mental health, etc.

    CFR and IFR are quite different; the former is subject to facility care and infrastructural variables.

    From a "larger scale viewpoint", wave 2+ will have a lower case/mortality load than the prior waves, due to training and herd immunity. But yes, 'up' is the only direction that the cases/deaths would be expected to go, relative to a scenario where 'everyone vaccinated'. Mother Nature and stuff.

    ------------------------------
    Christopher P. Horoszko, Ph.D.
    Risk & Tech Consultant
    CPLT Consulting LLC
    West Palm Beach, FL
    USA
    ------------------------------



  • 14.  RE: Covid 19 Vaccine

    Posted 10-Dec-2020 13:47
    Christopher, there are dozens of cases of overwhelmed hospitals in the US throughout the pandemic. I can't find a simple list, but patients being turned away, ambulances being directed to multiple locations to find an open spot, patients being treated in waiting rooms or parking lots, non-ICU units rapidly converted to ICU units, inability to segregate COVID and non-COVID patients, and rationing care, as examples, have all been reported numerous times. Even when it's not a matter of 100% of the hospitals' available beds being occupied, there is a huge volume of COVID patients that results in a much greater need for the staff needed to support the specific and intensive/extensive needs of the COVID patients. Many doctors and nurses are working significantly more hours in the COVID wards, having to work sick, and burning completely out, even committing suicide. I completely object to your statement that "practically all healthcare/clinical operations were fine, operational, and...free of any scenario remotely akin to the predicted 'overwhelmed and saturated' scenario." Where you are in New York, last week the state has ordered hospitals across the state to identify retired doctors and nurses to return to the frontlines, confirm a 90-day PPE stockpile, and increase bed capacity by 50 percent. Do you remember the morgue trucks? You must be in New York, New Zealand, by the way you're talking. 

    ------------------------------
    Kat Crowder
    Lake Zurich IL
    United States
    ------------------------------



  • 15.  RE: Covid 19 Vaccine

    Posted 10-Dec-2020 14:19
    Edited by Christopher Horoszko 10-Dec-2020 14:49
    Kat -- you are at length discussing "the preparation phase", that occurred under the assumption that the scenario would be apocalyptic. It isn't surprising that retired clinical workers were called up from retirement. That's "we are expecting to be inundated". It is common.

    If you're telling me (and I agree) that various places had to "redirect" incoming traffic, that's not a counter-example or proof that infrastructure 'failed'. That's evidence that the system was functioning as it should. This feature (not bug) certainly wasn't 'widespread'.

    NYC was one of the epicenters, all hospitals were able to accept patients and re-direct them as necessary. Exciting. I work for one of these hospital systems that took up patients and re-directs. Ordinarily they wouldn't take such patients. But they did to help. The situation was, according to an on-call Doc "generally normal if not a bit more rushed".

    The Military sent us an entire ship. We never used it. Only a small fraction (if any) of the 'arena sized field unit' they set up was used. Most of the requested ventilator units were not used. It was later reported, that an overwhelming majority of those rushing into ERs did so for unrelated things (read: I have a sore throat, it must be covid; it wasn't).

    The remainder of your litany is on a separate topic of 'supply-chains'. The morgue comment is off topic, unless we're about to make a hypothesis on the relationship between coroner/mortuary services and clinical infrastructure.

    ------------------------------
    Christopher P. Horoszko, Ph.D.
    Risk & Tech Consultant
    CPLT Consulting LLC
    West Palm Beach, FL
    USA
    ------------------------------



  • 16.  RE: Covid 19 Vaccine

    Posted 11-Dec-2020 09:04
    Christopher 

    Great, you are talking about New York.  Rural hospitals in my area and Minnesota are overwhelmed and sending patients to the Twin Cities. And now 95 %,of their beds are full.  Patients are being housed in ERs and temp shelters.  

    Our clinics have stopped prioritizing any other services except COVID . Good luck with any other emergency.   This is even with knowing how to better treat.  Mayo clinic  has shut most clinics regionally. We don't  have enough staff or beds.

    I have many friends who have gotten it, double pneumonias, one friend's  father died. Many are in hospital..great that you have cutting edge technology.  We are rationing healthcare and even some sick patients with pneumonia are being told to stay home, monitor their own pulse ox to save beds and don't come to the hospital.   Yay for you, your system isn't overwhelmed.  Ours is.  And still we have idiots flouting wearing no masks at all. Selfish.


    ------------------------------
    Ginger Cantor, MBA, RAC
    Founder/Principal Consultant
    Centaur Consulting LLC
    River Falls, Wisconsin 54022 USA
    715-307-1850
    centaurconsultingllc@gmail.com
    ------------------------------



  • 17.  RE: Covid 19 Vaccine

    Posted 11-Dec-2020 11:40
    Edited by Christopher Horoszko 11-Dec-2020 11:42
    Ginger -- it's unfortunate that this sub-thread has transformed into a "mine is worse" (subjectively) battle over the simple premise of clinical infrastructure stress. My original point was to convey (perhaps to no avail) that one can easily falsify the claim 'there was a total collapse' based on what happened for the test case of a fully operational clinical system (i.e. one that wasn't "handicapped" up front).  

    Because NY (metro) was an epicenter, has the highest population density in the country (with no abnormal difference in the facility:resident ratio), and took the worst initial hit (lasting a long time due to the density issue), it is the best 'case study' of this premise. Even so, some facilities were not able to take patients.

    What you are relaying is a very unfortunate case of a very low pop density area being handicapped by close-to-zero infrastructure (from a physical access perspective). There are too many additional caveats here to think it is a test of the premise. It makes sense that special care/chemistry required clinics to re-route.

    But the issue of someone closing down whole clinics/hospitals! This is NOT GOOD. This sounds like standing for Legal intervention.

    An important side-bar not considered yet is the role of the facility administration. The invisible hand making much of the operational, supply/demand, human, priority decisions for the facility. A truly unfortunate source of much of the dubious actions made/taken many months ago. The hit taken everywhere to non-covid services/access is truly appalling.


    ------------------------------
    Christopher P. Horoszko, Ph.D.
    Risk & Tech Consultant
    CPLT Consulting LLC
    West Palm Beach, FL
    USA
    ------------------------------



  • 18.  RE: Covid 19 Vaccine

    Posted 02-Dec-2020 08:28
    Having spent many years in the vaccine world in Regulatory I have good confidence in the vaccines that FDA will authorize under EUA.  Historically, the timeframe for adverse reactions to surface with vaccines is approximately the first six weeks post-vaccination and most, historically, have been associated with injection site reactions, fever, mild nausea, etc.  This is why the FDA EUA guidance for these vaccines requires at least 2 months of safety follow up and continued follow up of all vaccine recipients long term.  Long-term, we will have to monitor and see how the general population reacts.  I don't believe any of the trials were "challenge" trials where the vaccine was given and then subjects purposely exposed to COVID-19 virus, so time will tell re long term effect.

    I encourage all to read the FDA EUA guidance for COVID vaccines to understand the bar being set for all companies and also tune into the upcoming December 10 and 17 Advisory Committee meetings where the Pfizer and Moderna vaccines will be examined, respectively.

    Glenn

    ------------------------------
    Glenn Byrd, MBA
    President, GByrd Ad-Promo Solutions, LLC
    President, RAPS Board of Directors
    United States
    ------------------------------



  • 19.  RE: Covid 19 Vaccine

    Posted 02-Dec-2020 11:36
    What is the probability of a vaccine being denied due to longer-term issues?

    ------------------------------
    Edward Panek
    VP, QA/RA
    Med Device

    DOD/DARPA/Dept Veterans Affairs Design Controls in Research

    Research into Neural Nets - https://www.twitch.tv/edosani
    ------------------------------



  • 20.  RE: Covid 19 Vaccine

    Posted 02-Dec-2020 12:46
    Ed,

    That's a great question.  Part of the EUA is that companies must pursue BLA licensure/approval as soon as the full Phase III studies read out.  When the Emergency is declared over, products under EUA technically have to come off the market - so having that BLA is critical.

    Much like an accelerated approval - continued and full approval is contingent upon successful completion of confirmatory trials and an FDA review and determination that the product is ultimately safe and effective.

    Glenn

    ------------------------------
    Glenn Byrd, MBA
    President, GByrd Ad-Promo Solutions, LLC
    President, RAPS Board of Directors
    United States
    ------------------------------



  • 21.  RE: Covid 19 Vaccine

    Posted 03-Dec-2020 09:09
    What does "technically" mean in this context?

    ------------------------------
    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Mebane, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com
    ------------------------------



  • 22.  RE: Covid 19 Vaccine

    Posted 03-Dec-2020 09:42
    Julie,

    Good question on "technically".  I was very vague/general by design.  The reality of the situation that FDA will be faced with at the end of the Emergency will be dependent upon a multitude of factors (more complex than I'm willing to type here).

    Fundamentally, if I'm FDA and the emergency is declared over I have to decide whether to continue to allow distribution of a product under EUA (all EUA products - IVDs, ventilators, drugs, vaccines - all of them).  One of the elements in the EUA framework is that a company is supposed to pursue market authorization/approval as quickly as possible.  So, for example, in a scenario where the emergency is declared over and FDA looks at product X that is available under EUA, they will need to see if the company has a PMA, 510(k), BLA, or NDA submitted and in the process of FDA review for that product.  If that is the case and that application is progressing through review and appears to be approvable, then FDA may be likely to exercise discretion and be more flexible in not just cutting off the EUA.  That would ensure continued availability of product in the marketplace as it transfers from EUA status to approval status.

    In an alternate situation, if a product is available under EUA and the company has not submitted an application for approval or if that application has significant deficiencies that would result in non-approval, then I believe FDA would act differently and not be as lenient.

    Reality is that this continues to evolve.  FDA has a huge task on its plate to develop guidance for industry on exactly this topic so industry knows what to expect as the situation evolves over time.

    Glenn

    ------------------------------
    Glenn Byrd, MBA
    President, GByrd Ad-Promo Solutions, LLC
    President, RAPS Board of Directors
    United States
    ------------------------------



  • 23.  RE: Covid 19 Vaccine

    Posted 03-Dec-2020 10:43
    Glenn,

    I find this very interesting. I was under the impression that the marketing/distribution of products that have received emergency use authorization would have to cease when either a) the EUA is revoked or b) the public health emergency is terminated by DHHS.

    Jeff

    ------------------------------
    Jeffrey Freedman
    QA/RA Specialist III
    Lowell MA
    United States
    ------------------------------



  • 24.  RE: Covid 19 Vaccine

    Posted 03-Dec-2020 15:00
    That is my take as well.  Advance notice of termination is required in order to provide time to dispose of unused supplies of the product, but the authorization to sell product ends with the termination of the declaration.  The one exception seems to be in situations where a patient is currently using an unapproved product and their doctor determines that continued use is necessary to their health.  If it is a product approved for other indications, the physician can prescribe it off-label.



    ------------------------------
    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Mebane, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com
    ------------------------------



  • 25.  RE: Covid 19 Vaccine

    Posted 04-Dec-2020 08:10
    Ed,

    As with other accelerated approvals that reach the market initially under that path, the requirement is successful completion of confirmatory trials (pivotal trials) where the study prespecified safety and efficacy endpoints are met and support a full approval.

    There are several examples where products initially approved under accelerated approval failed in long-term trials and had to be withdrawn from the market.  It is an established process and if that would occur with a vaccine, the same situation should apply - failure in pivotal trials should result in withdrawal of the product from the market.

    Glenn

    ------------------------------
    Glenn Byrd, MBA
    President, GByrd Ad-Promo Solutions, LLC
    President, RAPS Board of Directors
    United States
    ------------------------------



  • 26.  RE: Covid 19 Vaccine

    Posted 04-Dec-2020 14:23
    Ed, do you mean...

    Denied authorization due to a lack of data on longer term safety issues?
    Denied approval due to longer term issues identified with longer term safety data available at the time it is being considered for approval?
    Authorization/approval being withdrawn due to longer term safety issues that emerge post-authorization/approval?

    ------------------------------
    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Mebane, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com
    ------------------------------



  • 27.  RE: Covid 19 Vaccine

    Posted 10-Dec-2020 13:52
    My question was, considering all the phases of drug evaluation that could cause failure, what does it mean that we are abridging the testing in this regard. Is it 5% of drugs fail to the area being abridged? Etc.

    ------------------------------
    Edward Panek
    VP, QA/RA
    Med Device

    DOD/DARPA/Dept Veterans Affairs Design Controls in Research

    Research into Neural Nets - https://www.twitch.tv/edosani
    ------------------------------



  • 28.  RE: Covid 19 Vaccine

    Posted 10-Dec-2020 17:19
    Interesting question.  I'm not sure the data are available to answer it.  Also not sure enough drugs have had testing abridged to generate much data to answer the question.

    My own perspective is influenced heavily by the high failure rate of medical startups, of which "abridging" seems to be a leading cause.

    ------------------------------
    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Mebane, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com
    ------------------------------



  • 29.  RE: Covid 19 Vaccine

    Posted 10-Dec-2020 20:14
    I think what you're asking is basically what causes vaccines to fail in clinical trials and have they skipped or not reached that step with these COVID-19 vaccines.

    I am not involved in the clinical side of RA so you can take what I say with a grain of salt. But I did work in vaccine development on the CMC side for 18yrs and I've heard things. While the failure rate for drugs is quite high, the failure rate for vaccines is lower. I found one website that says that while only 10% of drugs make it past Ph1, 22% of vaccines do (https://www.biospace.com/article/past-vaccine-failures-may-reduce-covid-19-vaccination-rates-/). These vaccines have been through Ph1, so that's not an issue. They go on to say that 38% of drugs fail in Ph3, but they don't specify for vaccines and I haven't been able to find a number for that (in a quick Google search, which is all I have time for right now). Vaccines fail in Ph3 for 2 main reasons: They don't prevent disease (or don't prevent it enough) or there's a safety signal that didn't show up in the Ph2 studies due to the lower number of patients, but I don't know the statistics on how often it's one or the other. These vaccines appear very efficacious, though the infection rates in vaccine subjects vs. placebo may be confounded by the behavior patterns of those particular people. The safety part is why there was so much discussion about how much safety follow-up was required for authorization. But the experts are saying that in general, safety issues for vaccines show up in the first couple of months. The Pfizer trial was quite large overall by vaccine standards (at least based on my experience from 10yrs ago), so it has a decent chance of picking up rarer AEs.

    My take is that while there was a pretty decent chance that the vaccines would just not work, now that we have the data showing that it does seem to work, there's little reason to think that it will turn out to not work after all. What could happen, though, is that it doesn't work as well (say, only 70% efficacious instead of >90%) under real-world conditions, and/or that it doesn't work for very long. I'm also not sure how compelling the data are on whether it appreciably prevents severe disease, as there were only 10 cases observed in the trial (though 9 of those were in the pbo group and only 1 in the vaccine group).

    ------------------------------
    Rachel Thornton
    Associate Director
    Smyrna GA
    United States
    ------------------------------



  • 30.  RE: Covid 19 Vaccine

    Posted 03-Dec-2020 00:26
    I don't think I have any way of knowing whether the companies are following any guidelines, or much of anything else about these vaccines.  Based on the description of CBER's vaccine approval process, CBER doesn't verify the integrity of the clinical data submitted to support approval of new vaccines, so I'm not sure how much CBER knows, either. If the manufacturers farmed out their clinical trials, which seems likely, they might not know all that much, either.

    In any case, if FDA won't approve it, I won't take it.  FDA approved or not, I will never take any of warped speed vaccines.  There are some smaller companies out there, quietly chugging along at a reasonable pace.  Maybe one of them will come up with something eventually.

    ------------------------------
    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Mebane, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com
    ------------------------------



  • 31.  RE: Covid 19 Vaccine

    Posted 03-Dec-2020 07:27
    Julie,

    As a Regulatory professional, you should know that BLA approvals are no different than NDA approvals (or PMA approvals for that matter).  Bioresearch monitoring audits by FDA staff are conducted to confirm clinical study data is valid and accurate as part of the approval process.  If discrepancies are found that jeopardize the integrity of the study data such that a determination of safety/efficacy is compromised a product would not get approved.

    Glenn

    ------------------------------
    Glenn Byrd, MBA
    President, GByrd Ad-Promo Solutions, LLC
    President, RAPS Board of Directors
    United States
    ------------------------------



  • 32.  RE: Covid 19 Vaccine

    Posted 03-Dec-2020 08:27
    Edited by Julie Omohundro 03-Dec-2020 09:17
    Hi Glenn,  I've never subscribed to the notion of a general-purpose, one-size-fits-all RA professional and do not present myself as one.  As a medical device regulatory professional, I've never had the slightest interest in BLA anything.  My current interest is limited to COVID-19 vaccines.

    I'm pleased to hear that BIMO audits are conducted, since all the information I've been able to find on FDA's website regarding its vaccine approval process refers only to manufacturing site inspections, no BIMO audits.  I will be very interested to read those inspection reports.

    I will also be interested to find out if all of the "inspections" were conducted remotely, as well as the details on how BIMO conducts remote audits.

    ------------------------------
    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Mebane, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com
    ------------------------------



  • 33.  RE: Covid 19 Vaccine

    Posted 04-Dec-2020 10:01
    FDA has ben performing all 'mission critical' inspections live, not remote.  The BIMO inspections for vaccine studies are being conducted as live inspections.  I have worked with several sites where FDA came to visit (live) for their Covid vaccine trials.

    It is important to remember that this initial use of these vaccines will be under a EUA (Emergency use authorization).  That means it is likely that not all aspects of analysis of the data across all demographics.  This will come later as they complete the studies and file for full approval under a BLA.  The EUA will be based on a public health need, interim data and a high expectation of efficacy across groups based o extrapolation of these data.  That's why it is an EUA, and not a full approval.

    The Advisory committee meetings coming up will be discussing the extent of the data and what is known at this point about different demographics, etc.  The hearings are public and live on internet and likely C-SPAN, so tune in if you want to know what they actually know.  Experts have already cautioned that they don't really know about efficacy in younger persons, and certain high-risk groups.  Also, none of the current studies include pediatric patients.  they are now starting separate studies to specifically address pediatrics.

    ------------------------------
    Michael Hamrell, Ph.D., RAC, FRAPS
    Huntington Beach CA
    United States
    ------------------------------



  • 34.  RE: Covid 19 Vaccine

    Posted 04-Dec-2020 11:53
    "it is likely that not all aspects of analysis of the data across all demographics"

    I think you may have dropped a word or two here?  Regardless, the 90-ish% efficacy has been calculated "across all demographics," and is not an estimate of efficacy for any one of the demographic groups represented in the "diverse" trial.. 

    Demographic-specific efficacy rates can be calculated (unless there were no cases of COVID-19 in the demographic), but they would be based on smaller...in some cases, much smaller...sample sizes than the overall efficacy rate.  The most robust split is by gender, which would reduce sample size by half.  When you start looking at a combination of gender/age/race, the sample sizes get much smaller.

    Again, whether this matters depends on whether the vaccine is more or less efficacious for some demographic groups than others.  This trial will not answer that question.  That question will not be answered until the vaccine is widely used in specific demographics, so basically, more human subjects research, but not in a clinical trial.  Apparently healthcare workers and nursing home residents are most likely to have the dubious honor.


    ------------------------------
    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Mebane, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com
    ------------------------------



  • 35.  RE: Covid 19 Vaccine

    Posted 04-Dec-2020 10:56
    As has been stated by others, there is FDA guidance on Emergency Use Authorizations that manufacturers need to follow
    https://www.fda.gov/regulatory-information/search-fda-guidance-documents/emergency-use-authorization-medical-products-and-related-authorities
    There is also a Guidance on licensure of Pandemic vaccines but this is specific for Influenza, so may only be partially applicable
    https://www.fda.gov/regulatory-information/search-fda-guidance-documents/clinical-data-needed-support-licensure-pandemic-influenza-vaccines
    Basically, in the event of a declared emergency, the vaccine must show evidence of efficacy and pass a risk-benefit evaluation. This is what will be discussed in the VRBPAC meeting next Thursday. The vaccine will only be approved if it is first recommended by VRBPAC
    https://www.fda.gov/advisory-committees/vaccines-and-related-biological-products-advisory-committee/2020-meeting-materials-vaccines-and-related-biological-products-advisory-committee



    ------------------------------
    Sam Simons
    Director, Regulatory Affairs
    Westerly RI
    United States
    ------------------------------



  • 36.  RE: Covid 19 Vaccine

    Posted 04-Dec-2020 11:53
    As opposed to what other purposes?

    ------------------------------
    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Mebane, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com
    ------------------------------



  • 37.  RE: Covid 19 Vaccine

    Posted 04-Dec-2020 13:17
    Personally, I think this vaccine is being rushed and clearly doesn't have enough data to support it's safety. I understand people are dying and millions of families are being affected by this illness, but I think many ARs will come from this vaccine and not just mild ones. What I think is going to happen is this vaccine will be distributed on a mass global scale and will end up being recalled.

    ------------------------------
    Lance Tovar
    RA/QA Specialist
    Roy UT
    United States
    ------------------------------



  • 38.  RE: Covid 19 Vaccine

    Posted 04-Dec-2020 14:41
    I'm not concerned about efficacy. I'm a bit concerned about the long-term safety of the mRNA vaccines given that they're a new vaccine technology and I really don't know how much preclinical work had been done in this area before the pandemic. If they didn't start until last March or even last December, I don't think they've had enough time to get the same amount of data we have with the other technologies. But also, I would think any new safety concerns due to the mRNA would be a longer term issue that we wouldn't get within the "normal" clinical development time frame either. My biggest concern is around Quality. Not because I don't think they are following GMPs but b/c they have not had time to do all the development and validation work that is normally done and I don't believe they really understand their product or process. For example, how much data do they actually have to set specs? If the Agencies (particularly Europeans) applied their usual standards for "clinical justification", I would imagine the specs would be quite tight due to limited data, which poses less risk for patients but a higher probability of failures leading to supply issues. If the Agencies are being more flexible and allowing slightly wider specs, then there's higher risk to the patient. And the key point is that since Quality information is always considered proprietary, and everyone only ever talks about the clinical data, we're not going to know which approach was taken.

    So on a personal level, I don't know yet whether I'll be lining up to receive the vaccine or, more to the point, recommending to my parents that they take it, given that we've done fairly well just staying home most of the time, avoiding personal contact as much as possible, and wearing masks when we go out.

    3mos ago I said no way in hell would I get a vaccine under an EUA. FDA's transparency on their expectations for issuing an EUA in this case has reduced my overall concern such that I no longer feel that strongly, but I still have concerns for myself and my family based on our individual risk/benefit situations.

    ------------------------------
    Rachel Thornton
    Associate Director
    Smyrna GA
    United States
    ------------------------------



  • 39.  RE: Covid 19 Vaccine

    Posted 04-Dec-2020 15:25
    Edited by Julie Omohundro 04-Dec-2020 15:26
    I gather by "expectations" you mean its guidances.  As they say, they are "just" guidances, especially from FDA's perspective.  It's not like FDA has a long and unblemished track record for diligently following its own regulations, much less its guidances.  A lot seems to hinge on what it thinks will bring out the lawyers and what it thinks the lawyers will overlook.

    As always, show me the data, not the guidances.  FDA has posted an impressive amount of information about the Ebola vaccine that it approved last December.  But since this won't be an approval, I'm not sure if we can expect the same level of transparency.  Even so, I personally won't be satisfied without seeing everything I would want to see as the company's RA, including source documents and lot records.

    I support those who want the vaccine to go expanded access instead of EUA, and those who would like the data made available for review by the scientific and medical community before a decision is made.  Above all, I support Jesse Goodman's position on the need for informed consent for EUA products.

    https://oversight.house.gov/sites/democrats.oversight.house.gov/files/Goodman%20-%20Statement%20%26%20Article%20%28combined%29.pdf

    ------------------------------
    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Mebane, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com
    ------------------------------



  • 40.  RE: Covid 19 Vaccine

    Posted 05-Dec-2020 06:56

    I have many responses and thoughts to this thread, but I'll post those I believe to be most constructive:

    • For those would would like to 'see the data' I would highly recommend loading and refreshing the applicable VRBPAC page on the FDA website, as the briefing materials will be posted not less than 2 days prior to the respective committee meeting. So, for the Pfizer/BioNTech vaccine, that means Tuesday. As FDA has committed to a high level of transparency for this process, I would expect a large amount of information to be posted, likely looking similar to a traditional FDA review package. As others have also mentioned, the committee meeting itself will be broadcast live on various platforms; links are included on the same page.
    • The discussion here has focused on the Ph3 efficacy trials which were initiated over the summer (late July for the earliest starts: Pfizer/BioNTech and Moderna), however sponsors continue following up on the earlier Ph1/2 studies that include specific subgroups. In fact, NIAID just posted 3 month data from Moderna's vaccine. While this is not the same duration data as would be obtained at this stage during a typical development timeline, it is something additional (plus, I'll note that journals continue to make these article freely accessible to the public, so everyone can read them).
    • I'll remind everyone that all types of drug/biologic approvals include some risks; while the approval standards may differ between 'regular' approval, accelerated, EUA, etc., the sponsor and consequently FDA are performing a benefit/risk assessment in every situation, and virtually no drug is either 100% effective and/or 100% safe. This is codified in the statute (21 U.S.C. §355(d)), specifically: "The Secretary shall implement a structured risk-benefit assessment framework in the new drug approval process to facilitate the balanced consideration of benefits and risks, a consistent and systematic approach to the discussion and regulatory decisionmaking, and the communication of the benefits and risks of new drugs."
    • As others have also mentioned, individuals are still able to make their own decisions in consultation with their healthcare providers. I'll note that many of us are fortunate enough to be able to work remotely and follow social distancing guidelines rather easily given the nature of our work, and many of us will be in later waves of the vaccination priority list. And, we also have the benefit of understanding the scientific and regulatory processes in play here. While there have been missteps along the way by various actors, I am personally confident in where we are at now and trust the FDA, CDC, and the scientific experts therein to make informed decisions based on the data. Meanwhile, I appreciate everyone who has done and continues to do their part to help human kind move forward while minimizing morbidity and mortality as much as possible.


    ------------------------------
    Jonathan Amaya-Hodges
    Associate Director, Regulatory Affairs CMC Combination Products and Medical Devices
    Cambridge MA
    United States
    ------------------------------



  • 41.  RE: Covid 19 Vaccine

    Posted 05-Dec-2020 11:10
    Edited by Julie Omohundro 05-Dec-2020 11:27
    From the Federal Register meeting notice:
    If FDA is unable to post the background material on its website prior to the meeting, background material will be made publicly available on FDA's website at the time of the advisory committee meeting.

    I will be interested to see what is posted, but of course FDA won't post the data, any more than NIAID has posted the data for Moderna's vaccine. Those are just the results of somebody crunching a bunch of numbers, based on however they decided to crunch them.  Crunch a different way, get a different result.

    Even if the data were accessible, without concurrent access to the source documents for verification, plus all the records needed to verify the test article(s) used in testing and clinical trials, those numbers are not data from any meaningful scientific perspective. They are "data" to the digital crowd, but to scientists (and to RA), they are just numbers in a database.  It's what FDA means when it says RWD is not RWE.

    Once you get past verifying all the data, there is the question of whether what is finally delivered to a patient's arm is actually supported by those data, or whether any number of Unfortunate Things might well have happened along the way, as many RA and QA professionals know only too well, so that it is something else instead.

    The other issues being raised by the research statisticians revolve, as always, around the potential damage done to the validity of the longer term data by the "early peek," and also the impact on future trials.  There seems to be a scenario in which the early vaccines crash and burn (made more likely by their development at warped speed), and then we are basically screwed, with no place left to go but herd immunity via infection.

    I think the only people who can reasonably "trust" anything at this point are those who think the whole pandemic is a scam, and therefore the vaccine doesn't really matter, except as something to be rolled out as justification to re-open.  I often speak in terms of "the political vaccine" and "the medical vaccine."

    As for people being "free" to make their own decisions, I watch with interest to see how many of those who vowed all summer that they would give up their jobs before getting vaccinated will actually follow through.  Many were healthcare workers. I'm not sure that's as tough a choice as it might sound at first blush. It's not like people weren't leaving healthcare at steady rate before the pandemic came along.  Similar situation with teachers, perhaps.  But the ratio of talk to walk is pretty low in our society.

    Trust is an abdication of the responsibility to verify, the byword of the con artist and the snake oil salesman, the antithesis of RA, QA, and risk management.

    ------------------------------
    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Mebane, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com
    ------------------------------



  • 42.  RE: Covid 19 Vaccine

    Posted 07-Dec-2020 10:41
    Julie- It sounds to me that you don't trust the FDA (or MHRA or EMA, etc.) reviewers to make an appropriate scientific assessment of the raw data. So do you never take medicine or get vaccinated? Because you personally will never have access to the raw data. If the answer to my question is 'no', then what makes this situation different?

    ------------------------------
    Rachel Thornton
    Associate Director
    Smyrna GA
    United States
    ------------------------------



  • 43.  RE: Covid 19 Vaccine

    Posted 07-Dec-2020 21:25

    As I said previously, trust is antithetical to RA, QA, risk management.  Especially risk management, I think.  Trust seems to be what people do as an alternative to risk management, which requires a tolerance for uncertainty.  Reagan's "trust but verify" has a nice oratorical ring to it, but if you verify, then of course trust becomes irrelevant.  If you can't verify, and you can tolerate uncertainty, you accept that you simply don't know, and trust again becomes irrelevant.  Those who can't tolerate that uncertainty, trust, which to me has an air of denial and blind faith about it, closer to religion than science.

    As I also said previously, it's been a long pandemic. A leap from "Don't trust FDA reviewers" to "Never take medicine or get vaccinated," seems like a depressingly long way from the nuanced mindset of "it depends."  I'm tired, so I'll leave those who make that kind of leap to remain planted where they landed.

    As for how our current situation is different from "old normal"...Really?



    ------------------------------
    Julie Omohundro, ex-RAC (US, GS), still an MBA
    Principal Consultant
    Class Three, LLC
    Mebane, North Carolina, USA
    919-544-3366 (T)
    434-964-1614 (C)
    julie@class3devices.com
    ------------------------------



  • 44.  RE: Covid 19 Vaccine

    Posted 08-Dec-2020 09:45
    For the record, the briefing materials for the 10 Dec VRBPAC meeting were posted this morning, on time according to the FR Notice. FDA's briefing document checks in at 53 pages and is supportive of granting an EUA and includes their own statistical analyses breaking down many patient subsets for both safety and efficacy. The sponsor's briefing document is 93 pages and includes similar analysis.

    ------------------------------
    Jonathan Amaya-Hodges
    Associate Director, Regulatory Affairs CMC Combination Products and Medical Devices
    Cambridge MA
    United States
    ------------------------------