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.
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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------------------------------
Original Message:
Sent: 05-Dec-2020 06:55
From: Jonathan Amaya-Hodges
Subject: Covid 19 Vaccine
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.
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Jonathan Amaya-Hodges
Associate Director, Regulatory Affairs CMC Combination Products and Medical Devices
Cambridge MA
United States
Original Message:
Sent: 04-Dec-2020 15:24
From: Julie Omohundro
Subject: Covid 19 Vaccine
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
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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
Original Message:
Sent: 04-Dec-2020 14:40
From: Rachel Thornton
Subject: Covid 19 Vaccine
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.
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Rachel Thornton
Associate Director
Smyrna GA
United States
Original Message:
Sent: 01-Dec-2020 14:22
From: Lance Tovar
Subject: Covid 19 Vaccine
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?
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Lance Tovar
RA/QA Specialist
Roy UT
United States
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