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Which risks did regulators probe for approved vaccines?

From the FDA and EMA reviews of all 13 approved vaccines. Each answer links to the regulator's own sentence.

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Short answer
What reviewers probed for each of the 13 approved vaccines.

Precedent by precedent

13 approved vaccines, with the reviewers' own words.

Arexvy

respiratory syncytial virus vaccine, adjuvanted (AS01E) · RSV preF3; TLR4 (AS01E adjuvant)
Immune & cytokine safety
In mice, AS01-adjuvanted RSVPreF3 induced CD4+/CD8+ T cells, neutralising antibodies and proinflammatory cytokines
“In combination with especially AS01B, RSVPreF3 induced F-specific CD4+ and CD8+ T cell responses and RSV-specific neutralising antibody titres after the second and third vaccination and induced proinflammatory cytokines as measured after the first and second vaccination.”
✓ VerifiedEMA assessment report, p. 30Source ↗
Biodistribution & persistence
No PK/ADME or new biodistribution studies; AS01 not a novel adjuvant (registered in Shingrix)
“No dedicated PK or ADME studies for RSVPreF3 OA are performed. This is endorsed. The adjuvant system AS01 is not a novel adjuvant, since several products using the adjuvant system have already been registered (a.o., Shingrix, using AS01B).”
✓ VerifiedEMA assessment report, p. 31Source ↗

Cervarix

human papillomavirus bivalent (types 16, 18) vaccine, recombinant, AS04-adjuvanted · HPV 16/18 L1 VLPs; TLR4 (AS04 adjuvant)
Immune & cytokine safety
No neurological, immunological or autoimmune adverse reactions in MPL-containing preclinical studies (FDA concurred)
“GSK’s 3rd table in their response lists the preclinical studies conducted with vaccine formulations containing MPL. GSK concluded that none of these studies show evidence of adverse neurological, immunological or autoimmune-based (AID) reactions.”
✓ VerifiedFDA toxicology review, p. 40Source ↗
Biodistribution & persistence
Radiolabelled MPL in rat widely distributed (fat, spleen), likely eliminated via expired air; no vaccine ADME
“In conclusion the pharmacokinetic studies conducted in rats have shown that MPL-related material is widely distributed throughout the body, notably to the fat and spleen, and is then likely eliminated mainly via the expired air, with only low levels of radioactivity remaining in the carcass.”
✓ VerifiedEMA assessment report, p. 11Source ↗

Cyfendus

anthrax vaccine adsorbed, adjuvanted · B. anthracis PA; TLR9 (CpG 7909 adjuvant)
Immune & cytokine safety
Transient neutrophil, monocyte, basophil and inflammatory-marker increases; spleen weight increase and lymphoid hyperplasia
“Systemically, treated animals showed a transient increase in neutrophil, monocyte and basophil counts, as well as inflammatory markers. Additionally, increases in spleen weights, and hyperplasia in lymphoid tissues of the spleen and draining lymph nodes were observed.”
✓ VerifiedFDA toxicology review, p. 4Source ↗
Biodistribution & persistence
Not stated in public reviews

Fendrix

hepatitis B vaccine (rDNA), AS04C-adjuvanted · HBsAg VLPs; TLR4 (AS04C adjuvant)
Immune & cytokine safety
Anti-HBs seroconversion in rabbits; rat dams and offspring exposed to high anti-HBs titres
“Furthermore, rat dams and offspring were shown to be exposed to high titres of circulating anti-HBs antibodies during the reproductive toxicity study.”
✓ VerifiedEMA assessment report, p. 9Source ↗
Biodistribution & persistence
No distribution or excretion data for vaccine or AS04C; assumed to follow unadsorbed aluminium particle disposition
“Neither distribution nor excretion data are available for the final HB-AS04C vaccine or the AS04C adjuvant. However, the applicant assumes that aluminium salt particles containing adsorbed materials follow the same distribution and elimination as for unadsorbed aluminium particles.”
✓ VerifiedEMA assessment report, p. 9Source ↗

Gardasil

human papillomavirus quadrivalent (types 6, 11, 16, 18) vaccine, recombinant · HPV 6/11/16/18 L1 VLPs
Immune & cytokine safety
Theoretical autoimmunity from cross-reactive antibodies, not readily studied in animals; left to clinical assessment
“Theoretically, the vaccine could give rise to antibodies, which cross-react to self-structures, resulting in autoimmune events. Such possibility is not readily studied in experimental animal models, but can only be studied in the clinical situation.”
✓ VerifiedEMA assessment report, p. 37Source ↗
Biodistribution & persistence
ADME studies not performed (vaccine guidance)
“Experimental studies to demonstrate absorption, distribution, metabolism, and excretion of the active ingredients in Gardasil have not been performed for any of the component viruses. This is in line with Note for guidance on preclinical pharmacological and toxicological testing of vaccines (CPMP/SWP/465/95).”
✓ VerifiedEMA assessment report, p. 8Source ↗

Gardasil 9

human papillomavirus 9-valent vaccine, recombinant · HPV 9-valent L1 VLPs
Immune & cytokine safety
Transient spleen weight increase from immune stimulation; theoretical autoimmunity risk left to post-marketing
“The increase in splenic weights was considered an expected secondary effect to the stimulation of the immune system by vaccination and was converted to normal range following a 21-day recovery. Theoretically, immune stimulation holds a risk of causing/exacerbating autoimmune diseases, but such a risk can only be characterized in post-marketing settings.”
✓ VerifiedEMA assessment report, p. 25Source ↗
Biodistribution & persistence
No ADME studies (vaccine guidance; acceptable)
“No studies on absorption, distribution, metabolism or excretion were performed. This is in line with the CHMP Note for Guidance on Preclinical Pharmacological and Toxicological Testing of Vaccines and is therefore acceptable.”
✓ VerifiedEMA assessment report, p. 24Source ↗

HBVaxPro

hepatitis B vaccine (rDNA) · HBsAg VLPs
Immune & cytokine safety
No autoimmune reactions, kidney or vascular lesions, or immune complex deposition in the rat repeat-dose study
“Based on the design of this repeated dose toxicology study, no immuno-toxicological findings such as autoimmune reactions were observed. It is noted that this animal study revealed no kidney or vascular lesions justifying further examinations or indicating potential immune complex deposition.”
✓ VerifiedEMA assessment report, p. 4Source ↗
Biodistribution & persistence
Not stated in public reviews

Heplisav-B

hepatitis B vaccine (recombinant), adjuvanted · HBsAg; TLR9 (CpG 1018 adjuvant)
Immune & cytokine safety
Serum IL-12p40 rose only 2-fold at ~20x the human CpG 1018 dose; no IL-12p40 or IFN-gamma increase at the 1x human dose
“The 300 mcg 1018 ISS + HBsAg dose (approximately 20 times the human dose) induced only a 2-fold increase in IL-12p40 levels over baseline, and the 15 mcg 1018 ISS + HBsAg dose (a 1 X human dose) did not induce an increase in either IL-12p40 or IFN-g levels after the first or last injection.”
✓ VerifiedFDA toxicology review, p. 40Source ↗
Biodistribution & persistence
Rapid plasma decline; PS-ODN binds plasma proteins (95%) and distributes to kidney (up to 20% of dose), liver and spleen
“According to published data the rapid decline is due to initial low affinity binding to plasma proteins (95%) and to significant distribution to kidney (up to 20 % of the dose), liver, and to a minor extent spleen.”
✓ VerifiedEMA assessment report, p. 25Source ↗

Mosquirix

RTS,S/AS01 malaria vaccine · P. falciparum CSP-HBsAg (RTS,S) VLPs; TLR4 (AS01 adjuvant)
Immune & cytokine safety
Transient neutrophil and fibrinogen increases after dosing, back to pre-dose levels within three days
“The neutrophil counts and fibrinogen concentrations showed evidence of a return to levels similar to those recorded before treatment commenced within three days after dosing.”
✓ VerifiedEMA assessment report, p. 50Source ↗
Biodistribution & persistence
Adjuvant only: QS-21 eliminated almost exclusively in urine (>99% by 72 h) in mice; antigen PK not studied
“[14C]-QS-21 was almost exclusively eliminated via urinary excretion with >99 % of the injected dose recovered in urine by 72 h after dosing.”
✓ VerifiedEMA assessment report, p. 47Source ↗

Nuvaxovid

COVID-19 vaccine, recombinant spike protein nanoparticle, Matrix-M-adjuvanted · SARS-CoV-2 spike (nanoparticle)
Immune & cytokine safety
Matrix-M1: injection-site inflammation, reversible draining lymph node enlargement, raised CRP, fibrinogen and globulin (immune stimulation)
“The findings were considered consistent with immune system stimulation consequent to administration of an active adjuvant, and comprised: local injection site inflammation, reversible enlargement of the lymph nodes draining the injection sites (but not elsewhere), and chemical markers of inflammation (i.e., CRP, fibrinogen, and globulin).”
✓ VerifiedEMA assessment report, p. 51Source ↗
Biodistribution & persistence
No biodistribution data at approval; mouse biodistribution study of Matrix-M1 adjuvant planned
“As the Matrix-M1 adjuvant is not currently marketed in a human vaccine in the EU market, Novavax is planning to conduct a biodistribution study in mice to evaluate the Matrix-M1 adjuvant, which may be of value in further understanding the mode of action of the adjuvant.”
✓ VerifiedEMA assessment report, p. 53Source ↗

PreHevbrio

hepatitis B vaccine (recombinant), 3-antigen · HBsAg S/pre-S1/pre-S2 VLPs
Immune & cytokine safety
Slight lymphoid hyperplasia in spleen and lymph nodes, an expected immunostimulatory effect
“There were no vaccine-related adverse gross or microscopic pathologic findings observed at terminal necropsy other than isolated incidence of slight discrete lymphoid hyperplasia in the spleens and lymph nodes of the vaccine treated rats, which represented an expected immunostimulatory property of the vaccine.”
✓ VerifiedEMA assessment report, p. 25Source ↗
Biodistribution & persistence
No pharmacokinetic studies; accepted by CHMP
“Pharmacokinetic studies were not performed with PreHevbri. This was considered acceptable by the CHMP.”
✓ VerifiedEMA assessment report, p. 24Source ↗

Shingrix

zoster vaccine recombinant, AS01B-adjuvanted · VZV glycoprotein E; TLR4 (AS01B adjuvant)
Immune & cytokine safety
Acute-phase response (CRP rise) indicating systemic inflammation, possibly linked to malaise, fatigue and nausea
“These changes in CRP levels reflect an activation of the acute-phase response and indicate increasing levels of systemic inflammation, which potentially may be correlated with clinical adverse events such as malaise, fatigue, and nausea.”
✓ VerifiedFDA summary basis for approval, p. 14Source ↗
Biodistribution & persistence
Adjuvant biodistribution only: QS-21 and MPL widely distributed, eliminated within 48-168 h
“Taken together, the biodistribution studies with QS-21 and MPL administered in solution have shown that QS-21 and MPL are widely distributed throughout the body and are eliminated within several hours (48-168 h).”
✓ VerifiedEMA assessment report, p. 31Source ↗

Flublok

influenza vaccine, recombinant hemagglutinin · Influenza HA
Immune & cytokine safety
Not stated in public reviews
Biodistribution & persistence
Not conducted; pharmacokinetic studies not required for vaccines
“In accordance with current guidelines, pharmacokinetic studies are not required for the vaccine assessment. No non-clinical pharmacokinetic studies have been performed to evaluate absorption, distribution, metabolism and excretion of the active ingredients of RIV4.”
✓ VerifiedEMA assessment report, p. 27Source ↗