Nonclinical precedent Request an invite

What safety margins were accepted for approved vaccines?

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

Check my plan against these
Short answer
7 of 13 reviews state the margin; median 50× human exposure at the NOAEL.
Infectious disease: median 50× (10×–1450×)7/13
Not stated in public reviews6/13
0.3×1×3×10×30×100×300×1000×
Infectious disease

Multiple of human exposure at the recommended dose, at the pivotal NOAEL (HNSTD for oncology), as stated by the regulator. Left of 1× = below human exposure; reviews that say "below human exposure" without a number sit at <1×.

Precedent by precedent

13 approved vaccines, with the reviewers' own words.

Heplisav-B

hepatitis B vaccine (recombinant), adjuvanted · HBsAg; TLR9 (CpG 1018 adjuvant)
Safety margin at NOAEL
Monkey NOAEL 0.5 mg/kg CpG adjuvant, >10-fold the clinical mg/kg dose, for systemic immunostimulation
“It should be noted that other systemic manifestations of TLR9 immunostimulation were seen in monkeys (i.e. spleen hyperplasia from 2.5 mg/kg/w and lymph node hyperplasia and liver inflammation at 12.5 mg/kg/w). Of importance, a NOAEL of 0.5 mg/kg 1018 ISS (>10-fold the clinical dose on mg/kg basis) for systemic immunostimulatory effects was identified in this study.”
✓ VerifiedEMA assessment report, p. 28Source ↗
NOAEL / key findings
Monkey NOAEL 0.5 mg/kg CpG 1018 (>10-fold clinical) for systemic immunostimulation; spleen and lymph node hyperplasia, liver inflammation at higher doses
“It should be noted that other systemic manifestations of TLR9 immunostimulation were seen in monkeys (i.e. spleen hyperplasia from 2.5 mg/kg/w and lymph node hyperplasia and liver inflammation at 12.5 mg/kg/w). Of importance, a NOAEL of 0.5 mg/kg 1018 ISS (>10-fold the clinical dose on mg/kg basis) for systemic immunostimulatory effects was identified in this study.”
✓ VerifiedEMA assessment report, p. 28Source ↗

Arexvy

respiratory syncytial virus vaccine, adjuvanted (AS01E) · RSV preF3; TLR4 (AS01E adjuvant)
Safety margin at NOAEL
Rabbit developmental toxicity study: full antigen dose ≈20x the human dose by body weight (3 kg rabbit, 60 kg human)
“a This dose was expected to give an approximate 20X dose multiple assuming a 3kg average rabbit weight and a 60 kg average human weight.”
✓ VerifiedFDA pharmacology/toxicology review, p. 127Source ↗
NOAEL / key findings
No NOAEL set; immune-stimulation findings in rabbits: WBC/neutrophil changes, lower albumin, larger iliac/popliteal lymph nodes, raised CRP and fibrinogen
“The vaccine resulted in effects on clinical pathology parameters and histopathology that are consistent with immune stimulation following administration of a vaccine, amongst others changes in white blood cell and absolute neutrophil counts, minimally to mildly decreased albumin, increased lymph node weights (ileac and popliteal), CRP and fibrinogen.”
✓ VerifiedEMA assessment report, p. 32Source ↗

Nuvaxovid

COVID-19 vaccine, recombinant spike protein nanoparticle, Matrix-M-adjuvanted · SARS-CoV-2 spike (nanoparticle)
Safety margin at NOAEL
Rat DART study: dose exceeds the human dose 40-fold on a weight-adjusted basis
“The administered dose was the maximum volume of clinical formulation (used for the early clinical studies) and, although the dose is smaller than the absolute dose that will be administered to humans, it does exceed the human dosage on a weight-adjusted basis by 40-fold.”
✓ VerifiedEMA assessment report, p. 54Source ↗
NOAEL / key findings
No NOAEL stated; transient CRP and fibrinogen elevations and injection-site inflammation in rabbits, as expected for a vaccine
“Transient elevations of C-reactive protein (CRP) and fibrinogen and local inflammation reactions were observed at the injection sites, indicative of acute reactions as expected.”
✓ VerifiedFDA summary basis for approval, p. 17Source ↗

Cervarix

human papillomavirus bivalent (types 16, 18) vaccine, recombinant, AS04-adjuvanted · HPV 16/18 L1 VLPs; TLR4 (AS04 adjuvant)
Safety margin at NOAEL
No adverse systemic effects at dosages up to more than 50-fold the human dose (body weight basis)
“No other vaccine- or adjuvant-associated adverse systemic effect was noted, even though the studied dosages exceeded the human dosage (up to more than 50-fold factor on a body weight basis), as well as the immunization schedule.”
✓ VerifiedFDA toxicology review, p. 10Source ↗
NOAEL / key findings
No NOAEL stated; vaccine and AS04 well tolerated with no consistent systemic findings in rabbits
“The HPV-16 /18 L1 VLP AS04 vaccine and the AS04 adjuvant were well tolerated. The organ-weight data, macroscopic pathology evaluation, and evaluation of systemic effects showed no consistent treatment-related findings.”
✓ VerifiedEMA assessment report, p. 11Source ↗

Fendrix

hepatitis B vaccine (rDNA), AS04C-adjuvanted · HBsAg VLPs; TLR4 (AS04C adjuvant)
Safety margin at NOAEL
Safety pharmacology only: no cardiorespiratory effects up to 63-fold the human dose (bodyweight basis); no repeat-dose margin stated
“A safety pharmacology study did not show any effect on respiratory or cardiovascular parameters when the HBsAg was administered intravenously or when the HB-AS04C vaccine was given intramuscularly, up to a 63-fold of the human dose expressed on a bodyweight basis.”
✓ VerifiedEMA assessment report, p. 9Source ↗
NOAEL / key findings
No NOAEL stated; minor dose-related immunostimulatory effects with MPL; minor reversible injection-site inflammation in rabbit
“The effects seen were minor and consistent with an immunostimulatory action. The minor effects seen were dose-related.”
✓ VerifiedEMA assessment report, p. 9Source ↗

Gardasil 9

human papillomavirus 9-valent vaccine, recombinant · HPV 9-valent L1 VLPs
Safety margin at NOAEL
Rat reproduction studies: up to 240 and 160 times the human dose (mg/kg) without fertility or fetal effects
“Reproduction studies have been performed in rats at doses up to 240 and 160 times the human dose on mg/kg basis and revealed no evidence of impaired fertility or harm to the fetus due to V503 vaccine.”
✓ VerifiedFDA pharmacology/toxicology review, p. 43Source ↗
NOAEL / key findings
No NOAEL stated; only immune-response and injection-site effects in rats
“The only treatment-related effects were indicative of the immune response and injection site reactions.”
✓ VerifiedEMA assessment report, p. 24Source ↗

Gardasil

human papillomavirus quadrivalent (types 6, 11, 16, 18) vaccine, recombinant · HPV 6/11/16/18 L1 VLPs
Safety margin at NOAEL
Mouse repeat-dose: ~1450-fold the projected human dose on a body weight basis
“On a body weight basis, the dose of the vaccine administered to mice was approximately 1450-fold the projected human dose.”
✓ VerifiedEMA assessment report, p. 8Source ↗
NOAEL / key findings
No systemic toxicity; iliac lymph node enlargement/hyperplasia and injection-site inflammation in mice
“There was a treatment-related enlargement of the iliac lymph nodes. Treatment-related microscopic changes were noted in lymph nodes (hyperplasia) and in the muscle at the injection sites (inflammation).”
✓ VerifiedEMA assessment report, p. 8Source ↗

Cyfendus

anthrax vaccine adsorbed, adjuvanted · B. anthracis PA; TLR9 (CpG 7909 adjuvant)
Safety margin at NOAEL
Not stated in public reviews
NOAEL / key findings
Injection-site necrosis and granulomatous inflammation judged adverse but expected to resolve
“The necrosis and granulomatous inflammation at the injection sites were considered adverse reactions and were expected to resolve over time.”
✓ VerifiedFDA summary basis for approval, p. 16Source ↗

Flublok

influenza vaccine, recombinant hemagglutinin · Influenza HA
Safety margin at NOAEL
Not stated in public reviews
NOAEL / key findings
No NOAEL stated; no systemic toxicity in rats, only transient injection-site microscopic changes
“There were no local reactions and no signs of systemic toxicity including clinical pathology parameters, organ weights and macroscopic findings. The main related findings were transient microscopic changes at the injection sites, which is expected.”
✓ VerifiedEMA assessment report, p. 29Source ↗

HBVaxPro

hepatitis B vaccine (rDNA) · HBsAg VLPs
Safety margin at NOAEL
Not stated in public reviews
NOAEL / key findings
No toxicologically significant findings in rat; changes attributed to the vaccine properties of test and reference vaccines
“revealed changes attributed to the vaccine properties of the reference and tested vaccines. None of these findings had a toxicological significance.”
✓ VerifiedEMA assessment report, p. 4Source ↗

Mosquirix

RTS,S/AS01 malaria vaccine · P. falciparum CSP-HBsAg (RTS,S) VLPs; TLR4 (AS01 adjuvant)
Safety margin at NOAEL
Rabbit study used RTS,S/AS01B with twice the antigen and adjuvant content of Mosquirix; no numeric margin stated
“The tested RTS,S/AS01B formulation consists of 50 μg of RTS,S antigen combined with AS01B containing 50 μg of MPL and 50 μg of QS-21 in liposomes and therefore contains twice the amounts of these constituents than the RTS,S/AS01E (Mosquirix) candidate vaccine.”
✓ VerifiedEMA assessment report, p. 58Source ↗
NOAEL / key findings
No NOAEL stated; dose-related acute injection-site inflammation, fully recovered 28 days after last dose; no systemic toxicity
“In conclusion, intramuscular administration of RTS,S/AS01B on four occasions at 2-week intervals triggered an acute inflammatory response at injection sites that increased with the vaccine dose and volume administered. Nonetheless, full recovery was observed 28 days after the last administration.”
✓ VerifiedEMA assessment report, p. 51Source ↗

PreHevbrio

hepatitis B vaccine (recombinant), 3-antigen · HBsAg S/pre-S1/pre-S2 VLPs
Safety margin at NOAEL
DART: rats given a dose equivalent to the adult human dose; no numeric multiple stated
“Developmental toxicity study has been performed in female rats at a dose equivalent to the adult human dose.”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗
NOAEL / key findings
No NOAEL stated; injection-site reactions and expected lymphoid hyperplasia only, no other systemic effects
“Based on the limited data submitted, the vaccine caused typical location reactions at the injection sites but did not cause any systemic effects other than the expected lymphoid hyperplasia.”
✓ VerifiedFDA summary basis for approval, p. 12Source ↗

Shingrix

zoster vaccine recombinant, AS01B-adjuvanted · VZV glycoprotein E; TLR4 (AS01B adjuvant)
Safety margin at NOAEL
Full human dose given to rabbits, with more doses than clinically; no numeric multiple stated
“Repeated dose toxicity has thus been evaluated in one relevant animal species (rabbits) and the studies have been conducted according to the relevant WHO and EMA guidelines, including recommendations on dose (full human dose), number of doses (exceeding proposed number in the clinic) and of route of administration (IM is proposed route of administration for licensure).”
✓ VerifiedEMA assessment report, p. 32Source ↗
NOAEL / key findings
No vaccine NOAEL stated; rabbit CRP up to 9-fold (males) and 5-fold (females), transient
“A transient but statistically significant increase in C-Reactive Protein (CRP) levels was observed in rabbits receiving SHINGRIX with levels up to 9 times (male animals) and 5 times (female animals) higher compared to control animals.”
✓ VerifiedFDA summary basis for approval, p. 14Source ↗