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Which nonclinical studies did approved vaccines skip?

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
11 of 13 skipped carcinogenicity; 8 of 13 skipped genotoxicity.
No genotoxicity studies8/13
No carcinogenicity study11/13
No dedicated repro tox2/13

Precedent by precedent

13 approved vaccines, with the reviewers' own words.

Arexvy

respiratory syncytial virus vaccine, adjuvanted (AS01E) · RSV preF3; TLR4 (AS01E adjuvant)
Genotoxicity
Not conducted for the vaccine (not required for vaccines)
“The absence of genotoxicity studies is accepted. This is not required for vaccines.”
✓ VerifiedEMA assessment report, p. 32Source ↗
Carcinogenicity
Not conducted (not required for vaccines)
“The absence of carcinogenicity studies is accepted and not required for vaccines.”
✓ VerifiedEMA assessment report, p. 32Source ↗
Instead of carcinogenicity
Not stated in public reviews

Cervarix

human papillomavirus bivalent (types 16, 18) vaccine, recombinant, AS04-adjuvanted · HPV 16/18 L1 VLPs; TLR4 (AS04 adjuvant)
Genotoxicity
Vaccine not tested; MPL adjuvant negative in Ames, CHO clastogenicity and in vivo micronucleus
“The in vitro mutagenicity (Ames) and clastogenicity (CHO cells) tests, and in vivo micronucleus assay demonstrated no genotoxic potential of the MPL adjuvant.”
✓ VerifiedEMA assessment report, p. 12Source ↗
Carcinogenicity
Not conducted; accepted as the vaccine is L1 protein without HPV oncoproteins
“The mutagenic and carcinogenic potential of the Cervarix vaccine was not further evaluated, which is accepted since the vaccine is based on L1 protein and HPV oncoproteins are absent.”
✓ VerifiedEMA assessment report, p. 53Source ↗
Instead of carcinogenicity
Not stated in public reviews

Cyfendus

anthrax vaccine adsorbed, adjuvanted · B. anthracis PA; TLR9 (CpG 7909 adjuvant)
Genotoxicity
Not conducted
“CYFENDUS has not been evaluated for carcinogenicity, mutagenic potential, or male infertility in animals.”
✓ VerifiedUS package insert, p. 9Source ↗
Carcinogenicity
Not conducted
“CYFENDUS has not been evaluated for carcinogenicity, mutagenic potential, or male infertility in animals.”
✓ VerifiedUS package insert, p. 9Source ↗
Instead of carcinogenicity
Not stated in public reviews

Fendrix

hepatitis B vaccine (rDNA), AS04C-adjuvanted · HBsAg VLPs; TLR4 (AS04C adjuvant)
Genotoxicity
MPL only: negative in Ames and CHO clastogenicity tests; vaccine not tested
“An in vitro mutagenicity (Ames) and clastogenicity (CHO cells) test failed to demonstrate a genotoxic potential of MPL.”
✓ VerifiedEMA assessment report, p. 9Source ↗
Carcinogenicity
Not stated in public reviews
Instead of carcinogenicity
Not stated in public reviews

Flublok

influenza vaccine, recombinant hemagglutinin · Influenza HA
Genotoxicity
Not conducted (not normally required for viral vaccines; no adjuvant)
“No genotoxicity and carcinogenicity studies were carried out in line with relevant guidelines. Studies evaluating genotoxicity and carcinogenicity are normally not required for viral vaccines.”
✓ VerifiedEMA assessment report, p. 29Source ↗
Carcinogenicity
Not conducted (not normally required for viral vaccines; no adjuvant or novel excipients)
“Studies evaluating genotoxicity and carcinogenicity are normally not required for viral vaccines. Since no adjuvants or novel excipients are used in this product absence of those studies is considered acceptable.”
✓ VerifiedEMA assessment report, p. 29Source ↗
Instead of carcinogenicity
Not stated in public reviews

Gardasil

human papillomavirus quadrivalent (types 6, 11, 16, 18) vaccine, recombinant · HPV 6/11/16/18 L1 VLPs
Genotoxicity
Not conducted (CPMP/SWP/465/95 vaccine guidance)
“No genotoxicity studies were conducted, and this is in line with CPMP/SWP/465/95.”
✓ VerifiedEMA assessment report, p. 8Source ↗
Carcinogenicity
Not conducted (CPMP/SWP/465/95 vaccine guidance)
“No carcinogenicity studies were conducted, and this is in line with CPMP/SWP/465/95.”
✓ VerifiedEMA assessment report, p. 9Source ↗
Instead of carcinogenicity
Not stated in public reviews

Gardasil 9

human papillomavirus 9-valent vaccine, recombinant · HPV 9-valent L1 VLPs
Genotoxicity
Not conducted (vaccine guidance; CHMP agreed)
“The in vitro and in vivo genetic toxicity/mutagenic potential of the 9vHPV vaccine were not evaluated.”
✓ VerifiedEMA assessment report, p. 25Source ↗
Carcinogenicity
Not conducted (not required for vaccines)
“The oncogenic/carcinogenic potential of the 9vHPV vaccine in long and short-term studies was not evaluated. According to current requirements as mentioned above, carcinogenicity studies are generally not required for vaccines and this is acceptable also for Gardasil 9.”
✓ VerifiedEMA assessment report, p. 25Source ↗
Instead of carcinogenicity
Not stated in public reviews

Heplisav-B

hepatitis B vaccine (recombinant), adjuvanted · HBsAg; TLR9 (CpG 1018 adjuvant)
Genotoxicity
CpG adjuvant negative in Ames, in vitro chromosome aberration and in vivo mouse micronucleus tests
“No genotoxicity was observed in the standard battery of tests composed of in vitro bacterial mutation, chromosome aberration and in vivo mouse erythrocyte micronucleus test.”
✓ VerifiedFDA toxicology review, p. 3Source ↗
Carcinogenicity
Not conducted (vaccine and adjuvant guidelines, ICH S1A; sporadic exposure)
“No studies assessing the carcinogenicity of Heplisav B or 1018 ISS adjuvant have been performed. This is acceptable for this type of product in line with EMAs guidelines for vaccines and adjuvants and compliant with ICH S1A, considering that the exposure to this vaccine will be sporadic.”
✓ VerifiedEMA assessment report, p. 31Source ↗
Instead of carcinogenicity
Not stated in public reviews

Mosquirix

RTS,S/AS01 malaria vaccine · P. falciparum CSP-HBsAg (RTS,S) VLPs; TLR4 (AS01 adjuvant)
Genotoxicity
Not conducted on the final vaccine; adjuvant system components tested instead
“Vaccines are not used in the long term and this reduces risk from consequences of genotoxicity. However, the genotoxic potential of the Adjuvant System and its components should be understood.”
✓ VerifiedEMA assessment report, p. 51Source ↗
Carcinogenicity
Not conducted (not required for vaccines, adjuvant systems or immunoenhancers per WHO/EMA guidance)
“According to the WHO Guidelines on Nonclinical Evaluation of Vaccines (WHO, 2005), the EMEA Note for Guidance on Preclinical Pharmacological and Toxicological testing of Vaccines (CPMP/SWP/465/95) and the Guideline on adjuvants in vaccines for human use (EMEA/CHMP/VEG/134716/2004), carcinogenicity studies are not required for final vaccine formulations, Adjuvants Systems and/or immunoenhancers.”
✓ VerifiedEMA assessment report, p. 54Source ↗
Instead of carcinogenicity
Not stated in public reviews

Nuvaxovid

COVID-19 vaccine, recombinant spike protein nanoparticle, Matrix-M-adjuvanted · SARS-CoV-2 spike (nanoparticle)
Genotoxicity
Matrix-M1 adjuvant negative in GLP Ames and in vitro CHO micronucleus assays; in vivo testing judged unnecessary
“The confirmatory GLP-compliant bacterial reverse mutation assay and Mammalian Cell Micronucleus assay in CHO Cells with Matrix-M1 confirmed the absence of any indication for a genotoxic potential of Matrix-M1. Further in vivo studies were therefore not considered necessary.”
✓ VerifiedEMA assessment report, p. 51Source ↗
Carcinogenicity
Not conducted (WHO vaccine and adjuvanted vaccine guidelines)
“No carcinogenicity studies have been performed with the SARS-CoV-2 rS vaccine and Matrix-M1 adjuvant in accordance with the WHO Guidelines on Non-clinical Evaluation of Vaccines (2005) and Guidelines on the Non-clinical Evaluation of Vaccine Adjuvants and Adjuvanted Vaccines (2014).”
✓ VerifiedEMA assessment report, p. 51Source ↗
Instead of carcinogenicity
Not stated in public reviews

PreHevbrio

hepatitis B vaccine (recombinant), 3-antigen · HBsAg S/pre-S1/pre-S2 VLPs
Genotoxicity
Not conducted (in line with applicable guidelines)
“There were no studies on genotoxicity and carcinogenicity, which is in line with applicable guidelines.”
✓ VerifiedEMA assessment report, p. 27Source ↗
Carcinogenicity
Not conducted (in line with applicable guidelines)
“There were no studies on genotoxicity and carcinogenicity, which is in line with applicable guidelines.”
✓ VerifiedEMA assessment report, p. 27Source ↗
Instead of carcinogenicity
Not stated in public reviews

Shingrix

zoster vaccine recombinant, AS01B-adjuvanted · VZV glycoprotein E; TLR4 (AS01B adjuvant)
Genotoxicity
Not conducted on the final vaccine formulation (considered acceptable)
“The Applicant did not provide genotoxicity data for the final vaccine formulation gE/AS01B, which is considered acceptable.”
✓ VerifiedEMA assessment report, p. 33Source ↗
Carcinogenicity
Not conducted (not required for vaccines, adjuvant systems or immunoenhancers)
“Carcinogenicity studies were not performed. As carcinogenicity studies are not required for final vaccine formulations, adjuvants systems and/or immunoenhancers based on current guidelines, this was considered acceptable.”
✓ VerifiedEMA assessment report, p. 33Source ↗
Instead of carcinogenicity
Not stated in public reviews

HBVaxPro

hepatitis B vaccine (rDNA) · HBsAg VLPs
Genotoxicity
Not stated in public reviews
Carcinogenicity
Not stated in public reviews
Instead of carcinogenicity
Not stated in public reviews