OtherCriticised but acceptedBeyond the letter
Adjuvant-alone 8-week repeat-dose study designs not representative of the clinical dose regimen
Why: Acceptable when all safety data are taken into account · Weight of evidence
“According to EMA guidelines on adjuvants the study designs were not representative for the clinical dose regime of Heplisav B.”
✓ VerifiedEMA assessment report, p. 27Source ↗ “However, by taking all safety data into account (as discussed along this report) these deficiencies of the 8-week repeated dose toxicity studies were considered acceptable.”
✓ VerifiedEMA assessment report, p. 28Source ↗ Safety marginCriticised but acceptedBeyond the letter
No NOAEL in the mouse repeat-dose study of the adjuvanted vaccine; adjuvant dose did not match the clinical dose
Why: High dose 42-fold the clinical dose; numerous clinical studies at intended and greater doses provide a basis to evaluate safety · Human data
“While the adjuvant dose does not provide the direct toxicologic support (lack of NOAEL) intended by matching the clinical dose, on a mg/kg basis the highest adjuvant dose in the mouse toxicology study (2.5 mg/kg) was approximately 42-fold greater than the intended clinical dose of 0.06 mg/kg.”
✓ VerifiedFDA toxicology review, p. 17Source ↗ “Numerous clinical studies at the current intended and greater doses have been conducted with possible autoimmune adverse events (Wegener’s granulomatous disease and thyroiditits) providing a basis to evaluate safety of this adjuvant.”
✓ VerifiedFDA toxicology review, p. 17Source ↗