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Nuvaxovid: what flexibility did regulators accept, and why?

COVID-19 vaccine, recombinant spike protein nanoparticle, Matrix-M-adjuvanted · SARS-CoV-2 spike (nanoparticle)
Flexibility accepted
DARTAcceptedBeyond the letter
Rat DART used Matrix-M1 below the absolute human dose (maximum volume of clinical formulation)
Why: Dose exceeds the human dose 40-fold on a weight-adjusted basis and induced an immune response in rats · Pharmacology or kinetics
“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 ↗
“In addition, the final audited DART report includes data showing that the dose used in this study did induce an immune response. The study design and generated results are therefore considered acceptable.”
✓ VerifiedEMA assessment report, p. 54Source ↗
OtherVerdict not stated
Rabbit repeat-dose study used antigen/adjuvant 50/50 µg instead of the clinical 5/50 µg ratio
“Of note, the dosing schedule used was not in accordance with the proposed clinical schedule (the dose ratio of SARS-CoV-2 rS nanoparticle/Matrix-M1 used is different: 50/50 in the study vs 5/50 in the clinical situation).”
✓ VerifiedEMA assessment report, p. 51Source ↗
DARTAcceptedBeyond the letter
DART done in rat although rabbit placental antibody transfer is more similar to humans
Why: Fetal titers about 8.0% and pup titers 70-82% of maternal levels showed sufficient antibody transfer · Pharmacology or kinetics
“For the evaluation of reproduction toxicology, the applicant has used the rat as animal model. It is noted that placental transfer of antibodies in rabbits is more similar to humans compared to rodents.”
✓ VerifiedEMA assessment report, p. 54Source ↗
“Titers measured in foetuses were approximately 8.0% of those present in dams, whereas nursing pups had anti-S lgG levels approximately 70-82 % of the IgG levels of the dams, indicating that sufficient antibody transfer occurred via placenta and especially lactation.”
✓ VerifiedEMA assessment report, p. 54Source ↗
DARTVerdict not stated
No male fertility study
Why: No adverse findings in male reproductive organs in the GLP repeat-dose study · Weight of evidence
“No male fertility studies were performed given no adverse observations in male reproductive organs were observed in the GLP repeat-dose toxicology study.”
✓ VerifiedEMA assessment report, p. 52Source ↗
BiodistributionAcceptedBeyond the letter
Matrix-M1 adjuvant biodistribution study not completed before approval
Why: Extensive clinical package at initial marketing approval · Human data
“Considering the extensive clinical package available at the time of initial marketing approval, the safety profile of the adjuvanted vaccine was considered acceptable without finalisation of the biodistribution study.”
✓ VerifiedEMA assessment report, p. 53Source ↗

Same question, other vaccines

Arexvy

respiratory syncytial virus vaccine, adjuvanted (AS01E) · RSV preF3; TLR4 (AS01E adjuvant)
Toxicity studies used AS01B adjuvant (double immunoenhancer dose) instead of the clinical AS01E formulation

Cervarix

human papillomavirus bivalent (types 16, 18) vaccine, recombinant, AS04-adjuvanted · HPV 16/18 L1 VLPs; TLR4 (AS04 adjuvant)
No genotoxicity or carcinogenicity studies with the vaccine (MPL adjuvant genotoxicity tested only)

Cyfendus

anthrax vaccine adsorbed, adjuvanted · B. anthracis PA; TLR9 (CpG 7909 adjuvant)
Effectiveness established from animal post-exposure survival studies under the Animal Rule instead of human efficacy trials

Fendrix

hepatitis B vaccine (rDNA), AS04C-adjuvanted · HBsAg VLPs; TLR4 (AS04C adjuvant)
No distribution or excretion data for the final vaccine or AS04C adjuvant

Flublok

influenza vaccine, recombinant hemagglutinin · Influenza HA
No nonclinical toxicity or pharmacology studies with the quadrivalent vaccine; package bridged from trivalent RIV3

Gardasil

human papillomavirus quadrivalent (types 6, 11, 16, 18) vaccine, recombinant · HPV 6/11/16/18 L1 VLPs
No dedicated safety pharmacology studies; physical signs monitored within toxicity studies

Gardasil 9

human papillomavirus 9-valent vaccine, recombinant · HPV 9-valent L1 VLPs
No safety pharmacology study

HBVaxPro

hepatitis B vaccine (rDNA) · HBsAg VLPs
No dedicated nonclinical studies with HBVaxPro; data extrapolated from HEXAVAC, PROCOMVAX and the thiomersal-containing vaccine

Heplisav-B

hepatitis B vaccine (recombinant), adjuvanted · HBsAg; TLR9 (CpG 1018 adjuvant)
Adjuvant-alone 8-week repeat-dose study designs not representative of the clinical dose regimen

Mosquirix

RTS,S/AS01 malaria vaccine · P. falciparum CSP-HBsAg (RTS,S) VLPs; TLR4 (AS01 adjuvant)
No reproductive and developmental toxicity studies

PreHevbrio

hepatitis B vaccine (recombinant), 3-antigen · HBsAg S/pre-S1/pre-S2 VLPs
Pivotal repeat-dose toxicity study in rats not GLP-compliant

Shingrix

zoster vaccine recombinant, AS01B-adjuvanted · VZV glycoprotein E; TLR4 (AS01B adjuvant)
Vaccine DART only in rats at 40% of the human dose; no full-human-dose rabbit study

Summary across all 13 vaccines →