For COVID-19 Vaccines, ACIP Will Be a Critical Gatekeeper

For COVID-19 Vaccines, ACIP Will Be a Critical Gatekeeper

; Paul A. Offit, MD

Disclosures

October 27, 2020

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This transcript has been edited for clarity.

Eric J. Topol, MD: Hello. This is Eric Topol for Medscape. It's a great privilege to have a one-on one conversation with my friend Paul Offit, MD, who is my go-to for vaccines. And this is an important time for vaccines. So, welcome, Paul.

Paul A. Offit, MD: Thank you, Eric.

Topol: We had convened recently to discuss vaccines. And then just last week there was a really important 9-hour meeting of the Vaccines and Related Biological Products Advisory Committee. Certainly, Paul, you were one of the key players there. Can you give us your overall sense of this long meeting, which was of intense public interest?

Offit: I think it was good that it was open, because what the public got to see was a look behind the curtain. What we struggled with is that typically for vaccines, one does large phase 3 trials, in which tens of thousands of people get the vaccine or don't get the vaccine. The data are evaluated and submitted as a biological license application (BLA) to the US Food and Drug Administration (FDA) for licensure.

But that's not this process. This process is not going to be a licensure process. These aren't going to be licensed vaccines. They're essentially going to be permitted for use through an emergency use authorization (EUA), which is frankly no different from any investigational drug. But that is odd because it's going to be given to most Americans.

I think from the public standpoint, when they hear EUA, they think hydroxychloroquine. Hydroxychloroquine was approved through an EUA, but it didn't work to treat or prevent the disease, and 10% of people who got it had cardiac toxicities. Or they think of convalescent plasma, also a product which has never been shown to work.

So the fear — and it's a reasonable fear, it's an understandable fear — is that the FDA, up to this point regarding these EUAs, really has not done its job. They have not stood between pharmaceutical companies and the American public to make sure that we get products that are safe and effective. They haven't. And therefore, the public is suspicious of this process.

What you saw in the advisory meeting last week, I thought, was an attempt to understand practically what the differences were going to be between doing it this way, with these unlicensed products, and doing it the way we always do. Because the fact of the matter is, these are large, prospective, placebo-controlled trials. The Johnson & Johnson trial is a 60,000-person trial. Pfizer's is 44,000. Moderna's is 30,000. That's a typical trial size for a biological license application. For example, the HPV vaccine was a 30,000-person trial. Our vaccine, the rotavirus vaccine, was a 70,000-person trial; pneumococcal vaccine was 35,000. So the size of these trials is typical. So why not do it through a biological license application? Why not do it the way we've always done it?

The answer is several-fold. Most important, I think the FDA would never license a product that was tested with a shorter period of time. I think that's the biggest. We're not going to know anything, really, about not just long-term efficacy, but even relatively short-term efficacy; we'll know that there's efficacy for months but not necessarily for a year. Whereas the HPV trial was a 7-year study and the rotavirus vaccine was a 4-year study. Usually it's several years. So this is unprecedented in terms of length of follow-up for efficacy and also, arguably more important, safety. We'll have a couple months of safety data after the last dose, which would pick up something like Guillain-Barré syndrome, as we saw with a flu vaccine. But you do worry about vaccine-induced pathology. And at least Stanley Perlman, MD, PhD, who was on the advisory meeting conference call, is a coronavirus immunologist. He wanted at least 4 months. So that's the struggle.

On the other hand, 225,000 people [in the United States] are dead from this virus within a year. As you move forward with these kinds of trials, you go from phase 1 to phase 2 to phase 3, you just try to reduce uncertainty. That's the goal. How much uncertainty do you need to reduce? Do we need to wait, for example, to see what the 1-year follow-up is, knowing that during that time hundreds of thousands of people may die? Should we wait 2 years, which William Haseltine, PhD, actually reasons: Why don't we wait 2 years and get all the data as we would do for a typical vaccine? The answer is because with the rotavirus trials, 60 children died per year; that's a little different from this.

Topol: Bill Haseltine was arguing during the advisory committee that we should wait 2 years for a vaccine?

Offit: No; it was just in a recent media interview.

Topol: Oh, okay. I didn't think he was weighing in on the committee. He's said some unusual things when I listen to his segments.

One of the reasons that an EUA is appropriate is, as you're putting it, the context of this pandemic, which is unlike the other vaccines that you reviewed. But another is that it takes many months to prepare a product BLA, right? They can be 10,000 pages. This is a much more expeditious route. Are there other reasons besides those two?

Offit: There's one other reason that was subtly stated on one of the slides presented by Jerry Weir, PhD, from the FDA, in regard to supervision regarding manufacturing. When the FDA licenses the product, they don't just license the product; they also license the process and they license the building. That is a rigorous process. I noticed that for our vaccine, the rotavirus vaccine, RotaTeq, was a 1-year process. You have to validate everything. You have to validate the computers; you have to validate how you're cleaning out the vats; you have to validate how you're putting the cells on a monolayer. However you're making the product, you have to validate every step of that. I think that in that slide that he showed, there was one word in there that made me think that this is a little looser than normal, which is the word "generally." It's going to be generally acceptable.

I asked somebody from the FDA to explain this to me, because when I looked at his slides, I thought, It doesn't look like it's any different in terms of what the FDA calls CMC, chemistry manufacturing control. It looked like it was no different from normal, which didn't make sense because I couldn't imagine how it could be that fast doing it the normal way. So there are some subtle differences there. But again, I wish we wouldn't call it an EUA. I wish we had another name for it.

Topol: Actually, that's an important point you brought up, because there is this pathway, expanded access, which could be used. What do you think about that?

Offit: Marion Gruber, PhD, who is at the FDA, talked about that as another way to think about this. And I think that makes sense. One of the fears she has, and I think we all have, is that Pfizer had stated that if they show that their vaccine meets a standard for efficacy, 50% or 60%, then they would then give the vaccine to the placebo group. She made the point in a couple of slides that they are under no obligation to do that — that under an emergency use authorization, you don't have to do that because, frankly, it's still investigational. It's an investigational product. Because the minute you give the vaccine to participants in the placebo group — and it could extend to other placebo-controlled trials — then you've lost data. Let's suppose that this vaccine is 60% effective. There may be vaccines out there that are 80% effective, 90% effective. But if you stop doing placebo-controlled trials, you're not going to know that. That's the tension in all of this.

Topol: This is one of the most important points of all: Once a company says their vaccine works and they file for an EUA, there is this ethical dilemma. I spoke to the Pfizer group, Kathrin Jansen and her colleagues, and their plan was, "We'll go ahead and file for an EUA. And we don't necessarily have to cross over our placebo participants, at least early on, because we certainly want to follow them." But there is an ethical dilemma. On the one hand, you're claiming some signal of efficacy; and on the other, you're denying the participants access to that efficacy. So it's a very fine line, right?

Offit: Yes. And there's not a clear answer to this. You could argue that if you're a 70-year-old person and you were in the placebo group — in the hopes that you were in the vaccine group — and now you find out that the vaccine is 60% effective or whatever, you can see how that person could reasonably say, "I think I should get this vaccine. I'm at higher risk. If I get this virus, I have a 10% chance of dying. I want this vaccine."

Topol: Yet here's this monstrous effort of having 60,000 people in a trial, but the follow-up can be basically lost if there's crossover. So it's like a domino effect. If one of these vaccines clicks and says, "We've got it" — and it looks like Pfizer and Moderna are leading at the moment — then there could be a rippling effect on all the programs, right?

Offit: Yes, because, ethically, can you give a placebo to somebody who's at risk — someone, say, who is obese or has diabetes or is older?

Topol: Clearly we're going to need lots of vaccines here. And as you alluded to, hopefully with incrementally increasing efficacy, even perhaps with a second generation of vaccines among these 200 different candidates. But is it a problem that people will ultimately take multiple vaccines along the way?

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