Questions and Answers on Bovine Derived Materials
Used in Vaccine Manufacturing:
Why are animal products used in the manufacture of
vaccines?
Vaccines contain either killed or weakened forms of disease-causing
bacteria or viruses, or components of these that stimulate a response by
the body’s immune system, which then protects against the development of
disease. In the late 19th century, microbiologists began to
grow bacteria in the laboratory. The early bacteriologists tried to mimic
as closely as possible the infected person’s tissues by using sugars,
salts, and various meat extracts to make "growth media." These kinds of
conditions were quite successful in growing bacteria and then viruses in
the lab, because these media supplied the many necessary nutrients.
Although synthetic media have been developed for growth of many medically
important microorganisms, some still require additional nutrients which
are easily provided by animal-derived products such as serum and blood.
Which bovine derived materials are used in vaccine
manufacture?
Microorganisms for vaccine manufacture are grown under controlled
conditions in media which provide the nutrients necessary for growth. Cow
components are often used simply because cows are very large animals, and
thus much material is available. Animal-derived products used in vaccine
manufacture can include amino acids, glycerol, detergents, gelatin,
enzymes and blood. Cow milk is a source of amino acids, and sugars such as
galactose. Cow tallow derivatives used in vaccine manufacture include
glycerol. Gelatin and some amino acids come from cow bones. Cow skeletal
muscle is used to prepare certain complex media. Many difficult to grow
microorganisms require the addition of serum from blood to the growth
media.
Do all bovine materials have the same risk of transmitting the
BSE agent?
Scientists have found that different bovine tissues contain different
amounts of the BSE agent. It is generally believed that the highest
amounts of infectivity are found in the brain and spinal cords from
animals in the final stages of clinical disease. Some tissues such as
skeletal muscle and milk have never been shown to have any infectivity.
However, the slaughtering and butchering methods used to obtain tissues
and prepare materials can affect the amount of infectivity that may be
present. Also the production processes used to prepare bovine-derived
materials (such as heat sterilization and chemical treatment) may reduce
or remove infectivity.
What measures have the FDA taken to ensure that people are not
exposed to the BSE agent in vaccines?
It is believed that variant CJD was acquired from eating food products
containing the BSE agent. However, FDA wants to minimize any chance that
the BSE could be introduced into biologic products during manufacture. The
Center for Biologics Evaluation and Research (CBER) is responsible for
regulation of biologic products, including vaccines. In a 1991 letter to
manufacturers CBER expressed concern about bovine sourced material. In
December 1993 and May 1996 FDA issued letters advising that bovine derived
materials from animals born in or residing in countries where BSE had
occurred should not be used to manufacture FDA-regulated products intended
for administration to humans. A 1993 Points to Consider document ("Points
to Consider in the Characterization of Cell Lines Used for the Production
of Biologics") stressed the importance of control of sourcing of bovine
materials. On April 19, 2000, CBER issued a letter reminding manufacturers
that the USDA list of BSE-countries had been expanded to include not only
those countries where BSE was known to exist but also those where BSE may
exist (FR, January 6, 1998). CBER strongly recommended "that manufacturers
take whatever steps are necessary to assure that materials derived from
all species of ruminant animals born, raised or slaughtered in countries
where BSE is known to exist, or countries where the USDA has been unable
to assure FDA that BSE does not exist, are not used in the manufacture of
FDA-regulated products intended for administration to humans."
Questions and Answers Related to FDA Guidance on
Sourcing of Bovine Materials:
How did the FDA discover that some manufacturers are not
universally following letters, PTC and guidance documents?
During review of new license applications manufacturers are asked to
provide detailed descriptions of the manufacturing process and
documentation of source country for all materials of animal origin. During
review of a recent license application it was determined that some of the
material used during manufacture had been obtained from countries which
are on the USDA list of countries which either have or may have BSE. This
finding prompted an inquiry of all licensed vaccines.
What is FDA doing now to assure that companies follow guidance,
letters, and PTC documents?
The Center for Biologics Evaluation and Research (CBER) has asked
licensed vaccine manufacturers to evaluate all bovine sourced material
used at any stage of manufacture. Manufacturers have been requested to
identify all material of animal origin. For materials of bovine origin
CBER has asked manufacturers to identify the source country from which the
animals originated, the date the material was obtained and the date the
material was used in manufacture of vaccine lots.
When it is determined that any bovine-derived component used to make
the working seeds or during routine production was obtained from a country
on the current USDA list of countries which either have or may have BSE,
the manufacturer has been asked to change the source of such material.
CBER inspects vaccine manufacturers on a routine basis to determine
whether sourcing and documentation are consistent with current
recommendations contained in letters and guidance documents.
Questions and Answers Related to Vaccines and
vCJD:
Why did the FDA ask the Transmissible Spongiform Encephalopathy
Advisory Committee and the Vaccines and Related Biological Products
Advisory Committee meet on July 27th, 2000?
The Center for Biologics Evaluation and Research (CBER), FDA regulates
biological products including vaccines. For several years CBER has
recommended that bovine derived components from countries which have or
may have BSE (bovine spongiform encephalopathy, the so called "mad cow
disease") not be used for the manufacture of US-licensed biological
products including vaccines. The consumption of food contaminated with the
BSE agent has been linked to a fatal disease in people called new variant
or variant CJD (vCJD). There is no evidence that any case of vCJD has
resulted from use of a vaccine, and there is no evidence that any vaccines
harbor the BSE agent. CBER had recently determined that some vaccines were
manufactured using bovine components from countries which the USDA has
determined have or may have BSE. CBER believed that the chance of getting
vCJD through vaccines is remote and theoretical. However, CBER has
responsiblility to ensure that vaccines used in the US are safe and asked
for this special joint meeting to ask vaccine and TSE experts to formally
discuss the risk of transmitting vCJD from vaccines.
What is the chance/risk that a vaccine on the market in the US
contains the BSE agent?
Studies of the BSE agent have shown that infectivity depends on nature
of material used, how much is used and the route of administration. Other
factors, such as the country of origin of the cattle used to supply the
manufacturing material, also have to be factored into any risk estimate.
Both the European Community and the US Pharmaceutical industry have
presented risk assessment calculations which attempt to account for all
these factors. In 1999, the Council on Scientific Affairs (CSA) of the
American Medical Association considered the risk of BSE to public health
and determined that the current risk of transmission of BSE in the US is
minimal, concluding that adequate guidelines exist to prevent high risk
bovine materials from contaminating products intended for human use. The
report from the CSA did not address the possibility that regulated
industry might not follow all of the recommendations made by the FDA.
However, both FDA and the joint advisory committee meeting have considered
the risks posed by bovine material in vaccines and concluded that any risk
is remote and theoretical See Section VI and MMWR Recommendations and Reports.
What is the risk of getting vCJD if a vaccine contained the BSE
agent?
There is no evidence to date that vaccines have contributed to the
cases of vCJD seen in Europe. Nor is there evidence that any vaccines
harbor the BSE agent. Vaccines are given a very limited number of times
via the intramuscular, subcutaneous or oral route. Even in experimental
studies, these routes of administration are less effective at spreading
the agent than the intracerebral route usually used to assess infectivity
in animal studies. The amount of infectivity present and the efficiency
with which the BSE agent passes from cow material to humans will also
affect the likelihood of infection.
How did FDA derive its risk estimates and decide the risk of
vCJD from vaccines was remote and theoretical?
Scientists, regulatory authorities in Europe and the pharmaceutical
industry of the US have considered the risks of BSE in pharmaceutical
products. In estimating these risks it is necessary to consider the
country of origin of any bovine material, the type of bovine tissue used,
the steps used to process the bovine tissue, the amount of bovine derived
material used and the stage of vaccine manufacture at which the bovine
material is used. Using previously published methods for calculating
theoretical risk of cases of vCJD from pharmaceutial products, FDA has
calculated a conservative estimation of the risk of a vaccine causing a
case of vCJD. These estimates were presented in public session at the
joint advisory committee on July 27th 2000. FDA believes these
estimations are a realistic worst case scenario and that the real risk any
US licensed vaccine could cause vCJD is even lower than the estimates
presented. See Section
VI and Section
II.
Why is FDA leaving vaccines on the market that did not follow
its own recommendations regarding sourcing of bovine derived
materials?
The FDA has looked at the benefit of vaccines and the risk of vCJD from
vaccine use. Vaccines have a proven benefit in reducing the incidence of
serious, often life-threatening diseases. The Public Health Service, FDA,
and the members of FDA’s advisory committees on TSE and Vaccines and
Related Products (VRBPAC) (7.27.00 link to Ad Com transcripts, link to
AAP and ACIP) believe the risk that anyone will get vCJD from a
vaccine to be remote and theoretical. Without routine vaccination the
incidence of disease would increase. This was seen in Sweden, Japan and
the UK when the number of children vaccinated against pertussis decreased
due to concerns about vaccine adverse events associated with the
whole-cell DTP vaccine. Manufacturers of US licensed vaccines ensure an
adequate supply of recommended vaccines. Removal of a licensed vaccine
from the market could cause insufficient supply and potentially increase
the number of unvaccinated or under vaccinated individuals at risk from
preventable diseases.
If vaccines are safe why did the UK recall their polio
vaccine?
If vaccines are safe why did the UK recall their polio vaccine? The UK
recalled the Evans/Medeva Oral Polio Vaccine in October, 2000. This
vaccine has never been licensed for use in the US. The Medicines Control
Agency (MCA) had requested and received assurances from drug companies
that they were implementing guidance not to use UK-sourced bovine
materials in the manufacture of injectable medicinal products. The recall
was prompted by evidence that the Evans/Medeva vaccine was manufactured
using fetal calf serum from the UK at a time when there was a risk of BSE
in that country. This is in contravention of European Union guidelines.
According to a statement from the Chief Medical Officer at the UK Dept. of
Health (10.20.00) the company had assured the MCA of the UK that
UK-sourced bovine materials were not used in the manufacture of the
vaccine. However, these assurances were inaccurate, thus the vaccine was
withdrawn. (www.doh.gov.uk/cmo/cmo00_12.htm)
What is the recent concern in the Republic of Ireland about polio
vaccine and vCJD?
In December, 2000 the Irish Government issued a statement indicating
that an oral polio vaccine distributed in 1998 and 1999 in Ireland had
been manufactured using human serum albumin from a pool of donors, one of
whom had since been diagnosed with vCJD. Evans/Medeva manufactured this
oral polio vaccine. This vaccine is not licensed for use in the US.
Have there been vaccines produced using cow materials from
countries where there is a significant risk of BSE?
During review of a new license application, FDA learned that one
manufacturer had used bovine-derived material from a country in which the
USDA had determined that BSE might exist. CBER requested all vaccine
manufacturers review the source of any bovine derived material used in the
manufacture of their vaccines. Additional vaccines manufactured using
bovine derived products from European countries were identified. These
vaccines are identified in the “Recommendations for the Use of Vaccines
Manufactured with Bovine Derived Materials” section of this web site.
Is there a possibility that some vaccines might be contaminated
with the BSE agent? (See above “What is the chance/risk that a
vaccine on the market in the US contains the BSE agent”)
My child was just immunized. Should I be worried?
No. FDA and other Public Health Service agencies believe that the risk
of contamination of any US licensed vaccine with the BSE agent is remote
and theoretical. FDA asked a special joint meeting of the Transmissible
Spongiform Encephalopathy and the Vaccines and related Biological products
Advisory Committees to review the available vaccine risk and benefit
information. This joint committee concluded that the substantial risk of
disease due to not vaccinating children far outweigh the theoretical risk
posed by vaccines that have a remote chance of containing the BSE agent
(see PHS statement in MMWR and “Recommendations for the Use of Vaccines
Manufactured with Bovine Derived Materials” section of this web site for
details)
Why are you continuing to vaccinate children with a vaccine
that may be contaminated with BSE causing materials? Also see
above “Why is FDA leaving vaccines on the market that did not follow its
own recommendations regarding sourcing of bovine derived materials."
FDA and other Public Health Service agencies believe that the risk of
contamination of any US licensed vaccine with the BSE agent is remote and
theoretical. FDA asked a special joint meeting of the Transmissible
Spongiform Encephalopathy and the Vaccines and related Biological products
Advisory Committees to review the available vaccine risk and benefit
information. This joint committee concluded that the substantial risk of
disease due to not vaccinating children far outweigh the theoretical risk
posed by vaccines that have a remote chance of containing the BSE agent
(see PHS statement in MMWR and Recommendations for the Use of Vaccines
Manufactured with Bovine Derived Materials” section of this web site for
details)
What is being done to ensure the United States’ vaccine supply
is safe?
Also see above “What is FDA doing now to assure that companies
follow guidance, letters and PTC documents?” FDA and the other PHS
agencies believe that vaccines licensed for use in the US are safe and
effective. However, because even the perception of risk could have
negative consequences for the use of vaccines and because it is possible
to decrease the risk of an already safe product even further,
manufacturers of affected vaccines have agreed to change the source of the
bovine derived material used during production of the working seeds and
cell banks and for routine production (see Recommendations for the Use of
Vaccines Manufactured with Bovine Derived Materials" section of this
web site for details).
When will vaccine manufacturers finish replacing cow-derived
materials in vaccines with materials obtained from countries free of
BSE?
The time to make a vaccine and bring it to market can take several
months to a year. Most vaccine made using bovine derived material from
non-BSE risk countries should be available by the end of 2001.
Shouldn't all potentially contaminated vaccine be destroyed?
Also see above “Why is FDA leaving on the market vaccines which may
be contaminated with the BSE agent?” FDA and other PHS agencies
believe that the vaccines currently licensed for use in the US are safe. A
special joint meeting of the TSE and Vaccines and Related Biological
Products Advisory Committees concluded that the real risk of disease due
to not vaccinating far outweigh the theoretical risk posed by exposure to
vaccines that have a remote chance of containing the BSE agent.
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