Since we have a good post, above, about the FDA and the approval process, I wanted to add some additional information.
I have spent my career in public service, working the past 35+ years for the FDA. My area of expertise is human/animal pharmaceutical manufacturing, drug manufacturing regulations, and FDA pharmaceutical inspections. I can share my knowledge of FDA with y’all, but I need to note that this is in a personal capacity and I’m not speaking on behalf of the Agency.
Lets start with some basics. First the Food & Drug Administration is an agency that is part of HHS (Health and Human Services). The head of the FDA (the FDA Commissioner) is typically a political appointee who reports to the Secretary of HHS, who in turn reports to the President. All of the Center Directors are civil servants. The FDA has an Office of the Commissioner (his/her immediate office) and several Centers, including CBER (Center for Biologics Evaluation and Research), CDER (Center for Drug Evaluation and Research, CDRH (Center for Devices and Radiologic Health), CFSAN (Center for Food Safety and Applied Nutrition), CVM (Center for Veterinary Medicine, and CTP (Center for Tobacco Product). In addition, one addition Office is ORA (Office of Regulatory Affairs). ORA is the field inspectional office for FDA and does inspectional/investigational work for all of the office described above. Vaccines are biological products, so their review falls to FDA/CBER.
Let’s talk about the post:
Had a long conversation about FDA approval this weekend with a friend. He didn't realize that the vaccines were NOT fully FDA approved.
True. As of this time, the covid-19 vaccines are approved under EAU (Emergency Use Authoriations). There is still an on-going review of data to, hopefully, support full authorization.
FDA will allow a product to present more of a risk when its potential benefit is great — especially for products used to treat serious, life-threatening conditions.
This is also true. FDA’s charge is to make sure that drug and biologics are safe and effective for their intended use. However, there is also a weighing of benefit to risk, especially when there are no other worthwhile treatments for a disease.
What finally solidified the premise that the FDA approval doesn't really fundamentally change the situation was the realization that the FDA doesn't do the testing, it only reviews the data that the company has gathered.
This is also true. However, it is not a situation where a company dumps data on the FDA and the Agency rubber stamps their interpretation of the data. There is a lot of data (raw data and not just summary data) that is reviewed by CBER and CDER for application reviews. Often during the CDER/CBER review, the corresponding Center will ask for clarification of the data and for additional data. Some products may have a Rolling Application where rather than wait until the studies are complete, the Center will review data in blocks as it is available. The Reviewers at both CBER and CDER are made up of PhD’s and MDs.
Furthermore, the idea that it's a judgement call to allow the use of a treatment means that someone with the appropriate credentials has already reviewed preliminary data, and made the assessment that the benefits outweigh the risks for an emergency approval, and the likeliness of an overturn here is low (less than 32% - data below).
While there may be unforeseen adverse events, post approval, few of them cause a drug product to be withdrawn from the marketplace. More likely, there are some adverse advents that may not have been seen during the safety and efficacy studies, or maybe at a different rate, as the study populations are much smaller than the general population. Companies (Sponsors of an application) make a commitment, in their applications, to notify FDA of any unforeseen serious adverse events they become aware of, both known and unknown.
We also found an article from NPR in 2017 that shows more asserts 1/3 of drugs that get FDA approval have problems. However, they only quote 3 out of 222 (and don't link to their data for further probing) as being removed from market. That certainly doesn't help the case, but if you consider that statistic, you're nearly as likely to have issues from a random drug your doctor prescribes as you are the vaccination. So again, under the idea of risk mitigation due to unapproved drugs, the vaccine is a marginal difference, it has about a 32% chance of having a problem that is required to be addressed and about a 1.4% chance of being removed from market.
These statements need to be parsed a bit more. Like discussed above, “problems” could be ‘minor’ adverse events not previously know, or possibly at a different rate. Occasionally, there could be ‘major’ adverse events. Major adverse events could cause a drug to be withdrawn from the marketplace or the creation of a ‘blackbox’ statement on the product labeling.
NPR News Article said:
Seventy-one of the 222 drugs approved in the first decade of the millennium were withdrawn, required a "black box" warning on side effects or warranted a safety announcement about new risks, Dr. Joseph Ross, an associate professor of medicine at Yale School of Medicine, and colleagues reported in JAMA on Tuesday. The study included safety actions through Feb. 28.
Again, there is a huge difference between a drug being withdrawn, a blackbox statement added to the product labeling, and finding known (or new) additional minor adverse events.
Link to NPR news article
Further reading into the article really underscores the lack of weight that should be given to FDA approval. The approval is nothing more than a peer review from other subject matter experts that the data agrees with the manufacturers intentions and assertions. It is not the FDA themselves designing, completing, or recording the testing, just a review of what the manufacturing company has completed.
FDA gives guidance on how drug studies should be conducted and the types of data they expect to be submitted. Aside, from the application review of the data, FDA conducts inspection of the manufacturing plants, and also conducts bioresearch monitoring audits of some drugs studies.
Bottom line is I trust the reviews that are done on biological and drug products and those that lead to the emergency use authorization of these vaccines. There have been almost 200 million Americans vaccinated so far, thus, there is a lot of data available. I encouraged my mother and my wife’s parents (all in the 80’s and 90’s) to get the covid vaccine as soon as it was available. Same holds true for my adult daughter. In addition, my wife and I were both vaccinated as soon as the vaccines were made available to us.
Jim