The National Vaccine Advisory Committee (NVAC)
TO: National Vaccine Advisory Committee
FROM: National Vaccine Advisory Committee, H1N1 Vaccine Safety Subgroup
SUBJECT: Draft Recommendations on 2009 H1N1 Influenza Vaccine Safety Monitoring
DATE: July 24, 2009
The National Vaccine Advisory Committee (NVAC) established the H1N1 Vaccine Safety Subgroup with the charge to review the current federal plans for safety monitoring for a 2009 H1N1 influenza vaccine and provide feedback on the adequacy, strengths, weaknesses and considerations for enhancement. As of July 23, 2009, the H1N1 Vaccine Safety Subgroup has met three times, and based on these discussions it has provided the following recommendations for NVAC’s consideration. These recommendations were made based on the incomplete information available at the time on plans for monitoring vaccine safety during a possible 2009 H1N1 influenza vaccination campaign this fall; the recommendations may evolve as plans change. They will be presented to the full NVAC for vote on July 27, 2009, via telephone conference call. The Subgroup will continue to meet and plans to update NVAC at its scheduled August 24, 2009, teleconference meeting.
1. A clear federal plan to monitor 2009 H1N1 influenza vaccine safety is needed both for proper planning purposes in the federal government and to provide information to the public and stakeholders (including states) about important vaccine safety activities. A comprehensive and detailed plan should be developed and disseminated that outlines the HHS plan for monitoring vaccine safety. This plan should include:
- Specific activities under development with acknowledgement of gaps and limitations. Specific studies planned to be carried out should also be included.
- An organization chart outlining who is involved, what their responsibilities are, the flow of information, how coordination will be achieved between different federal office and agencies, who makes which decisions, who is responsible, and other relevant roles.
- A clear timeline of planning processes, completion of preparations, and execution of activities.
- Involvement and role of other federal agencies such as Department of Defense and the Veterans Administration.
2. The need to actively monitor vaccine recipients for vaccine adverse events is critical given that the vaccine candidates will all contain a new antigen and may be combined with adjuvants that are not part of licensed vaccines in the US. Relevant parties of HHS should develop appropriate procedures for linking exposure and outcome data in as large a population base as feasible, including consideration of subpopulations targeted for vaccine use. In order to do this, accurate exposure to vaccine and adjuvant type for each dose administered (with lot numbers, if possible) must be linked to outcome data. The current vaccine safety infrastructure is unlikely to be sufficient to accomplish this. Consideration should be given to the following strategies for active vaccine safety surveillance:
- Utilizing existing mechanisms that are used for vaccine adverse event surveillance but may need to be enhanced or refined.
- Exploring existing databases that have not yet been used for vaccine adverse event monitoring but could be.
- Developing novel strategies, although a process for collecting and vetting is needed given the short timeframe anticipated.
A clear timeline should be developed for finalizing necessary arrangements.
3. Consideration should be given to a transparent and independent review of vaccine safety data as it accumulates. This Vaccine Safety Assessment Committee (VSAC) would be an independent group of outside experts with a charge to advise the ASH and/or ASPR on the presence, investigation, interpretation, and implications of possible side effects of H1N1 vaccines. The committee should be reviewing pre- and post-licensure vaccine safety data accumulated in a timely way and not await activation when a specific signal is declared. The VSAC should advise on distinguishing spurious from genuine side effects; anticipating and responding to coincident (non-causal) events; evaluating the occurrence, frequency, and seriousness of possible side effects associated with vaccine; programmatic and policy steps to take in response to purported or demonstrated safety concerns; strategies and content of communication about vaccine safety; and such other matters related to vaccine safety that the ASH/ASPR would find useful. Such an external review would involve an independent group of experts with no professional or commercial stake in the vaccines or conduct of an immunization program, to speed and improve response to possible vaccine side effects, to enhance public confidence, and to provide focused advice on what can become a scientifically and politically contentious issue. The VSAC may be made up of members of an existing federal advisory committee, such as NVAC, and supplemented by other vaccine safety experts. The committee would only assess risks (not consider vaccine benefits) and the committee would be only advisory and not decision making. The ASH/ASPR would be responsible for assuring programmatic response to the assessment of risk.
Federal planning activities are still underway. The H1N1 Vaccine Safety Subgroup will continue its task to provide specific advice and recommendations on 2009 H1N1 vaccine safety monitoring to NVAC, and specifically will report to NVAC at its planned July 27 and August 24 teleconference meetings.
H1N1 Vaccine Safety Subgroup Membership:
Gus Birkhead, Chair of NVAC, Deputy Commissioner, New York State Department of Health
Steve Black, Adjunct Professor, Cincinnati Children's Hospital, former CISA/VSD investigator
Corry Dekker, NVAC member, CISA investigator, Professor of Pediatrics & Medical Director, Stanford-LPCH Vaccine Program, Stanford University School of Medicine
Harvey Fineberg, President, Institute of Medicine
Claire Hannan, Executive Director, Association of Immunization Managers
Marie McCormick*, NVAC member, Professor of Maternal and Child Health, Harvard School of Public Health, former Chair of the IOM Immunization Safety Review Committee
Andy Pavia*, NVAC member, Department of Pediatrics, University of Utah School of Medicine
Wayne Rawlins, NVAC liaison representative from America's Health Insurance Plans, National Medical Director, Aetna
David Sundwall, Executive Director, Utah Department of Health
*Co-Chairs of the NVAC H1N1 Vaccine Safety Subgroup