| Literature DB >> 35001848 |
Margaret A Liu1, Tiequn Zhou2, Rebecca L Sheets3, Heidi Meyer4, Ivana Knezevic2.
Abstract
This paper presents the key outcomes of the above WHO informal consultation with global stakeholders including regulatory authorities, vaccine developers and manufacturers, academia and other international health organizations and institutions involved in the development, evaluation and use of messenger RNA (mRNA) vaccines. The aim of the consultation was to further clarify the main principles to be presented in an upcoming WHO guidance document on the regulatory considerations in evaluating the quality, safety and efficacy of mRNA prophylactic vaccines for infectious diseases. This WHO guidance document is intended to facilitate global mRNA vaccine development and regulatory convergence in the assessment of such vaccines. The urgent need to develop such a document as a new WHO written standard is outlined in this report along with the key scientific and regulatory challenges. A number of key conclusions are provided at the end of this report along with an update on the steps taken following this meeting.Entities:
Keywords: COVID-19; WHO; infectious diseases; mRNA vaccines; prophylactic vaccines; regulatory considerations
Mesh:
Substances:
Year: 2022 PMID: 35001848 PMCID: PMC8812800 DOI: 10.1080/22221751.2022.2026742
Source DB: PubMed Journal: Emerg Microbes Infect ISSN: 2222-1751 Impact factor: 7.163
Summary of major proposed changes for the draft WHO document by sections.
| Section | Proposed changes |
|---|---|
| Introduction | § Various points of clarification, specific wording and changes in organization were agreed upon. Such changes occurred throughout the document, but particularly in these sections, which provided the foundational information for the document. § Add following additional information as deemed important for the nonclinical and clinical evaluation sections:
expression efficiency of self-amplifying mRNA compared with standard mRNA constructs further information about LNP relevant to their in vivo behaviour including the cells to which they target and effects on innate immunity § Because some pathogens may have different strains, or variants may arise, the issues related to strain changes and/or increased valency may need to be considered in vaccine composition. Guidance and reference to WHO documents dealing with variants and multivalent vaccines are provided throughout the document. § Consensus was reached for the following terms:
“Drug substance” refers to mRNA “Final bulk” was changed to “final formulated bulk” and the definition has been amended to state that the final bulk may be stored at a higher concentration and diluted prior to fill “Final vaccine” aka “drug product” was clarified to include “mRNA formulated in LNP” for this document “Platform technology” was a newly added term and prompted extensive discussion due to considerations such as whether a licensed product must form the basis for a platform technology as well as what defines the technology (i.e. the LNP-formulated mRNA, and any impact of changes to the mRNA or the LNP, etc.). Continuing discussions by the drafting group will propose a definition in the next draft. Further issues related to considerations of a platform technology are discussed in the subsequent sections in relationship to general considerations for multivalent/multi-strain vaccines and for nonclinical and clinical evaluation. Moreover, the issues addressed regarding the implications of a platform technology concept required additional discussions and amendments under other sections such as “Manufacture and control of mRNA vaccines” and the nonclinical and clinical evaluation sections. § Multivalent candidates may be generated for vaccines targeting different strains of the same pathogen or for vaccines targeting more than one pathogen. The drafting group is working on modifications to the language regarding this point, including referencing existing WHO guidelines on clinical evaluation of vaccines [ § Specific manufacturing issues that will guide the writing and revisions include:
Leveraging existing experience with the same platform technology will facilitate expeditious development of mRNA vaccines in response to future emerging pathogens. The need to clarify the definition of “platform technology” was raised for this section as well. A key point was made that the technologies and components differ between manufacturers. For example, in addition to the differences between standard and self-amplifying mRNAs, certain manufacturers use modified nucleosides, whereas others modify the sequence of the mRNA from that of the natural pathogen antigen but use native nucleosides. Each manufacturer also has developed their own LNP based on differing lipids, with differing modifications, and their own process for formulation of the mRNA into the LNP. This has implications on the quality control and evaluation. Currently, there is limited experience and a lack of a “gold/or harmonized standard.” Based on the different components and methodologies, it might not be possible to have such a standard, even for vaccines against the same disease. Certain information about production and quality control methods and specifications is also confidential since it is based on a given manufacturer’s proprietary platform technology. Flexible approaches about what should be included for specific quality-control testing were suggested by manufacturers to take into account the ongoing development of the technology, e.g. confirmation or measurement of poly(A) tail length might not be needed on a lot-by-lot basis if encoded into the DNA template instead of added enzymatically. § While assessments for typical parameters such as content, identity, purity, mRNA integrity, potency, other quality and safety parameters, and stability would be needed, it was not recommended to provide a specific list of required assays, since the current situation is not standardized and the technologies may evolve. Certain tests might be for characterizations vs. control or release tests. A table of examples of assays suitable for various purposes was added to the document. § The use of starting materials that are appropriate for the stage of development of the product might mean that under emergency conditions, one might accept divergence from the otherwise expected full compliance with good manufacturing practices (GMP). This is an example of balancing a trade-off of risk and benefit in an emergency setting, such as with COVID-19. § For self-amplifying mRNAs where the replicon is encoded by a separate mRNA, additional controls may be needed to ensure adequate encapsulation of the (two) mRNAs, potentially different expression of the encoded proteins, and the ensuing impact on the potentially different safety and efficacy of the vaccines based on self-amplifying mRNA versus mRNA. § The table of analytical methods was re-labelled to clarify that the listed assays were examples rather than specifically recommended assays; the statement in the narrative leading into the table was also modified. § Differences of opinion arose as to what should be required for certain control parameters. One example is what would be an indication of vaccine potency, and in particular whether an in vivo assay would be needed or if an in vitro assay would be adequate or preferred. Language was changed in the potency section to soften the statement about application of the 3Rs (Replacement, Reduction and Refinement) approach, which had stated that it was recommended to avoid animal-based potency methods. § Different types of impurities may be seen and different products may have different properties. Specifications, including upper limits, need to be set on a case-by-case basis, for example depending on the length of the mRNA. A suggestion was made to include a statement that limits should be reflected by clinical batch data. § Regarding the issues of whether modified or nonmodified nucleosides are used together or with complete replacement, the wording was changed to reflect different mRNA designs. Wording suggested may include, “in cases where specific ratios or positions are part of the product design.” The text was clarified that at present, when modified nucleosides are used, they entirely replace the natural nucleoside. § A comment was also added about double-stranded RNA: “Testing for dsRNA needs to be done depending on the process and its ability to generate it.” dsRNA can be generated during certain in vitro transcription manufacturing processes of mRNA. This impurity can stimulate innate immune responses, and thus should be removed or quantitated and controlled for if the manufacturing method produces it. § The text was amended to specifically mention that information about all the components of the vaccine, i.e. LNP and excipients as well as the mRNA would need to be provided. This includes the rationale for their inclusion as well as their specifications. § In addition, the document will be amended to additionally address LNP controls regarding manufacture, purity, consistency and purification to remove excess raw materials. Section on “Manufacture and control of lipid nanoparticles and encapsulation of mRNA” needs more attention to add controls. Examples of issues that need to be addressed include the fact that the size of the mRNA can affect its interaction with the LNP and the concepts of same/identical vs. comparable/essentially unchanged in regard to what could be considered a platform technology. § A requirement was added that information related to the generation of the linearized DNA template will also be necessary, including the cell banks, stability and other characteristics. § Additional discussions dealt with identity, purity, quantification and physical state, and additional quality parameters (e.g. poly(A) tail length, degree of capping efficacy) resulting in ongoing modifications to the text. § The section on reference standards was discussed and expanded to address additional issues such as the role of the NRA, a standards programme, and the conditions for formulation and storage. § Additional attention was deemed necessary for issues related to the impact of changed mRNA upon the LNP. § The labelling recommendations were discussed and expanded. § Safety and toxicity: Discussions centred around biodistribution, persistence and inflammation of both the mRNA and the LNPs. § Because novel lipids and novel formulations can affect the charge of the LNP, a discussion ensued regarding which component needed genotoxicity and systemic toxicity studies. Much as would be done for a novel adjuvant, the novel lipids or formulation might be included as a study arm in comparison with the vaccine, in such studies. Reference to relevant WHO and International Council for Harmonization guidelines [ § As a result of the discussion on the rationale that integration studies are not necessary for mRNA vaccines, the text was amended to read: “Further, the design of candidate mRNA vaccines should be considered so that they do not include specific RNA-binding sites for primers required for the reverse transcriptase to initiate transcription,” to specifically highlight that the vaccine should be designed to exclude such RNA-binding sites. § The possibility of accelerating the nonclinical evaluation of mRNA vaccines in the case of strain changes when all other aspects of the construct, manufacturing processes and controls are the same was discussed with modifications to the text proposed. § The types and scope of adverse effects including immunological parameters, and how these could affect the design of clinical trials was discussed with reference to existing WHO guidance documents. § Efficacy evaluation in a public health emergency when variants arise, and the possibility of bridging studies, were further discussed and modifications to the section are under consideration with reference made to existing WHO guidelines. A caution was made by some participants that this document should provide general guidance and specific considerations will be case-by-case. Particularly, there are other groups working on regulatory guidance on strain changes and immunobridging for COVID-19 vaccines, and there is established practice for global annual influenza vaccine strain changes, which should not be contradicted by this document. |
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Because new data are rapidly accruing, this WHO document may need to be updated in the future when more information is available. To avoid restricting future development, this WHO document should include statements on the need for case-by-case considerations and benefit/risk evaluation. It is important that NRAs are engaged early on in vaccine development and evaluation to ensure the optimal progress of clinical trials of mRNA vaccines. |
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Key discussions centred on the concept of mRNA as a platform technology, what should be accepted for various assays/characterizations including: potency, safety, toxicity studies, biodistribution, mechanism of action studies, variants/multivalent vaccines, etc. These aspects were each specifically discussed during the review of the relevant section(s) of the document. Specific manufacturing issues that guide the writing and revisions: Leveraging prior/existing experience with the same platform technology will facilitate expeditious development of mRNA vaccines in response to future emerging pathogens. Technologies/processes for mRNA vaccine production are not all the same among manufacturers, which has implications on the differing approaches to quality control and evaluation. Detailed information about mRNA vaccine production and quality control is either not yet available, or is proprietary. There is currently limited experience and lack of a “gold/or harmonized standard.” Flexible approaches are suggested by manufacturers given the ongoing development of the technology and lack of existing standards. |