Extraneous agents testing for substrates of avian origin and viral vaccines for poultry: Current provisions and proposals for future approaches

In the 1970s the European Pharmacopoeia (Ph. Eur.) established the first requirements for testing starting materials for vaccines and the vaccines themselves. These requirements also cover testing for freedom from extraneous agents of specific pathogen free (SPF) chicken flocks, the embryonated eggs derived from them and viral vaccines for poultry. This was the first common European approach initiated by the Ph. Eur. as an institution of the Council of Europe and it was the beginning of building a scientific basis for vaccine quality. In the following years, the increasingly detailed requirements concerning viral purity also impacted viral vaccines for poultry, SPF chicken flocks and the embryonated eggs derived from them. The core of these requirements is formed by the list of extraneous agents that must be tested for and the accepted test methods. In the early 1990s and in 2004, the next steps were taken towards the harmonisation of quality regulations for the production and testing of veterinary immunological products, this time at the level of the European Community. With the first step, good manufacturing practices (GMP) and good laboratory practices (GLP) were introduced, ensuring more consistent production, validation of production procedures and testing. The next step introduced the risk assessment, which covers the evaluation of the quality of production and control.The intention of these efforts is to contribute to the quality, safety and purity of the products placed on the market. It makes sense that, based on the outcome of the risk-evaluation, a reduction of in-process and final product testing may be called for in certain cases. However, despite the fact that the quality of the starting materials and vaccines has been increased over the years, the provisions of the Ph. Eur. have not been adjusted. Progress made by the manufacturers of starting materials and vaccines with respect to increasing the quality of their products should be recognised. This review gives an analysis of the current provisions of the Ph. Eur. and makes some proposals on how the requirements concerning the testing of extraneous agents could be modified to take into consideration the increase in quality that has been achieved over the past few decades.     

Viral safety and extraneous agents testing for veterinary vaccines: Rationale for requirements,the European approach

Freedom from extraneous agents is a high priority for any medicinal product. For veterinary vaccines, extraneous agents testing is addressed by different regulations of the European Pharmacopoeia and guidelines issued by the European Medicines Evaluation Agency. This article provides a brief review of the relevant texts.     

Extraneous agent detection in vaccines--a review of technical aspects

The quality and safety of commercial vaccines have a profound importance. Contrary to all precautions and efforts the use of biological material in vaccine development and production may lead to potential contamination of the vaccines with known and unknown extraneous agents (EAs). In veterinary field official lists of EAs have been compiled as legal framework to describe the potential agents, which must be tested during manufacture of vaccines. Nevertheless, detection of known and unknown contaminants in vaccines is a common duty for manufacturers and authorities of both veterinary and human field sharing similar needs of special technical approaches. State-of-art molecular methods such as randomly primed PCR combined with massive parallel sequencing (MPS) or microarrays may open new perspectives in extraneous agent testing. The robustness and efficacy of this technical approach in vaccine control was clearly demonstrated on a human vaccine example when porcine circovirus type 1 (PCV1) contamination was revealed in Rotarix, a human rotavirus vaccine. The consequences and implications are reviewed hereby from a veterinary regulatory point of view.     

European regulatory framework and practices for veterinary Leptospira vaccine potency testing

In Europe, the legal basis for requirements for medicinal products is described in the European Pharmacopoeia (Ph. Eur.) In the European Union, the Ph. Eur. is supplemented by several guidelines issued by the European Medicines Agency. Immunological veterinary products must comply with the Ph. Eur. monograph on veterinary vaccines and the accompanying texts, as well as specific monographs. The Ph. Eur. includes monographs on canine leptospirosis and bovine leptospirosis vaccines (inactivated). Both monographs require that an immunogenicity test be performed once in the target species during the life of a vaccine. The hamster challenge test is applied for batch potency testing of canine vaccines. Alternatively, serological tests or suitable validated in vitro tests to determine the content of one or more antigenic components indicative of protection may be performed. Vaccines for use in cattle are tested in a serological test in guinea pigs. The acceptance criteria in alternative tests are set with reference to a batch of vaccine that has given satisfactory results in the immunogenicity test. At a January 2012 European workshop, the suitability of the hamster potency test was questioned and unanimous agreement was reached that moving toward complete in vitro testing is possible and should be promoted.     

Development,standardization and assessment of PCR systems for purity testing of avian viral vaccines

The European Pharmacopoeia (Ph. Eur.) requires avian viral vaccines to be free of adventitious agents. Purity testing is an essential quality requirement of immunological veterinary medicinal products (IVMPs) and testing for extraneous agents includes monitoring for many different viruses. Conventional virus detection methods include serology or virus culture, however, molecular tests have become a valid alternative testing method.Nucleic acid testing (NAT) is fast, highly sensitive and has a higher degree of discrimination than conventional approaches. These advantages have led to the development and standardization of polymerase chain reaction (PCR) assays for the detection of avian leucosis virus, avian orthoreovirus, infectious bursal disease virus, infectious bronchitis virus, Newcastle disease virus, infectious laryngotracheitis virus, influenza A virus, Marek's disease virus, turkey rhinotracheitis virus, egg drop syndrome virus, chicken anaemia virus, avian adenovirus and avian encephalomyelitis virus. This paper reviews the development, standardization and assessment of PCR for extraneous agent testing in IVMPs with examples from an Official Medicines Control Laboratory (OMCL).     

Low levels of extraneous agents in vaccine starting materials

There are different ways to define the concept of ‘low levels’ of extraneous agents in vaccines and vaccine starting materials, based on the amount of extraneous agents as such, the sensitivity of the detection method and the probability approach linked to the sampling method. None of these approaches, however, is entirely satisfactory – a general definition of a ‘low level’ cannot be provided. Since the main point is the safety of medicinal products, the risk analysis approach to ‘low level’ contaminations can be considered as a way to overcome the abovementioned deadlock. But as too many variables impact the risk analysis, it cannot be properly performed either. In practice, seeds are tested to show freedom from extraneous agents, the other raw materials are inactivated through a validated method. However, there are technical and regulatory limits in both cases, and neither testing nor inactivation entirely guarantees freedom from extraneous agents. Despite this unsatisfactory situation, it should be acknowledged that no truly significant disease outbreak linked to an extraneous agent has been identified until today. Regulatory actions are mainly undertaken when a sanitary problem occurs. In the end, companies remain responsible for their products.     

International regulatory requirements for Leptospira vaccine potency testing. Roundtable: Current requirements and opportunity for harmonization

Progress continues to be made in the ongoing efforts to replace, reduce, or refine the use of laboratory animals for Leptospira vaccine potency testing in certain markets/regions. Leptospira-containing vaccines, as with many veterinary vaccines, are manufactured and distributed both on a regional basis by local manufacturers and internationally by large multinational firms. Three general scenarios exist for the international testing and distribution of veterinary vaccines including: 1) the importing country recognizes the country of origin's testing and batch release data with no additional testing; 2) the importing country requires the manufacturer to conduct a specific potency assay based on the current importing market's regulations for the importing country or 3) the importing country requires retesting of the product in country prior to distribution. Scenarios 2 and 3 both have the potential to significantly increase the usage of laboratory animals for what may be considered redundant testing. Specific requirements for the importation of Leptospira vaccines in the United States, Europe, and Mexico were presented as well as efforts to reduce the use of laboratory animal testing through the availability of internationally recognized tests.     

The Target Animal Safety Test—Is it Still Relevant?

In Europe, the target animal safety test (TAST) is stipulated by 52 European Pharmacopoeia monographs, by three European Union (EU) Directives and a number of EU guidelines as a routine test for veterinary immunologicals, to be carried out on the finished product. TAST data from seven European Official Member States Control Laboratories (OMCLs) and 14 manufacturers were retrospectively analysed. During 1994–1997, 11 185 vaccine batches had been submitted for batch release, and the OMCLs had tested 670 batches in the TAST (665 passed, 4 passed after retesting, 1 failed). In total, 82 of these batches were not released; however, in only one case this was due to failure in the TAST. The data received from the 14 manufacturers covered the years from 1997 to 1999. 11 386 batches were tested in the TAST, of which 215 passed after retesting and 7 failed. Although only 30% of the OMCLs provided data and the data of the manufacturers are not complete they clearly indicate that the TAST does not contribute to the safety of veterinary vaccines and should therefore not be required as a routine batch test. In cases, where it appears to be necessary, detailed guidance on the test design and evaluation should be given. Copyright 2002 Published by Elsevier Science Ltd on behalf of The International Association for Biologicals.     

Testing for viral contaminants of veterinary vaccines in Hungary

The safety of veterinary vaccines is of paramount importance and it is significantly jeopardised by extraneous agents such as bacteria, mycoplasma, Chlamydia and viruses. Several critical steps of vaccine manufacture involve a potential risk of viral contamination. Viruses, as extraneous, agents can be divided into two main groups. Group 1 agents, such as Pestivirus, chicken anaemia virus (CAV), and egg drop syndrome virus (EDSV) are well-known to manufacturers and authorities. Compendial detection methods, clear guidelines and legislation have been established to minimise the risk of contamination with these agents. Contrary to group 1, group 2 agents like Torque Teno virus (TTV) or RD114, a replication-competent feline γ-retrovirus, have only recently been recognised and their role as contaminants needs further investigation.Randomly selected veterinary vaccines used between 1992 and 2009 were tested by nucleic acid amplification for CAV, EDSV, and TTV. Pestivirus contamination was examined in 33 vaccines used between 1996 and 2006 and a further 27 vaccines used between 2007 and 2009 based on random selection of these vaccines. In addition to random tests done on vaccines used from 2007 on, 12 batches of live Aujeszky's disease vaccines submitted to our laboratory for Official Control Authority Batch Release (OCABR) were also tested for Pestivirus.     

The control of chemicals used in aquaculture in Europe

A range of chemicals are used in European marine aquaculture and these may be categorized as disinfectants, antifoulants and medicines (includes vaccines). This article provides a review of chemicals used in aquaculture in Europe, their regulatory status, and a checklist of points considered best practice in the use (and avoidance of use) of medicines in marine aquaculture. The release of antifoulants and disinfectants into the marine environment is controlled by local and/or national waste discharge regulations that may in turn be guided by wider environmental quality objectives. The authorization of veterinary medicines, biologicals (vaccines) and pharmaceuticals (chemicals), in Europe is the subject of several EC Directives. Registration dossiers address the issues of product quality, safety and efficacy and include environmental and consumer safety where the product is destined for use in a food‐producing animal. Fish farmers, like all livestock producers, must have access to a range of properly authorized medicines to safeguard animal health and welfare. The distribution and supply of medicines must be appropriately controlled and their authorization appropriately includes environmental risk assessment to a common European Union (EU) or international standard. There is progress towards the harmonization of the authorization process within the EU and this will help to ensure the continued availability of medicines for fish. Consumer safety is addressed by the setting of maximum residue limits (MRLs) derived through toxicological risk assessment and by surveillance of food for residues of veterinary medicines. The system for the environmental risk assessment of chemicals used in aquaculture is being developed and is outlined in the present article. It is recommended that the supply and use of fish medicines is uniformly regulated in the EU and supported by appropriate codes of best practice. A number of codes of practice that include reference to the use of medicines have been produced both at a European level and in member states. It is recommended that all European marine aquaculture producers adopt a code of best practice for the use of medicinal and other chemicals their industry. Medicines are one part of an integrated package in dealing with animal health. This includes environmental conditions, nutrition and hygiene. The best practice guidelines presented here are based on the outcome of three European workshops as part of the EU MARAQUA project that involved industry, government and research scientists. They cover the avoidance and minimizing of the need to use medicines and other chemicals, to recording and monitoring their use and effectiveness (in case of resistance development), exchange of experiences within the industry, and staff training. Recommendations are also included for manufacturers of medicines and other chemicals, and for regulatory authorities. Minimizing the need to use medicines and other chemicals requires attention to a healthy source of fish stock. Staff must be appropriately trained in fish husbandry (to minimize stress), hygiene and disease recognition and treatment, including management of the farm site to keep it disease free. The latter may require single generations of fish per site to allow a fallow period during which a disease or parasite cycle is broken. These recommendations and guidelines are in accordance with the current codes of practice being developed by different sectors of the aquaculture industry in different countries. They do not necessarily involve significantly higher production costs and indeed are more likely to save costs as medicines and disease impacts are very costly to industry.     

How Does Medical Device Regulation Perform in the United States and the European Union? A Systematic Review

Background

Policymakers and regulators in the United States (US) and the European Union (EU) are weighing reforms to their medical device approval and post-market surveillance systems. Data may be available that identify strengths and weakness of the approaches to medical device regulation in these settings.

Methods and Findings

We performed a systematic review to find empirical studies evaluating medical device regulation in the US or EU. We searched Medline using two nested categories that included medical devices and glossary terms attributable to the US Food and Drug Administration and the EU, following PRISMA guidelines for systematic reviews. We supplemented this search with a review of the US Government Accountability Office online database for reports on US Food and Drug Administration device regulation, consultations with local experts in the field, manual reference mining of selected articles, and Google searches using the same key terms used in the Medline search. We found studies of premarket evaluation and timing (n = 9), studies of device recalls (n = 8), and surveys of device manufacturers (n = 3). These studies provide evidence of quality problems in pre-market submissions in the US, provide conflicting views of device safety based largely on recall data, and relay perceptions of some industry leaders from self-surveys.

Conclusions

Few studies have quantitatively assessed medical device regulation in either the US or EU. Existing studies of US and EU device approval and post-market evaluation performance suggest that policy reforms are necessary for both systems, including improving classification of devices in the US and promoting transparency and post-market oversight in the EU. Assessment of regulatory performance in both settings is limited by lack of data on post-approval safety outcomes. Changes to these device approval and post-marketing systems must be accompanied by ongoing research to ensure that there is better assessment of what works in either setting. Please see later in the article for the Editors'' Summary.     

ECVAM's contributions to the implementation of the Three Rs in the production and quality control of biologicals

A summary is presented of the activities initiated, and the progress achieved, between April 1993 and December 2001 in implementing the Three Rs in one of the main priority areas of the European Centre for the Validation of Alternative Methods (ECVAM) - the production and quality control of biologicals. These have included organising eight key workshops, and financial contributions to, and sponsorship of, relevant international workshops, symposia and conferences. Noteworthy activities include financial support and/or participation in a number of prevalidation and validation studies. These involved alternative methods for the batch potency testing of: human tetanus vaccines; human and veterinary tetanus antisera and immunoglobulin; rabies vaccines; Leptospira hardjo vaccines; Clostridium perfringens vaccines; and erysipelas vaccines. They also involved a cell culture test for specific toxicity testing of diphtheria toxoid vaccines. In addition, ECVAM funded a study on the use of humane endpoints for vaccine quality control tests involving severe suffering, such as the potency testing of erysipelas, rabies and pertussis vaccines. ECVAM has also contributed financially to the compilation of manuals and expert reports, and to training in test methods. Following the report of an ECVAM Task Force, ECVAM financially supported the prevalidation of some in vitro methods for the potency testing of a recombinant hormone. A proposal is presented for promotion of regulatory acceptance, and suggestions are made for possible future activities.     

The rapid fluorescent focus inhibition test is a suitable method for batch potency testing of inactivated rabies vaccines

The European Pharmacopoeia proposes two methods for potency determination of inactivated rabies vaccines for veterinary use: The first one is a classical mouse challenge test, which is imprecise, time-consuming, and causes severe distress to the test animals. Alternatively, the potency may be determined serologically by measuring the neutralizing antibody titers induced after vaccination of mice by using a rapid fluorescent focus inhibition test (RFFIT). Although this method is faster and less painful for the animals, it is not widely used yet, and only little data exist concerning the comparability of both methods.We have therefore performed a comparative study, in which we demonstrated a good correlation between the challenge test results and the mean titers determined by RFFIT. Furthermore, all vaccine batches failing the challenge test were also recognized as insufficient in the serological assay. This publication further describes the influence of different vaccine administration routes on the resulting antibody titers, and it proposes various modifications to the serological assay protocol which could improve its overall practicability. Finally, we recommend that the serological assay be used for the potency testing of inactivated rabies vaccines.     

Exploitation of genetically modified inoculants for industrial ecology applications

The major growth seen in the biotechnology industry in recent decades has largely been driven by the exploitation of genetic engineering techniques. The initial benefits have been predominantly in the biomedical area, with products such as vaccines and hormones that have received broad public approval. In the environmental biotechnology and industrial ecology sectors, biotechnology has the potential to make significant advances through the use of genetically modified (GM) microbial inoculants that can reduce agri-chemical usage or remediate polluted environments. Although many GM inoculants have been developed and tested under laboratory conditions, commercial exploitation has lagged behind. Here, we review scientific and regulatory requirements that must be satisfied as part of that exploitation process. Particular attention is paid to new European Union (EU) regulations (Directives) that govern the testing and release of genetically modified organisms and microbial plant protection inoculants in the EU. With regard to the release of GM inoculants, the impact of the inoculant and the fate of modified genes are important concerns. Long term monitoring of release sites is necessary to address these issues. Data are reported from the monitoring of a site 6 years after release of GM Sinorhizobium meliloti strains. It was found that despite the absence of a host plant, the GM strains persisted in the soil for at least 6 years. Horizontal transfer and microevolution of a GM plasmid between S. meliloti strains was also observed. These data illustrate the importance of assessing the long-term persistence of GM inoculants. This revised version was published online in August 2006 with corrections to the Cover Date.     

Temporary derogation from European environmental legislation for clinical trials of genetically modified organisms for coronavirus disease 2019

Attempts to streamline environmental procedures for those products containing or consisting of genetically modified organisms (GMOs) among the European Union (EU) Member States are ongoing but still need to be further developed. These procedures can be complex, resource-intensive and time-consuming. Some candidate vaccines currently under development for COVID-19 include genetically modified viruses, which may be considered GMOs. Given the public health emergency caused by the COVID-19 outbreak, on July 15, 2020, the European Parliament approved a temporary derogation of the European environmental requirements to facilitate that those clinical trials with GMOs intended to treat or prevent COVID-19 can start as soon as possible in Europe. This measure has been very controversial, since it could entail risks to human health and the environment, and could be seen as unfair for other products targeting unmet medical needs. With the adoption of this measure, the bottlenecks and obstacles for the development of innovative GMO-based medicines in the EU that the environmental legislation entails have become even more evident.     

Human and animal vaccine contaminations

Vaccination is one of the most important public health accomplishments. However, since vaccine preparation involves the use of materials of biological origin, vaccines are subject to contamination by micro-organisms. In fact, vaccine contamination has occurred; a historical example of vaccine contamination, for example, can be found in the early days of development of the smallpox vaccine. The introduction of new techniques of vaccine virus production on cell cultures has lead to safer vaccines, but has not completely removed the risk of virus contamination. There are several examples of vaccine contamination, for example, contamination of human vaccines against poliomyelitis by SV40 virus from the use of monkey primary renal cells. Several veterinary vaccines have been contaminated by pestiviruses from foetal calf serum.These incidents have lead industry to change certain practices and regulatory authorities to develop more stringent and detailed requirements. But the increasing number of target species for vaccines, the diversity of the origin of biological materials and the extremely high number of known and unknown viruses and their constant evolution represent a challenge to vaccine producers and regulatory authorities.     

Particulate delivery systems for animal vaccines

The requirements for veterinary vaccines are different to those of human vaccines. Indeed, while more side effects can be tolerated in animals than in humans; there are stricter requirements in terms of cost, ease of delivery (including to wildlife), and a need to develop vaccines in species for which relatively little is known in terms of molecular immunology. By their nature particulate vaccine delivery systems are well suited to address these challenges. Here, we review particulate vaccine delivery systems, ranging from cm-sized long-distance ballistic devices to nano-bead technology for veterinary species and wildlife.     

Evaluation of the sensitivity of PCR methods for the detection of extraneous agents and comparison with in vivo testing

In this study the sensitivity of polymerase chain reaction (PCR) methods for the detection of Newcastle disease virus (NDV), avian reovirus (ARV), avian influenza virus (AIV) and avian infectious bronchitis virus (IBV) was compared to the sensitivity of the corresponding serological tests described in the European Pharmacopoeia (Ph. Eur.). For this purpose, serial 10-fold dilutions of the respective inactivated vaccines were prepared and groups of SPF chickens were vaccinated with a double dose of the vaccine dilutions. After a period of 21 days, the animals were revaccinated with a single dose. Two weeks later, serum samples from each animal were tested for antibodies using an Idexx enzyme linked immunosorbent assay (ELISA). In parallel, samples of the diluted vaccines were tested by PCR. It was found that the sensitivity of the four PCR tests is comparable to or even slightly better than that of the corresponding serological tests. Thus these PCR tests fulfil the sensitivity requirements of the Ph. Eur. and could be used as alternative tests for the detection of extraneous agents in final batches of inactivated vaccines.     

New EU legislation for risk assessment of GM food: no scientific justification for mandatory animal feeding trials

This commentary focuses on the potential added value of and need for (sub)‐chronic testing of whole genetically modified (GM) foods in rodents to assess their safety. Such routine testing should not be required since, due to apparent weaknesses in the approach, it does not add to current risk assessment of GM foods. Moreover, the demand for routine testing using animals is in conflict with the European Union (EU) Commission's efforts to reduce animal experimentation. Regulating agencies in the EU are invited to respect the sound scientific principles applied to the risk assessment of foods derived from GM plants and not to interfere in the risk assessment by introducing extra requirements based on pseudo‐scientific or political considerations.