Lessons need to be drawn from the assessment and licensing of influenza vaccines in previous years
In April 2010, Australia suspended paediatric influenza vaccinations as a result of febrile convulsions associated with seasonal trivalent influenza vaccine (TIV). Epidemiological investigations have established that the increase in febrile reactions was limited to one of three brands of TIV used in Australia that year — CSL Biotherapies Fluvax or Fluvax Junior (CSL TIV), registered as Afluria in the United States and Enzira in the United Kingdom.1–3 Health authorities in Australia estimated that the risk of febrile convulsions in children aged 6 months to 4 years after vaccination with CSL 2010 TIV ranged from 3–10 per 1000 vaccinated.1,3 This figure is remarkable because TIV has an excellent safety record in children and before 2010 was only rarely associated with febrile convulsions. The largest published population-based study found only one febrile convulsion after TIV vaccination of 45 356 children aged 6–23 months,4 giving a risk estimate of 2.2 convulsions per 100 000. Nonetheless, age-related differences in the reactogenicity of influenza vaccines and the potential for influenza vaccines to cause febrile reactions in children had been recognised for decades.5 Reviewing the regulatory history of the CSL influenza vaccine for children (Box) suggests there may be opportunities for improving the licensure of paediatric influenza vaccines.
In 2002, Australia’s Therapeutic Goods Administration (TGA) registered the thiomersal-free CSL TIV Fluvax for use in persons aged 6 months and older.6 Between 2004 and 2005, CSL TIV was approved for paediatric use in Sweden, the UK and Denmark despite a European Public Assessment Report which indicated that, at the time of initial registration in Europe, “no controlled clinical studies had been conducted in infants, young children, or young adolescents”.7 The assessment also acknowledged that the extent of CSL TIV use among paediatric populations at the time was “not well understood”.7
The first paediatric study of CSL TIV began in March 2005 as a post-licensure commitment to the Swedish Medical Products Agency.7,8 Conducted in Australia, the study involved vaccinating 298 children less than 9 years of age with two doses of the 2005 formulation of TIV.9 In the following year, 273 of the children received a “booster” dose using the 2006 TIV formulation, which had different influenza A(H3N2) and B vaccine virus antigens.9,10 The study results, published in 2009, showed a marked difference between the risk of reported fever, depending on the annual formulation of the CSL TIV administered.9 Among children less than 3 years of age, the proportion experiencing fever was 22.5% after vaccination with the CSL 2005 TIV formulation and 39.5% after vaccination with the 2006 formulation.9 For children aged 3–8 years, the proportions experiencing fever were also elevated in 2006, rising from 15.6% and 8.2% for doses 1 and 2 in 2005, respectively, to 27.0% after vaccination with the 2006 TIV formulation.9 Reanalysis of the published data shows that the increase in the proportion of children with fever after vaccination in 2006 compared with either vaccine dose in 2005 was statistically significant for both age groups (P < 0.05). In addition, two serious adverse events were reported from this study. Both reports were of fever and vomiting on the evening of vaccination with CSL 2006 TIV, with one of the children also experiencing a febrile convulsion — a clinical picture similar to the adverse events subsequently associated with CSL TIV in 2010.3,6,9
In March 2007, CSL submitted a biologics license application (BLA) to the US Food and Drug Administration (FDA) requesting approval to market TIV for adults in the US. To enhance the safety database, CSL also provided the FDA with data from the 2005–2006 Australian paediatric study. The FDA concluded that the Australian paediatric study had not identified any unusual safety concerns,8 although a separate assessment by FDA statisticians conducted later noted the small sample size and lack of comparator arm, and stated “this study was not designed to test any hypothesis”.11 In September 2007, the FDA wrote that “ . . . the pediatric study was not controlled for safety. Therefore, at this time the data will not be considered for approval in a pediatric population”.8 Accordingly, the prescribing information for the CSL TIV formulation distributed in the US for 2008–2009 stated that the “safety and effectiveness in the pediatric population have not been established”.12
The US Pediatric Research Equity Act of 2003 requires that clinical studies are conducted in children for biological products under development.8,13 As part of the accelerated approval of CSL TIV for adults in the US, CSL agreed to conduct the first randomised controlled trial of CSL TIV in children, which was scheduled to begin in August 2009 (CSLCT-USF-07-36).8
In the interim, two developments prompted the FDA to reassess the paediatric indication for CSL TIV without waiting for the results from this study. The first was a decision in 2008 by the Advisory Committee on Immunization Practices to expand the recommendation for annual influenza vaccination to include children 5 to < 18 years of age.6 The second was the onset of the influenza A(H1N1) pandemic in April 2009. Accelerated approval of CSL’s seasonal influenza vaccine for children would facilitate licensure of CSL’s monovalent pandemic vaccine for children because
an approved pediatric indication [for CSL TIV] would permit approval of the H1N1 vaccine in children as a strain change as has been done for adults, and would obviate the need for an Emergency Use Authorization in the pediatric population.6
While acknowledging the limitations of the existing data, the FDA concluded that “due to constraints related to the influenza shortage in 2004 and current concerns related to the circulating H1N1 pandemic swine flu strain, less stringent criteria for submission for BLA is acceptable”.11 Ultimately, the FDA determined that “extenuating circumstances have changed the risk benefit ratio for the pediatric indication” and recommended that CSL TIV “be granted approval in children 6 months to < 18 years of age because of newly recognized potential clinical benefit that outweigh known risks”.6
The paediatric trial of CSL 2009–2010 TIV compared with a US-licensed comparator (NCT00959049) was completed in May 2010, just weeks after suspension of childhood influenza vaccinations in Australia. Data from this unpublished study are available on the US National Institutes of Health website, albeit without statistical analysis.14 Independent examination of the data showed that children aged 6 months to < 3 years who received a first dose of CSL TIV experienced fever (≥ 37.5°C axillary or ≥ 38.0°C oral) nearly three times as often as those receiving the comparator (37% v 14%, respectively; P < 0.00005).14 In addition, children in this age cohort were significantly more likely to experience severe fever (> 39.5°C axillary or > 40.0°C oral; P < 0.05), irritability (P < 0.00005), loss of appetite (P < 0.005), or severe nausea/vomiting (P < 0.005) after receiving a first dose of CSL TIV compared with those receiving the comparator vaccine. Children aged 3 to < 9 years who received a first dose of CSL TIV were significantly more likely to experience fever (22% v 9%, respectively; P < 0.0005) and malaise (29% v 13%; P < 0.0005).14 The seasonal TIV formulation used for this trial was antigenically distinct to the formulation subsequently associated with severe febrile reactions in Australia in 2010 (specifically, the 2009–2010 northern hemisphere vaccine did not contain pandemic 2009 H1N1 strain antigens and used a different H3N2 vaccine strain).10 Taken together, data from this study and the experience in Australia in 2010 indicate that, compared with other contemporaneous TIVs, CSL TIV was associated with a higher risk of fever in children over two consecutive manufacturing seasons using different H1N1 and H3N2 viral strains.3,14 The findings from the 2005–2006 Australian study extend this observation, suggesting that CSL TIV may have been associated with a high risk of fever in children, at least intermittently, in other years.9
In hindsight, it would appear that the US decision to grant a paediatric indication for CSL TIV in 2009 without the benefit of data from a controlled paediatric clinical trial may have led to an optimistic assessment of the risks and benefits of this vaccine. The CSL TIV associated with severe febrile reactions in the southern hemisphere in 2010 was antigenically equivalent to that distributed in the northern hemisphere for the 2010–2011 influenza season.10 If Australia had not identified the safety signal in April 2010 — an event which led directly to health authority recommendations in the US and UK that CSL TIV not be administered to children aged < 5 years for the upcoming 2010–2011 influenza season — it is possible that febrile adverse reactions associated with this formulation might have been observed among children in those countries.15,16
It is nearly 3 years since the use of CSL TIV in young children was suspended, and laboratory investigations undertaken by CSL have not yet identified a definitive cause of the adverse reactions.17 CSL has acknowledged, however, that the increase in febrile adverse events in children in 2010 may have been due, at least in part, to “differences in the manufacturing processes used to manufacture CSL TIVs compared to other licensed TIVs on the market”.17 Suboptimal virus splitting or other mechanisms related to CSL’s use of deoxycholate have been suggested as possible contributing factors.18
Last year a joint working group of the Australian Technical Advisory Group on Immunisation and the TGA reviewed data on adverse events associated with different TIV brands among persons over 10 years of age and concluded that “the safety profile of many currently registered inactivated influenza vaccines is likely to differ and evidence to support this exists”.19 This observation underscores that assumptions regarding the safety of influenza vaccines may not be transferable across brands.
CSL TIV was licensed for use in children in a number of countries without the benefit of data from controlled paediatric clinical trials. The results of the only paediatric randomised controlled trial to date, conducted 7 years after thiomersal-free Fluvax was licensed for children in Australia, and Australia’s experience in 2010 demonstrate the risks inherent with this approach. Ideally, adequately powered, controlled paediatric studies should be conducted before a vaccine is licensed for children.20 Regulatory decisions on a paediatric indication for a vaccine can be challenging and are even more difficult if the safety profile of the vaccine has not been established. If circumstances do not permit a rigorous assessment of a vaccine’s safety before licensure, as could be argued for the US in 2009 with an influenza pandemic approaching, this important caveat should be communicated to providers and consumers. In addition, given that the antigenic composition of influenza vaccines often changes from year to year, comprehensive postmarketing surveillance for adverse events is essential to maintain public trust and ensure the long-term success of paediatric influenza vaccination programs.21

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