Thank you very much for this opportunity to speak to the committee.
As you've already heard from Dr. Butler-Jones, Health Canada authorized Arepanrix on October 21. This is the adjuvanted vaccine manufactured by GSK, GlaxoSmithKline, for use against the H1N1 flu virus. This authorization was made under an interim order.
An interim order is issued by the Minister of Health under the authority of the Food and Drugs Act in rare situations when the minister believes that immediate action is required to deal with a significant risk, direct or indirect, to human health, to public safety, or the environment. This interim order enabled Health Canada to authorize the vaccine based on human clinical data available at the current time. Based on Health Canada's review of the available data on quality, safety, and efficacy—in this case, its immunogenicity—and given the World Health Organization's declaration of an influenza pandemic and its risk to human health, Health Canada considers the benefit-risk profile of the vaccine as favourable for immunization against a pandemic strain.
Canada, like many other countries worldwide, exercises tight regulatory oversight over all vaccines, because they're usually given to very large numbers of healthy individuals. All vaccines made available to Canadians are subject to a strict authorization process conducted by Health Canada, the regulatory authority in Canada. In order to fulfill its mandate, Health Canada—which is the regulator, as I said—works in collaboration with the Public Health Agency of Canada, which itself provides health advice to Canadians.
To put the regulatory system into perspective, I'll very briefly describe some of Health Canada's activities on the vaccine side, activities that apply to a whole range of different vaccines, not just to the pandemic one. This is for the child and adult populations.
Prior to the approval of a new vaccine, the manufacturer must file a submission with scientific and clinical evidence demonstrating that the vaccine's health benefits outweigh the risks and that the vaccine is effective and suitable for use in Canadians.
Clinical trials that take place in Canada must also be approved by the regulator before their commencement. However—and I think this is quite important—it is not necessary for trials to be conducted in Canada in order for a vaccine to be eventually authorized here. Adherence to internationally accepted standards of good clinical practice helps ensure that clinical trials conducted in other countries meet the same high standards of evidence needed to support authorization in Canada. With clinical trials, the issue is the quality of the science, not where the science has been done.
All clinical data, regardless of where the trials are conducted, will be evaluated with data from laboratory and animal studies as well. Furthermore, as part of the overall approval processes, Health Canada conducts an evaluation of the manufacturer's facilities to assess the quality of the vaccine manufacturing process and determines the manufacturer's ability to carry out the necessary quality control studies on the vaccine. The manufacturer must also provide samples of the vaccine for testing by Health Canada.
Once the evaluation is completed, and if the conclusion is that the benefits of a vaccine outweigh any potential risks, then the vaccine is granted market authorization and can be sold in Canada. After approval, however, Health Canada continues its regulatory oversight by conducting its own independent testing as part of a lot release program before each lot is released onto the market. An inspection of the manufacturer's facilities is also conducted regularly—at least every two years—to make sure they're following the very best practices for drug manufacturing.
Potential adverse events with the vaccine are also monitored, this time by the Public Health Agency of Canada through active and passive surveillance. However, there are unique challenges associated with the development and regulatory evaluation of influenza vaccines. Each year the influenza vaccine must be remade to reflect the strain of the virus the WHO believes will be circulating that year. The time between the completion of the manufacturing and the need to get the vaccine into the arms of Canadians to provide immediate protection is always short. Health Canada works closely, therefore, with manufacturers to help minimize any delays.
While challenges are the norm in dealing with influenza vaccine regulation, these are magnified in a pandemic situation considerably. Influenza pandemics are actually caused by novel strains that have not previously circulated. A key challenge the regulatory authorities worldwide have had to deal with—this is not peculiar to Canada—is how to conduct clinical evaluation for safety and efficacy of a vaccine in the absence of disease and prior to the start of a pandemic. You cannot just manufacture or test a vaccine against a disease that doesn't yet exist.
For this reason, both Health Canada and the Public Health Agency of Canada have been proactively preparing for a pandemic for several years. The Canadian pandemic influenza plan has built in a balance between the need to provide access to a pandemic vaccine in a timely manner and the need to gather as much information as we can on vaccine quality, safety, and effectiveness.
A key component of this preparatory work has been close collaboration with the contract vaccine manufacturer GSK to complete as much of the process as necessary for the evaluation of a pandemic vaccine in advance of the declaration of a real pandemic. In this period, what you might call the pre-pandemic period, Health Canada evaluated potential pandemic or mock H5N1 avian vaccine that was produced by the manufacturer, and this enabled Health Canada to inspect the vaccine manufacturing facilities and review results from both animal and human studies with the mock vaccine. These activities were performed to assess the quality, safety, and efficacy of the vaccine, which all contribute, really, to the overall safety of the product. The idea was that the development of a regulatory evaluation of the prototype vaccine would facilitate the approval of a pandemic vaccine once the pandemic stream was identified and production started.
The GSK adjuvanted vaccine consists, as we've already heard, of two components, an antigen and the adjuvant. The antigen is the active component, an ingredient in the vaccine, or the immunizing part, which provides protection against the virus. The adjuvant is a substance added to the vaccine to boost the immune response. Adjuvanted vaccines may also provide broader cross-protection against mutating flu virus strains. Adding the adjuvant contributes also to what is called dose sparing, which allows for larger amounts of the vaccine to be produced because less antigen is used.
During the pre-pandemic period, the safety and effectiveness of the adjuvant to be used with the vaccine was assessed by both Health Canada and other regulatory agencies worldwide. Clinical trials on the adjuvant were conducted in the United States, Canada, Europe, and so on, and included over 13,000 patients. Data from additional trials conducted by GSK in Europe, which combined this same adjuvant with a seasonal influenza vaccine, were also assessed. Now overall, this adjuvant has been evaluated in around 40,000 to 45,000 individuals worldwide. No serious safety concerns regarding the use of the adjuvant have been detected.
A similar adjuvant has been used safely in Europe since 1999 in an influenza vaccine manufactured by the company Novartis, which is a licensed vaccine. Furthermore, the World Health Organization held a consultation early in June, from all the world regulators, on the safety of the adjuvanted vaccine, the conclusion of which was that there were no significant safety concerns or barriers to the use of adjuvanted vaccines in the current H1N1 virus situation.
In Canada, the pandemic vaccine file is what's called a rolling submission, which means that Health Canada has been reviewing data on an ongoing basis--as it becomes available, essentially--and it will continue to do so and review any additional information from the ongoing studies immediately upon receipt.
Quality, which means the chemistry and manufacturing of the vaccine, are the data that are used to indicate that the vaccine is produced with the H1N1 strain and it has been manufactured in accordance with the usual high standards expected of vaccines in Canada. Safety information for the H1N1 vaccine has been reviewed from studies in animals as well as clinical studies in around 900 individuals, to ensure that the vaccine has an acceptable safety profile for use in humans, and that the vaccine produced is an adequate immune response.
Both the safety of the antigen and adjuvant were considered. However, because it was recognized that the vaccine would need to be made available before extensive safety studies could be completed, additional studies and surveillance will continue post-market in order to detect any change in the incidence of adverse events or special interests, such as Guillain-Barré syndrome or any other rare adverse events. GSK's clinical development plan includes trials across Europe, the United States, and Canada, and it will also include resulting safety and effectiveness data in a further 10,000 people, approximately.
Data from clinical trials have become available globally during the authorization process. Using similar or related pandemic vaccines was also considered in this period. Clinical trial results from the United States, Europe, Australia, and China supported vaccine safety and effectiveness, and with no serious adverse events--we looked at all those as well. Canadian clinical trials of the GSK H1N1 pandemic vaccine are under way, and promising early results have already started to come in to us.
As you have already heard, a non-adjuvanted H1N1 pandemic vaccine is also being manufactured by GSK as part of its contract with the Government of Canada. Health Canada is also reviewing available data to support the quality, safety, and efficacy of this non-adjuvanted version as it becomes available.
Now, maximizing the quality, safety, and efficacy of vaccines is well recognized as really an essential component of any successful immunization program. Vaccines have an excellent safety record. However, we all know that rare adverse events cannot be detected until the vaccines are given to very large numbers of individuals. And these occur even when the very best regulatory controls are in place. There are instances where adverse events may occur following immunization. So further investigation is key, really, to determining if the reaction was directly or causally, as we say, related to the vaccine or not. This is an important way of investigating this.
Due to the uniqueness of the pandemic situation, all of the safety and clinical effectiveness data regularly required were not available at the time of licensure. This is the case in Canada and in all other jurisdictions. Major regulatory agencies, including Health Canada, have developed review processes specifically as part of their pandemic planning. As a result, a carefully designed post-market surveillance plan is a critical component in order for Health Canada and the Public Health Agency to monitor the safety and effectiveness of the vaccine and to communicate any adverse events following immunization in a very timely manner.
Now, a pandemic is a global issue that requires collaborative international response. It's not peculiar to Canada. As noted previously, Health Canada and the Public Health Agency, in close collaboration with other national regulatory and public health authorities, have been preparing for many years to deal with this situation. So between 2006 and 2007, Health Canada initiated and hosted regulatory preparedness workshops with the U.S. Food and Drug Administration and the World Health Organization. These workshops resulted in the development of what is now called the WHO guidelines on regulatory preparedness for human pandemic influenza vaccines and the creation of a global network of about 10 influenza vaccine regulators. These are the key global regulators.
Since the H1N1 virus emerged, the WHO has been hosting biweekly telephone conferences with this vaccine regulators network. In addition, Health Canada has been participating in biweekly multilateral discussions with the USFDA, the European Medicines Agency, the Australian Therapeutic Goods Administration—the regulator in Australia—and Japan to discuss clinical development plans and pharmaco-vigilance of the H1N1 vaccines.
Most importantly, there is a global commitment amongst this group to share clinical and safety data on the H1N1 vaccines in real time. This enables countries to maximize the amount of data available to support vaccine approval and rapidly share information on potential adverse events following immunization. This has already started and will continue to inform vaccine policy decisions worldwide as time progresses.
Vaccines are only authorized if the benefits outweigh any risks, be they real or theoretical. In the case of the H1N1 pandemic vaccine, as part of the authorization the manufacturer is required to submit and adhere to a risk management plan. The plan includes a list of adverse events of special interest, such as Guillain-Barré syndrome, which would develop by consensus between the WHO and major regulatory authorities around the world, and these adverse events will be monitored when the vaccine is rolled out.
The manufacturer will also be required to continue conducting clinical studies and to submit monthly safety reports to the government. The continued clinical trials will focus on assessing vaccine safety and effectiveness especially in specific population groups. And all lots of pandemic vaccine will be tested in Health Canada laboratories before they are released for the Canadian market.
Let me conclude by saying that the regulator has not really cut corners in the regulatory process here to verify the safety and effectiveness of this vaccine. A lot of work has gone into evaluating this vaccine.
Thank you very much.