Annex 3: Recommendations To Assure The Quality, Safety and Efficacy of BCG Vaccines
Annex 3: Recommendations To Assure The Quality, Safety and Efficacy of BCG Vaccines
Annex 3: Recommendations To Assure The Quality, Safety and Efficacy of BCG Vaccines
Introduction 139
General considerations 139
Special considerations 140
Scope of the Recommendations 141
BCG vaccine strains 141
Potency-related tests 142
Part A. Manufacturing recommendations 143
A.1 Definitions 143
A.2 General manufacturing recommendations 145
A.3 Control of source materials 147
A.4 Control of vaccine production 149
A.5 Filling and containers 152
A.6 Control tests on final lot 152
A.7 Records 156
A.8 Retained samples 156
A.9 Labelling 156
A.10 Distribution and transport 157
A.11 Stability, storage and expiry date 157
Part B. Nonclinical evaluation of BCG vaccines 159
Part C. Clinical evaluation of BCG vaccines 160
C.1 General considerations 160
C.2 Special considerations 162
C.3 Post-marketing surveillance 164
Part D. Guidelines for NRAs 164
D.1 General 164
D.2 Release and certification 166
Authors and acknowledgements 166
References 170
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Appendix 1
History and genealogy of BCG substrains 174
Appendix 2
Summary protocol for manufacturing and control of BCG vaccine 175
Appendix 3
Model certificate for the release of BCG vaccine by NRAs 184
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Introduction
The last revision of the Requirements for dried bacille Calmette–Guérin (BCG)
vaccine for human use was in 1985, and an amendment which updated the
section on the expiry date was published in 1988 (1, 2). Recent WHO consultation
meetings (3–6) have addressed issues concerning the improvement of vaccine
characterization and quality control assays of BCG vaccine to reflect current state-
of-the-art technology. In addition, a recommendation to replace the International
Reference Preparation for BCG vaccine by substrain-specific Reference Reagents
evaluated by collaborative studies has been proposed. This document provides:
recommendations for the production and control of BCG vaccines (Part A);
guidelines for nonclinical evaluation (Part B); guidelines for the content of the
clinical development programme applicable to BCG vaccines (Part C); and
recommendations for NRAs (Part D). The guidelines for nonclinical evaluation
apply to classic BCG vaccine products that are still in need of such evaluation,
including newly manufactured products requiring clinical trial studies or those
produced following changes in the manufacturing process. The clinical part of this
document aims to provide a basis for assessment of efficacy and safety of BCG
vaccines in pre-licensing clinical trials as well as in post-marketing surveillance,
monitoring consistency of production and clinical testing of new classic BCG
vaccine products. If important changes have been introduced to an authorized
production process, the need for preclinical and clinical testing should be
considered on a case-by-case basis in consultation with the NRA(s) concerned.
General considerations
Tuberculosis (TB) was declared a global emergency by WHO in 1993, and
Mycobacterium tuberculosis (M. tuberculosis) is now considered to be responsible
for more adult deaths than any other pathogen. Vaccination with BCG still
remains the standard for TB prevention in most countries because of its efficacy
in preventing life-threatening forms of TB in infants and young children. It is
inexpensive and usually requires only one administration in either newborns or
adolescents (7, 8). As there is currently no suitable alternative, BCG will remain
in use for the foreseeable future and may continue to be used as a prime vaccine in
a prime-boost immunization schedule in conjunction with new TB vaccines (4).
BCG vaccine contains a live, attenuated strain of M. bovis that was
originally isolated from cattle with tuberculosis and cultured for a period of 13
years and a total of 231 passages (7). The BCG vaccine was first used to immunize
humans in 1921. Following its introduction into the WHO Expanded Programme
on Immunization (EPI) in 1974, the vaccine soon reached global coverage rates
exceeding 80% in countries endemic for TB (9).
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Over the years, different BCG vaccine seed strains have evolved from the
original vaccine strain for production. A number of BCG vaccine strains that
are used worldwide differ in terms of their genetic and phenotypic properties,
and their reactogenicity and immunogenicity profile when given to infants
and children. With this background of a diversity of substrains, manufacturing
processes, immunization schedules and levels of exposure to environmental
mycobacteria and virulent M. tuberculosis infection, different levels of protective
efficacy of BCG vaccines in adult populations have been reported (10). However,
the data are insufficient to make recommendations on whether one strain should
be preferred over the other (11). The United Nations agencies are the largest
supplier of BCG vaccines, distributing more than 120 million doses each year to
more than 100 countries. Worldwide, the most commonly used vaccine strains
are currently Danish 1331, Tokyo 172-1 and Russian BCG-I because they are
supplied by the United Nations Children’s Fund (UNICEF) which purchases the
vaccines through a published prequalification process which determines their
eligibility for use in national immunization programmes (12).
There has been particular concern over the safety of BCG vaccination
in subjects infected with the human immunodeficiency virus (HIV) (8). WHO
previously recommended that in countries with a high burden of TB, a single
administration of BCG vaccine should be given to all healthy infants as soon as
possible after birth, unless the child presented a symptomatic HIV infection (9).
However, recent evidence shows that children who were HIV-infected when
vaccinated with BCG at birth, and who later developed acquired immunodeficiency
syndrome (AIDS), were at increased risk of developing disseminated BCG
disease. Among these children, the benefits of potential prevention of severe TB
are outweighed by the risks associated with the use of BCG vaccine; thus the use
of BCG vaccines at birth in relation to HIV-infected infants should follow the
recommendations of the Global Advisory Committee on Vaccine Safety (GACVS)
(13, 14).
WHO Technical Report Series No. 979, 2013
Special considerations
The formulation of international requirements for freeze-dried BCG vaccine is
complicated by the following: (a) a number of different substrains derived from
the original strain of BCG are used in vaccine manufacture; (b) a number of
different manufacturing and testing procedures are employed; (c) it is difficult to
identify a link between significant differences in vitro and in vivo between different
BCG vaccine strains and any possible differences in protective efficacy against
TB in humans; (d) vaccines are produced with different total bacterial content
and numbers of culturable particles; and (e) vaccines intended for administration
by different routes are prepared. Therefore, the following considerations should
be borne in mind regarding the scope of these recommendations, BCG vaccine
strains, and potency-related tests.
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Potency-related tests
There is some evidence that BCG seed lots that have been shown to produce
vaccines with protective potency in laboratory animals and tuberculin sensitivity
WHO Technical Report Series No. 979, 2013
the conversion takes place. In these animal tests, the inclusion for comparative
purposes of an in-house reference BCG vaccine prepared from a seed lot known
to be effective in animals and humans is recommended.
Currently there is no biomarker which directly correlates to clinical
efficacy of BCG vaccine. These Recommendations are intended to be used for
ensuring the manufacture of consistent lots. This means that new lots should
not significantly differ from those that have already been shown to be safe and
effective in humans.
At present, for batch control purposes, much reliance is placed on tests
for the estimation of the total bacterial content and for the number of culturable
particles. It is not possible to specify single requirements for the total bacterial
content and for the number of culturable particles for all vaccines (24), since
different substrains and methods of manufacture may yield different specifications
for these parameters. For example, although the number of culturable bacteria in
a single human dose may differ for different vaccines, these vaccines may show
satisfactory properties as regards their ability to induce adequate sensitivity to
tuberculin and their safety in humans. It is therefore essential that clinical studies
for dose optimization in humans be carried out to estimate suitable total bacterial
contents and the number of culturable particles for a particular manufacturer’s
product. For a particular vaccine, the difference between the lower and upper
specification for the number of culturable particles should not be larger than
fourfold. In addition, it is necessary to perform animal experiments that give an
indication of the safety and efficacy of the vaccines to the satisfaction of the NRA.
A.1.4 Terminology
The definitions given below apply to the terms as used in these Recommendations.
They may have different meanings in other contexts.
Final bulk: the homogeneous finished liquid vaccine present in a single
container from which the final containers are filled, either directly or through
one or more intermediate containers derived from the initial single container.
Final lot: a number of sealed, final containers that are equivalent with
respect to the risk of contamination during filling and, when it is performed,
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freeze-drying. A final lot should therefore have been filled from a single container
and freeze-dried in one continuous working session.
In-house reference: a batch of vaccine prepared from the same BCG
strain as the tested vaccine and used in parallel to the vaccine tested in:
■ quantitative assays such as viability estimates (such as culturable
particle count and modified ATP assays);
■ residual virulence assays.
Master seed lot: a bacterial suspension of a single substrain originated
from the bacillus of Calmette and Guérin that has been processed as a single lot
and is of uniform composition. A seed lot should be maintained in the freeze-
dried form stored at –20 °C or below (in the liquid form it is stored at –80 °C
or below) in order to maintain viability. In each manufacturing establishment, a
master seed lot is that from which material is drawn for inoculating media for the
preparation of working seed lots or single harvests.
Single harvest: the material obtained from one batch of cultures that
have been inoculated with the working seed lot (or with the inoculum derived
from it), harvested and processed together.
Working seed lot: a quantity of bacterial organisms of a single substrain
derived from the master seed lot by growing the organisms and maintaining
them in aliquots in the freeze-dried form stored at –20 °C or below (in the liquid
form stored at –80 °C or below). The working seed lot should be prepared from
the master seed lot by as few cultural passages as possible (e.g. 3–6 passages from
the master seed lot), having the same characteristics as the master seed lot and
intended for inoculating media for the preparation of single harvests.
that a formal clinical lot-to-lot consistency study is not necessary if there are
adequate and satisfactory data provided to support consistency of manufacture.
However, several different lots of the product should be used in randomized
studies and should elicit comparable immune responses in similar populations.
The degree of consistency in producing satisfactory final lots is an
important factor in judging the efficacy and safety of a particular
manufacturer’s product.
that should take place in dedicated facilities are all operations up to and including
the sealing of the vaccine in the final containers.
In some countries, the production of BCG vaccine – although isolated –
is carried out in a building in which other work takes place. This should
be done only after consultation with, and with the approval of, the NRA.
If production takes place in part of a building, the work carried out in
other parts of the building should be of such a nature that there is no
possibility of cross-contamination with the BCG vaccine.
vaccine not less than 50 single human doses and should be observed for at least
six weeks. If none of the animals shows signs of progressive TB and at least 90%
survive the observation period (i.e. should one of the 10 animals die), the seed lot
should be considered to be free from virulent mycobacteria.
If more than 10% of the guinea-pigs die during the observation period
(i.e. should two out of 10 animals die) and freedom from progressive TB disease
is verified, the test should be repeated on at least 10 more guinea-pigs. On the
second occasion, the seed lot passes the test if not more than 10% of the animals
die during the observation period (i.e. should one of the 10 animals die) and the
autopsy does not reveal any sign of TB.
1
When a more concentrated vaccine, intended for administration by the percutaneous route, is tested, a
dilution factor approved by the NRA should be applied so that the mass of BCG injected corresponds to at
least 50 human doses of intradermal vaccine.
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animal dies during the observation period and the autopsy does not reveal any
sign of TB.
Should a vaccine lot fail to satisfy the requirements of this test because
animals die from causes other than TB, the procedure to be followed by
the manufacturer should be determined with the approval of the NRA.
If signs of TB disease are seen, the vaccine lot should be rejected, all subsequent
vaccine lots should be withheld, and all current vaccine stocks should be held
pending further investigation. The manufacture of BCG vaccine should be
discontinued and it should not be resumed until a thorough investigation has
been made and the cause or causes of the failure determined and appropriate
actions have been taken. Production should be allowed to resume only upon the
approval of the NRA.
2
The International Reference Preparation of Opacity is in the custody of the NIBSC, Potters Bar, England,
which supplies samples on request.
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appearance and residual moisture tests. The diluent supplied or recommended for
reconstitution should be used, unless such diluent would interfere with any of the
tests, in which case some other suitable fluid should be used. The vaccine should
be reconstituted to the concentration at which it is to be used for injection into
humans; however, an exception may be made in the case of the test for absence
of virulent mycobacteria (Part A, section 6.4.1), when a higher concentration
of reconstituted vaccine may be necessary. It would be appropriate to monitor
periodically the antimicrobial sensitivity in final lots.
The survival rate after freeze-drying is usually not less than 20%.
Since ATP is present in all living cells and is immediately destroyed when
the cell dies, ATP is a reliable marker for living cells.
All manufacturers should keep their product for the approved storage period
and should determine the number of culturable particles from time to time to
demonstrate that the number is being maintained at an adequate level.
In some countries, the thermal stability test is carried out only after the
vaccine has been stored for 3–4 weeks after freeze-drying, since it is
considered that the degree of stability during the first three weeks may
not be related to the long-term stability of the product.
A.7 Records
The recommendations in section 8 of Good manufacturing practices for biological
products (28) should apply.
Written records should be kept of all seed lots, all cultures intended for
vaccine production, all single harvests, all final bulk vaccines, and all vaccine in
the final containers produced by the manufacturing establishments, including
all tests irrespective of their results.
The records should be of a type approved by the NRA. An example of a
suitable protocol is given in Appendix 2.
A.9 Labelling
The recommendations in section 7 of Good manufacturing practices for biological
products (28) should apply, including the following guidance.
The label, and/or the packaging insert in some countries, printed on or
affixed to each container should show the volume and nature of the diluent. Also,
this label, or the label on the carton holding several final containers, or the leaflet
accompanying the containers, should carry the following additional information:
■ the fact that the vaccine fulfils the requirements of this document;
■ instructions for use of the vaccine and information concerning
contraindications and the reactions that may follow vaccination;
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The label for the diluent should state “Reconstituting fluid for BCG
vaccine [proprietary name]”.
Historically the use of ampoules sealed under vacuum was the most
common practice for increasing stability. However, vacuum-sealing is
difficult compared to sealing in the presence of inert gas. There were
no significant differences between BCG vaccines sealed under vacuum
and under nitrogen or carbon dioxide at either 4 °C or 37 °C (41).
Manufacturers now prepare BCG vaccines in vials/ampoules and, under
well-validated conditions, the product is adequately stable.
If there are two pharmacologically relevant species for the clinical candidate (one
rodent and one non-rodent), both species should be used for short-term (up to one
month duration) toxicology studies. If the toxicological findings from these studies
are similar in both species, longer-term studies in one species are usually considered
sufficient; the rodent species should be considered unless there is a rationale for
using non-rodents. Studies in two non-rodent species are not appropriate. Other
in vivo studies should address both potency (such as tuberculin sensitivity and
immunological tests) and safety issues (such as tests for excessive dermal reactivity
and absence of virulent mycobacteria) of the classical BCG vaccines.
It may be of benefit for new BCG vaccine developers to consider the
points raised in recent meetings establishing recommendations for new live
vaccines against TB (51, 52).
In the case of certain vaccines, it has been revealed that there is a strong correlation
between the incidence of these complications in newborns and the number of
culturable particles in the vaccine.
The concentration of the vaccine should be shown to be effective and
tolerated in the age groups for which the vaccine is intended.
A reduction of the dose for newborns may be based on the evidence and
approved by the NRA (57).
safety and protective efficacy of the vaccine. However, for such a new classical
BCG vaccine product, comparative studies with an existing licensed BCG vaccine,
using immunological responses as a marker for efficacy, may be acceptable to the
responsible NRA.
Comparable PPD response (proportion of PPD converters, intensity of
response) may be acceptable.
Clinical studies should provide evidence of safety in all the potential target
populations, including those with a high incidence of diseases that may affect the
safety or efficacy of the new vaccine product. In phase I and phase II studies this
should include evaluation of:
■ safety and reactogenicity in healthy adults (comparative);
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■ end-points;
■ safety and reactogenicity – can include healthy HIV-infected adults;
■ immune responses – non-inferior PPD response, and may include
other immunological markers.
These studies are difficult to interpret as adults will most likely have
received BCG vaccination at birth. Dose-finding studies may be considered
unnecessary for these vaccines. The safety in HIV-infected individuals
and in infants needs to be considered.
Dose-finding and age de-escalation can be included in these studies, but review
at each step by a suitable independent safety committee should be considered.
In phase III studies evaluation should be made of:
■ safety and reactogenicity in infants (comparative)
■ end-points
■ safety and reactogenicity
■ non-inferior PPD immune response.
3
An intradermal test with a dose of tuberculin equivalent to 5 IU of tuberculin PPD is suitable. A description
of an appropriate method and a design for a study to assess BCG vaccines in humans are available on
application to the World Health Organization, 1211 Geneva 27, Switzerland.
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WHO Expert Committee on Biological Standardization Sixty-second report
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Appendix 1
History and genealogy of BCG substrains
WHO Technical Report Series No. 979, 2013
Note: This diagram provides only a historical overview of the use of different substrains derived from BCG vaccine
strain. It does not indicate any WHO “qualification” or “approval” of the strains or vaccines in the context of this
document.
* Yamamoto S, Yamamoto T. Historical review of BCG vaccine in Japan. Japanese Journal of Infectious Disease, 2007,
60:331–336.
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Annex 3
Appendix 2
Summary protocol for manufacturing and control of BCG
vaccine
The following protocol is intended for guidance, and indicates the information that
should be provided as a minimum by the manufacturer to the NRA. Information
and tests may be added or omitted as required by the NRA, if applicable.
It is thus possible that a protocol for a specific product may differ in
detail from the model provided. The essential point is that all relevant details
demonstrating compliance with the licence and with the relevant WHO
recommendations of a particular product should be given in the protocol
submitted.
The section concerning the final product must be accompanied by
a sample of the label and a copy of the leaflet that accompanies the vaccine
container. If the protocol is being submitted in support of a request to permit
importation, it must also be accompanied by a lot release certificate from the
NRA or NCL of the country in which the vaccine was produced stating that the
product meets national requirements as well as Part A of the recommendations
of this document published by WHO.
Production information
A genealogy of the lot numbers of all vaccine components used in the formulation
of the final product will be informative.
The following sections are intended for the reporting of the results of
the tests performed during the production of the vaccine, so that the complete
document will provide evidence of consistency of production. Thus, if any test has
to be repeated, this must be indicated. Any abnormal results should be recorded
on a separate sheet.
on master and working seed lots are required on first submission only and whenever
a change has been introduced.
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WHO Expert Committee on Biological Standardization Sixty-second report
20–25 °C
30–36 °C
Negative
control
178
Annex 3
20–25 °C
30–36 °C
Negative
control
Date of freeze-drying:
Number of containers rejected during inspection:
Number of containers sampled:
Total number of containers (net):
Maximum period of storage approved:
Storage temperature and period:
Result:
Recommended reconstitution fluid:
Volume of reconstitution fluid per final container:
20–25 °C
30–36 °C
Negative
control
Specification:
Result:
Specification:
Result:
Details of working Reference Preparation:
1
With the exception of provisions on distribution and shipping, which the NRA may not be in a position
to assess.
2
WHO Technical Report Series, No. 979, Annex 3.
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WHO Expert Committee on Biological Standardization Sixty-second report
Appendix 3
Model certificate for the release of BCG vaccine by NRAs
Lot release certificate
Certificate no.
1
Name of manufacturer.
2
Country of origin.
3
If any national requirements are not met, specify which one(s) and indicate why release of the lot(s) has
nevertheless been authorized by the NRA.
4
With the exception of provisions on distribution and shipping, which the NRA may not be in a position
to assess.
5
WHO Technical Report Series, No. 979, Annex 3.
6
WHO Technical Report Series, No. 961, Annex 3.
7
WHO Technical Report Series, No. 822, Annex 1.
8
WHO Technical Report Series, No. 978, Annex 2.
9
Evaluation of summary protocol, independent laboratory testing, and/or specific procedures laid down in
defined document etc., as appropriate.
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Annex 3
■ type of container;
■ number of doses per container;
■ number of containers/lot size;
■ date of start of period of validity (e.g. manufacturing date) and/or
expiry date;
■ storage condition;
■ signature and function of the authorized person and authorized
agent to issue the certificate;
■ date of issue of certificate;
■ certificate number.
The Director of the NRA (or other authority as appropriate):
Name (typed)
Signature
Date
185