4 RESEARCH, DEVELOPMENT AND
PROCUREMENT
VACCINES
65. Vaccines are available for a surprisingly small
number of infectious agents, around 10% according to PowderJect.
We heard from Gail Cassel from Eli Lilly in the US that only two
vaccines were available for the 13 agents on the A List (see Table
3). If vaccines are to be a major biodefence tool then a concerted
research effort will be required into a range of agents that have
so far received little attention owing to their low prevalence
in the populations of developed countries. The US National Institutes
of Health has recognised this by establishing a new Vaccine Research
Center with an annual budget of $50 million. We were told during
our visit in May 2003 that the Center was set up with HIV as its
primary target but that biodefence was now an important objective
also. The House of Lords Science and Technology Committee reports
that pharmaceutical companies invest 10 or 20 times less money
in vaccine R&D than in therapeutics.[59]
PowderJect reports that while the timescale for developing a bioweapon
on an industrial scale is 3-5 years, it takes 12-15 years to develop
a vaccine.[60]Table
3: Development of vaccines for A list agents.[61]
| Agent
| Properties
| Current vaccines
|
| Anthrax
| Non-contagious spore forming bacteria; inhalation anthrax toxaemia is lethal; 70-100% fatality if left untreated
| Anthrax vaccine with 5-6 doses over 12-18 months with annual booster available; may respond to ciproflaxacin if treated early
|
| Smallpox
| Highly contagious DNA virus; variola major; 30% mortality
| Wyeth: DryVax 1 shot live vaccine 10 years+; safety concerns in elderly; no known cure; treatment with antivirals may have some efficacy
|
| Plague |
Pneumonic plague; highly contagious bacterium Yersinia pestis; 80-100% mortality
| No commercially available vaccine; may respond to aminoglycosides if treated early
|
| Botulism
| Non-contagious, spore-forming bacteria; toxin is lethal if enters water or food supply
| No vaccine: antiserum or immunglobulin in short supply
|
| Tularaemia
| Francissella tularensis, a highly infective non-contagious intracellular bacterium
| Experimental live attenuated vaccine available; If treated early will respond to antibiotics
|
Viral haemorrhagic
fevers
| Arenaviruses; Lassa fever, bunyaviruses; Rift Valley fever, filoviruses; Ebola, haemorrhagic flaviviruses; yellow fever: carried by insect or rodent vectors; highly fatal
| No vaccines exist except for yellow fever and Korean haemorrhagic fever; ribavirin against hantavirus; no effective therapies
|
66. Dstl Porton Down has a vaccine programme as does its close
neighbour CAMR. Dr Scott told us that "We are undertaking,
and have been since the last Gulf War, a number of medical countermeasures
development programmes to try and ensure in the biodefence area
that we produce rapid acting effective vaccines". This includes,
with the DoH, work on the development of the smallpox vaccine
and new generations of anthrax and plague vaccines.[62]
We were told by Dr Scott that he was working "very closely
with our US counterparts in the DoD [Department of Defense] to
generate a whole panel of defence vaccines".[63]
The holy grail of vaccine development is the production of a generic
vaccine that provides protection against a wide range of pathogens.
We understand that Dstl is active in this pursuit. The vaccine
development work by Dstl Porton Down would seem to bring closer
the prospect of protection for civilians against several of the
A List agents, but Dr Scott was cautious: "the strategy for
producing vaccines in a military context is totally different
from that which it would be in a civilian scenario".[64]
67. There has been a lot of public attention on vaccines.
But, as Dr Scott said, their role needs careful thought before
large amounts are invested: "Many of the current vaccines
take a long time to establish immunity. Are we going to go and
immunise our populus with fifteen different vaccines on the off-chance
there might be a bioterrorism event using these materials?
you need to do the thinking first and then work out where you
can spend the money".[65]
The amount of money is substantial. As Dr Penn pointed out, "the
science is there to attempt to develop safe and effective treatments
or vaccines for a wide range of organisms but the risk and cost
of doing so for each and every case is very high".[66]
According to PowderJect, the cost of developing a new vaccine
could be in excess of $350 million.[67]
68. A further problem is ensuring that large numbers
of doses are available in the event of a bioterrorist attack.
Either large volumes are stockpiled or there needs to be the capability
to produce large amounts very quickly.
69. We share Dr Scott's concern that too much attention
may be given to vaccination. Nevertheless, it is prudent to marshal
available resources without compromising research programmes into
vaccines for infectious diseases such as HIV, malaria or even
SARS. The decision by DoH to ask CAMR to provide a Strategic Response
Capability to concentrate on those micro-organisms rarely encountered
in the UK seems sensible.
Rapid Response Vaccine Facility
70. In September 2002 CAMR submitted to the DoH a
draft business case for a Rapid Response Vaccine Facility. The
proposal was for the design and build of a state-of-the-art manufacturing
facility capable of operating at Pathogen Containment Levels 3
and 4 (the degree to which the worker is protected from the agent)
and suitable for process development and production of vaccines
for emergency use. The projected cost was £30 million.
71. The Government has not accepted the business
case in its current form. Hazel Blears, giving evidence to the
House of Lords Science and Technology Committee on 8 April 2003,
said that the DoH was keen that the development time should be
reduced below six months and they had concerns about the cost.
Ms Blears said "That does not mean the door is closed on
it and I am certainly still happy to consider it with advice from
the HPA and to see if there is a way forward on this". The
House of Lords Science and Technology Committee did not give explicit
support to the proposal in its report Fighting Infection
but said it was pleased that the DoH would consider a further
submission.[68] Dr Pat
Troop, Chief Executive of the Health Protection Agency told us
that the proposal "was not turned down, but there were some
issues in the business plan that we felt needed further clarification
and discussion".[69]
Dr Harper from the DoH told us that "we have asked specifically
that the Health Protection Agency considers the vaccine production
facility in the round, looking at what is available in dialogue
with industry and with the wider academic community as well".
72. The evidence we have received on the proposal
from the pharmaceutical industry displays little enthusiasm. Philip
Wright from the Association of the British Pharmaceutical Industry
(APBI) said "I think it would be very interesting if a public
body could actually out-compete some highly competitive industries
across the globe".[70]
Nick Higgins from Acambis questioned the proposed speed of development.
He said that his company had been able to produce a bottled vaccine
within 10 months of getting the contract: "CAMR typically
has not worked at that sort of breakneck speed and I think generally
industry tends to work faster".[71]
Dr Scott from Dstl dismissed the idea that the public sector could
not match the speed of industry, but tellingly, he refused to
be drawn on the merits of the facility, maintaining that "we
need to establish the case".[72]
73. We too have concerns about the creation of a
Rapid Response Vaccine Facility. There is merit in a publicly
funded vaccine development facility. As the APBI indicated, "only
a few member companies in the UK have category three facilities
and none have category four", which are necessary for handling
the most dangerous biological agents. CAMR has many qualities
but we believe that this venture would be better conceived as
a partnership between CAMR and industry. Given the Government's
policy of keeping the pharmaceutical industry at arms' length
on this issue, this was not an avenue that CAMR could pursue.[73]
John Hutton indicated that the DoH was planning a more constructive
(and long-overdue) dialogue with industry. This is an opportunity
to rethink the proposed Rapid Response Vaccine Facility. We
recommend that the HPA develop with industry a fast efficient
vaccine production facility which combines a service to the tax-payer
and benefits participating companies. This should form part of
a long-term vaccine development strategy for Government.
Vaccination policy
74. While vaccines generally offer better protection
against infection if administered before exposure, they can have
value in limiting the effects after exposure. In the case of smallpox,
current vaccines can keep a patient alive although they do not
prevent them being carriers, which has implications for restricting
the spread of the disease. The DoH have published a smallpox strategy,
based upon regional teams of vaccinated staff, ring-fenced vaccination
around any outbreak and the procurement of additional vaccine
stocks. The Prime Minister said that the Government's policy on
smallpox vaccination was consistent with WHO guidelines.[74]
These state that:
"vaccination of entire populations [against
smallpox] is not recommended. The reason for not recommending
such mass vaccination is that there is a risk of severe reactions
to the vaccine, including death, and the fact that vaccination
can prevent smallpox even after exposure to the virus
the
best method of stopping a smallpox outbreak, should it occur,
remains the same - search and containment. That means identifying
persons with smallpox, identifying those people who have been
in contact with them, and vaccinating them".[75]
75. Smallpox has attracted a lot of attention on
account of its virulence and the potential susceptibility of the
population. There has not been a case in the UK since 1978. As
a result, medical practitioners have no licensed vaccine available
to them. With no incidents of infected individuals, it is not
possibile to test a vaccine to regulatory standards in an ethically
acceptable manner. There are two commercially available vaccines.
The purchase by the UK Government of the product produced by PowderJect
was highly contentious and the subject of a National Audit Office
(NAO) inquiry.[76] This
issue will not be considered here. Representatives from the companies
(the other one was Acambis) insisted to us that there was nothing
to choose between their products and we have no reason to doubt
them.[77]
76. The US Government has decided on a mass vaccination
campaign and inevitably this has focused attention on UK policy.
The medical community is largely supportive of the UK position.
Vivian Nathanson from the BMA told us that "Smallpox vaccine
is a dangerous vaccine and if nobody has smallpox in the community
you do not give it to people who are not at front line risk".
But there could be a mass vaccination programme with "the
right kind of agent and the right kind of vaccine".[78]
We note that the US smallpox vaccination programme has been making
slow progress, with less that 40,000 individuals (excluding the
military) as of September 2003.[79]
Regulation
77. Dr Paul Drayson, Chief Executive of PowderJect,
said that the smallpox vaccine that PowderJect produced was unlicensed
and that it had provided for an emergency response situation against
a potential biodefence threat. He said that the responsibility
for compensation and indemnification lay with the medical practitioner
who administered the vaccine, who would be a Government employee.
Issues of indemnification and vaccine damage payments would therefore
come under the responsibility of Government. We were reassured
to hear the Minister, John Hutton, confirm to us that all healthcare
workers taking the smallpox vaccine would be compensated for any
side effects.[80] Evidence
from the US military vaccination programme suggests that adverse
side effects have been lower than expected and there have been
no deaths among the 450,000 who have been vaccinated.[81]
78. The Committee heard during its visit to the US
of the Food and Drug Administration's (FDA's) ability to invoke
the "animal rule".[82]
This enables it to approve critical drugs and vaccines based on
evidence of their effectiveness in animal tests rather than on
extensive human studies. This permits scaled-back human trials,
especially for products to counter biological and chemical weapons.
The equivalent body in the UK is the Medicines and Healthcare
products Regulatory Agency (MHRA), which has recently been formed
by the merger of the replaced the Medical Devices Agency and the
Medicines Control Agency. The MHRA tells us that "When the
CSM [Committee on Safety of Medicines] considers the application
on the basis of quality, safety, efficacy and the risk:benefit
of the product, it takes into account the data submitted and also
the reasons for absence of full data. This is then factored into
evaluation of risk:benefit before a decision is taken". At
a European level, we understand that the European Medicines Evaluation
Agency already has a provision for marketing authorisation under
exceptional circumstances.[83]
How this applied is another matter. The vaccine manufacturer Acambis
reports that guidance from the European Medicines Evaluation Agency
is that any new smallpox vaccine needs to be fully tested as a
'new vaccine', which would involve Phase I trials of a hundred
or so people, Phase II of several hundred and Phase III of many
thousands to show that it is safe.[84]
79. The Government's decision not to conduct a
mass vaccination programme for smallpox is correct in our view.
The reported side effects of the vaccine make this option unattractive.
Should a safer vaccine become available, we would expect the Government
to reconsider this policy yet the Minister refused to address
this point. We have heard of doctors' concerns about the "worried
well".[85]
A safe vaccine might prove cost effective, provide reassurance
to millions and possibly act as a deterrent to any attack.
PERSONAL PROTECTION AND DECONTAMINATION
80. A DoH working group was looking at the procurement
of personal protective equipment (PPE) at the time of 11 September
2001. While the new specification was being established, the NHS
procured PPE as an interim measure, the process starting in October
2001 and finishing in March 2002, at a cost of £16 million.[86]
It became apparent that these interim suits were faulty, as David
Harper from the DoH explained to us:
"At the time of September 11, we put out
very quickly on an interim basis personal protective equipment
recognising the possible new threats we might need to be prepared
for.
we then rolled out the programme of provision of the
new suits and decontamination units. When the suits were tested
they were found to leak through some of the foot seams
once we were made aware of this [we] had discussions with
the industry, with the provider, and with the end users, to come
up with a suitable interim solution to maintain our capability
in an operational sense, information was put out very quickly
indeed, and we undertook a rolling programme of modification which
will rectify the problem".[87]
81. This is an embarrassing episode for the DoH.
We can understand the desire to be seen to be doing something
in response to the 11 September 2001 attacks but the Department
has succeeded only in undermining confidence in its competence.
An NAO review of NHS preparedness reports the concerns of the
London Ambulance Service about "the recurring costs associated
with maintaining and replacing the one-off Department of Health
issue".[88] The
most curious aspect of the affair is that the suits were tested
by Dstl.[89] Either Dstl
did not identify the problem or its advice was ignored. We were
also surprised that in the first instance the Fire Service was
not consulted.[90] Its
demands are likely to be more in line with the health service
than the military.
82. In law the DoH is responsible for the decontamination
of the public.[91] The
DoH and the OPDM have signed a Memorandum of Understanding in
respect of mass decontamination. It outlines the basis on which
the Fire Service will assist the Department of Health by providing
and staffing mass decontamination facilities at a CBRN incident.[92]
83. The NAO review found that existing provision
to deal with contamination incidents was inadequate and that there
was a fragmented approach, which had led to individual NHS trusts
procuring different types and quantities of PPE and decontamination
facilities. Only after this review were national specifications
developed.[93] The review
concluded that the situation concerning PPE and decontamination
equipment was continuing to improve.
84. In its initial procurement of personal protective
equipment after 11 September 2001, the DoH acted too hastily and
without consulting sufficiently widely. We are content that problems
are being remedied but at considerable expense and at a cost to
the public's and health professionals' confidence in the Department's
competence.
59 House of Lords, Fourth Report of the Select Committee
on Science and Technology, Session 2002-03, Fighting Infection,
HL Paper 138,para 8.3 Back
60
Ev 202 Back
61
Ev 202 Back
62
The new anthrax vaccine about to enter phase 1 clinical trials;
the plague vaccine is about to enter phase 2 clinical trials Back
63
Q 265 Back
64
Q 251 Back
65
Q 248 Back
66
Q 44 Back
67
Ev 202 Back
68
House of Lords, 4th Report of the Select Committee on Science
and Technology, Session 2002-03, Fighting Infection, HL
Paper 138, para 4.12 Back
69
Q 693 Back
70
Q 199 Back
71
Q 201 Back
72
Q 250 Back
73
The role of industry in developing medical countermeasures is
considered in paras 91-102 Back
74
HC Deb, 18 December 2002, Col 835 Back
75
Statement by the Director-General of the World Health Organization,
Dr Gro Harlem Brundtland, 2 October 2001 Back
76
National Audit Office, Procurement of Vaccines by the Department
of Health, Report by the Comptroller and Auditor General,
HC 625, Session 2002-2003, April 2003 Back
77
Q 180 Back
78
Q 121 Back
79
The US Centers for Disease Control has distributed 291,400 doses
of vaccine to states for pre-vaccination of key health and safety
workers, at the discretion of the states and the workers, www.hhs.gov
; www.smallpox.army.mil Back
80
Q 687 Back
81
www.smallpox.army.mil Back
82
US Food and Drug Administration press release P 02-17, 30 May
2002 Back
83
Ev 260 Back
84
Ev 212 Back
85
Q 104 Back
86
Ev 121 Back
87
Q 239 Back
88
Report by the Comptroller and Auditor General, Facing the Challenge:
NHS Emergency Planning in England, HC 36 Session 2002-2003, November
2002, Annex G, p 51 Back
89
Q 242 Back
90
Qq 616-618 Back
91
Q 620 Back
92
Ev 135 Back
93
Report by the Comptroller and Auditor General, Facing the Challenge:
NHS Emergency Planning in England, HC 36 Session 2002-2003, November
2002, pp 25,30 Back
|