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rjh's avatar

You are mistakenly mixing the approval of factories with the approval of the vaccine. While related, they are two different things. Also, you must consider the kind of approval. I haven't brought a vaccine to market but I have been involved in getting factories approved.

Factory approval is about process control, temperatures, chemical content, cleanliness, measurement tracking, batch tracking, etc. It's not about efficacy of the drug, other than efficacy approval establishes the quality parameters that must be met.

1. Factory approval requires a level of documented paperwork and demonstrated compliance with procedures that can be staggering. You must track every item, every machine, every process, every worker, every procedure. These must be documented, logged, etc. Every potential problem, actual problem, modification, etc. must be documented, reviewed, and approved. All of this documentation must be available on demand to an FDA inspector, and the inspector must have instant access to the relevant parts of the factory with no warning, no appointment, and no warrant. The initial approval determines what are the relevant parts of the factory and it's agreed by the FDA. If you relocate any people or machines this can change the access.

This level of inspection access is problematic to many people. I've watched multi-year battles between the FDA and some European companies over this level of access. This kind of access is anathema to a closed controlled country like China.

2. The US vaccines are being made in factories that were already approved for manufacture of other similar drugs using the same equipment. Adding one more drug to the process is trivial in comparison to approving a new factory. That's been one of the limits to increasing production. Once the factories already approved and capable of making the vaccine are at 100% capacity it's very slow to get new factories approved. The FDA has not weakened the manufacturing safety rules.

3. The efficacy rules for the vaccine approval were weakened. If you want to read the endless details they are available. The FDA published the Emergency Use requirements about a year ago. They are the basis for all the current vaccine distribution. They are less stringent than regular requirements. The first vaccine to meet the regular requirements was only approved by FDA about a month ago. The manufacturing rules were not weakened.

I agree that the FDA process is excessively risk averse and excessively bureaucratic. It's prioritization is often terrible. This certainly needs work. The careful improvements needed are not the kind of chanage that you are suggesting.

I've also seen and inspected factories that failed the FDA inspections. I was shocked and appalled. The level of filth and contamination of products was staggering. For example, you should expect a factory floor that you are comfortable eating off. (Of course food won't be allowed into the facility, so you won't actually eat off that floor.) I saw factories with muddy dirty floors, bird droppings, etc. These places wouldn't pass routine kitchen inspection at a restaurant.

Many people don't realize what is needed.

The non-FDA factories that I've seen which would pass FDA cleanliness and process control inspection were semiconductor fabs, precision electronics manufacturing, etc. I helped bring one precision electronics manufacturer up to FDA standards and it was pretty easy. We mostly documented and explained how their existing extremely demanding process control met all the goals set by the FDA. It took about 5% the time and cost of bringing a new production facility up to FDA standards, with very little process change needed.

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Charles Ryder's avatar

I think public health officials cajole rich countries into foregoing booster shots and child vaccination at the peril of global public health. Far better to work on supply. At the end of the day people don't want themselves or their loved ones to get sick or die. Confident, less-stressed rich country residents (who have no reason to complain about people in poor countries) are more apt to support the kinds of global vaccine aid the world needs right now. Reminds me a bit of the climate change sub-debate regarding conservation vs. abundant (green) energy. The latter would be vastly preferable, if it could be pulled off.

In short, rich countries should do more if at all possible, but not at the cost of denying their own citizens medically recommended, optimal vaccine regimens. At least that's my take.

I'm fully vaccinated with Sinovac, for what it's worth.

(Also, Chinese pharma firm Shanghai Fosun is working on a deal with BioNtech, it appears. In the Chinese press, at least, I haven't seen the name "Pfizer" mentioned).

https://www.japantimes.co.jp/news/2021/08/30/asia-pacific/china-pfizer-approval-pending/

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