At the time of FDA approval for any vaccine, it is impossible to know whether it causes rare, unexpected serious adverse reactions. More than a year after the Covid vaccine approvals, we should have that information, but we do not. This is a serious problem.
If the vaccines are mostly safe, people need to know that, so they do not hesitate to get vaccinated. If there are serious safety issues, people need to know that, so they can properly weigh the risks and benefits, which vary by age. This failure has forced people to make their decisions based on anecdotal evidence. It has also led to less trust in CDC and the FDA. Unfortunately, this distrust extends beyond the Covid vaccines to other vaccines as well.
Over the last two decades, I worked closely with the CDC and the FDA to help design the systems used to track vaccine safety after FDA approval. During the pandemic, the FDA and CDC have not used the systems optimally and journalists and the public understand them poorly.
Pre-Approval Clinical Trials
When the FDA approves a drug or a vaccine, we know its efficacy from randomized clinical trials, but our knowledge about its safety and potential adverse reactions is limited. This is unavoidable. To measure efficacy—whether the vaccine works to prevent undesirable outcomes like infection or hospitalization—it is often enough to evaluate the product on a few thousand people.That sample size, however, is insufficient to determine whether the vaccine causes rare but serious adverse reactions. Pfizer evaluated its vaccine on 18,860 people. If an adverse reaction happens in only one in 10,000 people, and we see one or two such adverse reactions in the clinical trial, that is not enough to determine if the vaccine caused the reaction or if it occurred because of chance alone.
Also, if the randomized trial does not include enough people from important demographic groups, we can say little about its safety in that group. The Pfizer trial did not include many people under 30, above 80 or pregnant women, so we cannot know much about adverse reactions for those groups from the trial alone.
Post-Approval Vaccine Safety Monitoring
Since clinical trials are too small to tell us whether the vaccine causes rare but serious adverse reactions, it is necessary to do post-market safety surveillance after the FDA has already approved the product. In the United States, the three most important post-market vaccine safety surveillance systems are the Vaccine Adverse Event Reporting System (VAERS), the Vaccine Safety Datalink (VSD), and the Biologics Effectiveness and Safety System (BEST). There are other vaccine safety evaluation systems in other countries. In the United States, we also have the CDC’s After Vaccination Health Checker (vSafe) and the Clinical Immunization Safety Assessment Project (CISA), but they do not have the same ability to evaluate causality as VSD or BEST.Vaccine Adverse Event Reporting System (VAERS)
Administered jointly by the CDC and the FDA, VAERS is a passive reporting system where anyone can report a plausible or suspected adverse vaccine to the CDC/FDA, including physicians, nurses, patients, families, and friends. Vaccine manufacturers must forward reports that they receive to the VAERS system. Most countries have similar systems not only for vaccines but also for pharmaceutical drugs.VAERS and other passive reporting systems have strengths and weaknesses but more of the latter. The strength is that it is universal so that an adverse reaction can be reported no matter where or when it occurs. The two main weaknesses are underreporting and overreporting. Overreporting comes from the fact that the vaccine is not necessarily the cause of all adverse events that occur soon after vaccination. That is, many VAERS reports are accidental occurrences unrelated to the vaccine.
By itself, the number of reported post-vaccination events (strokes, seizures, heart attacks, deaths, etc.) is hence of limited use since those events might have occurred even without the vaccine. The key is whether there are more events than one would expect by chance if the vaccine did not cause them. To accurately determine whether the vaccine was responsible for those events, we need to know precisely how many people were vaccinated, and we need to receive all their health events as well as health events from an unvaccinated comparison group. None of this is available in VAERS.
Sophisticated epidemiological methods, such as ‘proportional reporting ratios’ and ‘gamma-Poisson shrinkage’ can help overcome some, but not all, of these problems. By making raw VAERS counts public without any such accompanying analyses, the CDC and the FDA have generated more confusion than clarity from these data.
In a bid to reassure the public about the vaccines, the media used this as a take-home sound bite, but unfortunately, it is nonsensical. Patients care about the likelihood of a serious adverse reaction occurring per vaccination dose; the ratio of mild to serious events observed is irrelevant. A vaccine with one mild and one serious adverse reaction per 1 million doses has a ‘terrifying’ 1:1 ratio. But it is much better than a vaccine with fifty mild and one serious adverse reaction per 100 doses administered, even though the latter has a more ‘reassuring’ 50:1 ratio.
Vaccine Safety Datalink (VSD)
The Vaccine Safety Datalink is a collaboration between the CDC and several integrated health systems, each of which makes available electronic medical records of patients for data analysis. In VSD, an exposed cohort of vaccinated individuals is defined independently of any subsequent health events. All health care visits are available irrespective of vaccination status, which means that the VSD does not suffer from the same reporting biases as VAERS.Researchers can then compare the observed adverse event counts with what would be expected by chance in the absence of vaccination. Researchers estimate the latter using either (i) historical counts in the same population, (ii) concurrent controls of similar unvaccinated individuals, or (iii) self-controls (comparing different time periods from the same vaccinated individuals). Having a control cohort or time period is critically important to determine whether the health events observed in the vaccinated cohort are caused by or unrelated to the vaccine.
The MMRV vaccine is still used for the booster shot, given to 4 to 6-year-old children, for which no such excess risk exists. The toddlers are instead given two separate shots for MMR and varicella, respectively.
MMRV is a powerful example of the potential of the VSD system, which quickly detected this safety problem soon after the vaccine’s launch. The finding dismayed Merck, the vaccine manufacturer, and others who had promoted the new vaccine. It was a heated conference call, to say the least, when we presented these results to Merck, but the childhood vaccine schedule was altered because of the VSD’s findings.
Biologics Effectiveness and Safety System (BEST)
Using health insurance claim data, the FDA has built a similar system to the VSD. It got off the ground just before the pandemic, so it does not have as long a track record of experience as the VSD. But the population it analyzes is larger in size, and through the Medicare program, the FDA has better data about older Americans than does the VSD.Vaccine Safety Concerns
Vaccine safety must always be evaluated relative to disease risk and vaccine efficacy. Older adults have a high Covid mortality risk, so unless they already have natural immunity from a prior Covid infection, the benefit of vaccination outweighs the small risk of both known and potentially unknown adverse reactions. Covid mortality is exceptionally low for children and young adults, so for them it is unclear whether the limited benefit of vaccination outweighs the still unknown safety profile of the vaccine.We built the vaccine safety surveillance systems to quickly find any adverse reactions caused by the vaccines when they exist and assure the public about their safety when they are safe. That has only partly happened with the Covid vaccines. Both the VSD and BEST have excellent rank-and-file epidemiologists on staff. The VSD has been able to detect and quantify the increased risk of myocarditis after Covid vaccination and show how that risk varies by age and sex.
Public health officials face a temptation to summarily dismiss anecdotal vaccine injury stories and people concerned about the publicly available VAERS reports, but in public health, we cannot do that. We must take people’s concerns seriously.
Whatever the truth is, we need to convincingly determine whether there is a problem or not and make that evidence public. Rather than the CDC and FDA feeding the public with inferior VAERS data that cannot answer the question, Americans deserve to be presented with solid evidence from the superior VSD and BEST systems.