Regulatory considerations for nucleic acid vaccines

For regulatory purposes nucleic acid vaccines are considered biological products and will be regulated by the Center for Biologics Evaluation and Research (CBER). Vaccines derived through the use of this technology may ultimately find broad application as preventive vaccines for infectious disease or as therapeutic vaccines for treatment of disease. The regulations that govern the use of biological products as well as other guidance documents available from CBER are applicable to the regulation of nucleic acid vaccines. The regulatory concerns associated with the manufacture, preclinical evaluation and clinical studies for these vaccines are similar to those for other biological products. The following discussion will provide an overview of the organization of CBER and how nucleic acid vaccines will be reviewed within this organization. This discussion will also describe the regulations encoded in the US Code of Federal Regulations which govern the use of biological products and additional guidance provided in Points to Consider Documents and in specific Guidelines. In addition, this discussion will note specific concerns regarding the manufacture, lot release and preclinical evaluation to assess the safety of polynucleotide vaccines. Finally, the process for submission of an Investigational New Drug application and the design of protocols for clinical studies will be described.