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Review of the management of adverse effects associated with ...

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The <strong>Review</strong> has found that <strong>the</strong> Australian system<br />

has a number <strong>of</strong> strengths. It is similar to passive<br />

<strong>adverse</strong> event surveillance systems in comparable<br />

countries and was able to detect <strong>the</strong> safety signal<br />

<strong>associated</strong> <strong>with</strong> <strong>the</strong> use <strong>of</strong> <strong>the</strong> 2010 seasonal<br />

influenza vaccine, take appropriate action and<br />

undertake a rigorous investigation.<br />

The <strong>Review</strong> has found that <strong>the</strong> reporting <strong>of</strong><br />

<strong>adverse</strong> events following immunisation could be<br />

more timely. Factors that impact on <strong>the</strong> timeliness<br />

<strong>of</strong> reporting include: health pr<strong>of</strong>essional and<br />

consumer knowledge <strong>of</strong> how to report; delays in<br />

information exchange between <strong>the</strong> jurisdictions<br />

and <strong>the</strong> TGA; reports being sent in batches;<br />

differing forms and protocols used in each<br />

jurisdiction; and a lack <strong>of</strong> agreed case definitions.<br />

The <strong>Review</strong> considers that, once <strong>the</strong> first batch<br />

<strong>of</strong> case reports had been received by <strong>the</strong> TGA,<br />

its actions in starting a thorough investigation<br />

were appropriate and timely. The decision <strong>of</strong> <strong>the</strong><br />

CMO to suspend <strong>the</strong> use <strong>of</strong> all seasonal influenza<br />

vaccines in young children was also appropriate,<br />

timely and proportionate. The subsequent<br />

investigation was extensive and thorough.<br />

Updates were provided by <strong>the</strong> CMO to keep<br />

jurisdictions, health pr<strong>of</strong>essionals, consumers<br />

and <strong>the</strong> media informed <strong>of</strong> <strong>the</strong> findings <strong>of</strong> <strong>the</strong><br />

investigation as <strong>the</strong>y became available.<br />

The <strong>Review</strong> has found that knowledge and<br />

awareness <strong>of</strong> <strong>the</strong> vaccine surveillance system and<br />

its processes and procedures among jurisdictions,<br />

health pr<strong>of</strong>essionals and consumers could be<br />

improved.<br />

Some health pr<strong>of</strong>essionals and consumers<br />

felt <strong>the</strong>y were not sufficiently informed <strong>of</strong> <strong>the</strong><br />

unfolding events surrounding <strong>the</strong> suspension <strong>of</strong><br />

<strong>the</strong> use <strong>of</strong> seasonal influenza vaccines and <strong>the</strong><br />

subsequent investigation, particularly in <strong>the</strong> early<br />

stages before <strong>the</strong> suspension was announced.<br />

The <strong>Review</strong> notes <strong>the</strong>re are significant challenges<br />

in determining how to communicate <strong>with</strong> health<br />

pr<strong>of</strong>essionals and <strong>the</strong> community during <strong>the</strong> early<br />

stages <strong>of</strong> an investigation, when <strong>the</strong>re is a level <strong>of</strong><br />

doubt about <strong>the</strong> significance <strong>of</strong> <strong>the</strong> events.<br />

There is a perception amongst some stakeholders<br />

that <strong>the</strong>re is a lack <strong>of</strong> transparency in <strong>the</strong><br />

TGA vaccine surveillance processes and that<br />

information about investigations into <strong>adverse</strong><br />

events <strong>associated</strong> <strong>with</strong> vaccines is slow to be<br />

made public.<br />

The <strong>Review</strong> has found that <strong>the</strong> Governance<br />

arrangements for vaccine safety issues<br />

are complex. While <strong>the</strong> TGA has legislated<br />

responsibility to monitor <strong>the</strong> safety <strong>of</strong> vaccines,<br />

many organisations, committees and individuals<br />

have a role, and <strong>the</strong>re is a lack <strong>of</strong> clarity <strong>of</strong> <strong>the</strong><br />

relationships between <strong>the</strong>se groups and <strong>the</strong>ir<br />

roles and responsibilities in vaccine safety<br />

monitoring and responding to <strong>the</strong> identification<br />

<strong>of</strong> a possible signal. The <strong>Review</strong> notes that<br />

<strong>the</strong>re are no Standard Operating Procedures for<br />

responding to a vaccine safety issue that does<br />

not require regulatory action but which has<br />

possible implications for <strong>the</strong> use <strong>of</strong> a vaccine in a<br />

vaccination program.<br />

x<br />

<strong>Review</strong> <strong>of</strong> <strong>the</strong> <strong>management</strong> <strong>of</strong> <strong>adverse</strong> events <strong>associated</strong> <strong>with</strong> Panvax and Fluvax

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