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Review of animal use requirements in WHO biologics guidelines – database of suggested guideline revisions

This fully searchable database contains all of the animal tests and 3Rs language found in the WHO biologics guidelines reviewed during the project. For each entry in the database, the expert reviewers have made comments on the original text (in bold) and/or suggested revisions to promote adoption of specific 3Rs approaches where appropriate or to modify the language to facilitate adoption of 3Rs approaches in the future. More information about the review process can be found in the final report to WHO.

349 results

WHO guideline title Product TRS Test name Test category 3Rs approach Toggle to view all updates
Guidelines for independent lot release of vaccines by regulatory authorities
n/a
978 Annex 2
Encouragement of networking and work-sharing
n/a

Original text

Sharing of test results can contribute to reducing the number of animals used for testing

New text

Text should be stronger - sharing data should be an expectation
Year
2013
Page
54
Section
3.2
Guidelines for independent lot release of vaccines by regulatory authorities
n/a
978 Annex 2
Practical considerations
n/a

Original text

When animals are used for testing, the NCL should be aware of the potential variability of the source, housing and handling of animals. It is desirable to apply the “3R” principles (reduction, replacement, refinement) to minimize the use of animals, for ethical reasons. Validated in vitro alternatives should be favoured wherever possible. However, the type of testing should be driven by the scientific need for valid relevant data. Moreover, in the spirit of minimizing animal testing worldwide, agreements should be sought with the NCL of the exporting country or with other NCLs, in a mutual recognition or collaborative agreement, in order to utilize the results of animal testing already performed by another NCL.

New text

Application of the 3Rs should be more than desirable. Need to emphasise the scientific and economic benefits including time to market reduction and prevention of shortage risk for patients. Linking to the statement on page 53 "Multiple testing can be costly and time consuming. In addition, many biological assays are highly variable, and repetitive testing can result in “false” OOS results, which then require extensive investigation and delay vaccine supply. The decision to repeat tests on a lot that has already been tested by another competent authority should be carefully considered in light of all available information."
Year
2013
Page
67
Section
5.2.7
WHO Manual for the establishment of national and other secondary standards for vaccines
n/a
WHO/IVB/11.03
n/a
n/a

Original text

Appendices illustrate model approaches and examples. The model approaches may need to be revised to reflect 3Rs

New text

Manual should be revisited following revision of guidelines
Year
2011
Page
29
Section
Appendices
WHO Manual for the establishment of national and other secondary standards for vaccines
n/a
WHO/IVB/11.03
Calibration against IS (including collaborative study design)
n/a

Original text

Chapter 7 mentions experimental design 'sound statistical design principles'. This could be streathened and extended to include a general statement about model selection and the 3Rs.

New text

Manual should be revisited following revision of guidelines
Year
2011
Page
16
Section
Chapter 7
Guidelines on stability evaluation of vaccines
n/a
962 Annex 3
Choice of stability-indicating parameters and frequency of testing
n/a

Original text

This is a general guideline describing strategies for the assessment and monitoring of vaccine stability, both during the development process and post-licensure. The selection of assays for stability studies would be dependent on the vaccine product, but should include safety- and potency-indicating parameters. Whether those assays are in vivo or in vitro is not defined or required within the document (as that would be dependent on the vaccine).

New text

A 3Rs approach should be recommended and emphasized in the definition of stability protocols, notably for post-licensure stability monitoring. It could be emphasized in Chapter 5.1 which mentions "stability-indicating parameters should be selected on a case-by-case basis". Although tests are dependant on the vaccine, some 3Rs applications should be recommended as the guideline gives examples of tests that are vaccine specific.For example safety tests are mentionned such as reversibility, specific toxicity which apply to toxoid based vaccines : in that case reversibility testing is being removed and specific test is also being removed on drug product (refer to review of guidelines on tetanus and pertussis for example). If detoxification process is validatedand and initial toxicity test for release is compliant residual toxin and reversion are not stablity indicating parameters as they will not evolve over time. This is an example to illustrate that whatever the vaccine : 1) in vivo tests should not be mentionned per say (named cf p.180, 182, or stated example 185 :"" in addition to in vivo and in vitro potency"" : potency is sufficient)) as alternatives and removals are ongoing (including for the potency tests that are mentionned) 2) the guideline should recommend to introduce in vivo assays in stability study protocols only if justified that is if the quality attribute assessed through the in vivo assay is expected to evolve over time and if there is no alternative to assess that evolution"
Year
2011
Page
181
Section
5.1
Guidelines on stability evaluation of vaccines
n/a
962 Annex 3
n/a
GST

Original text

Parameters other than potency-indicating ones should also be considered since they indicate changes in vaccine quality with unknown effects on efficacy and safety. Such parameters may include, in addition to in vivo and in vitro potency, antigen content, appearance, pH, general safety, specific toxicity, antimicrobial agent content, completeness of adsorption, sterility, adjuvant (adsorbent) content and changes in physicochemical properties.

New text

As the general safety test is no longer recommended by WHO, this should be deleted from the text.
Year
2011
Page
182
Section
5.1
Manual for Quality Control of Diphtheria, Tetanus and Pertussis Vaccines
DTP vaccines
WHO/IVB/11.11
The use of laboratory animals in the quality control of vaccines
Miscellaneous

Original text

Bioassays performed on living animals are still the method of choice for evaluating the safety and potency of many bacterial vaccines. Before any new procedure is introduced it should be validated against the standard method to ensure at least non-inferiority of performance. Most bio-assays use either guinea-pigs or mice often in quite large numbers. The main shortcoming of such tests is the result of individual variation between animals which can result in low precision and poor reproducibility. More than any other system used for testing, animals have to be handled and maintained appropriately to generate accurate, reliable, and reproducible results. It is essential to be aware of all the factors that may affect the biological functions of the test animals, and thus interfere with the outcome of a potency, safety or toxicity test.

New text

Manual should be revisited following revision of guidelines
Year
2013
Page
10
Section
I.4
Manual for Quality Control of Diphtheria, Tetanus and Pertussis Vaccines
DTP vaccines
WHO/IVB/11.11
Choice of animals
Miscellaneous

Original text

Tests performed to assure the safety and potency of diphtheria and tetanus vaccines should ideally be performed in guinea-pigs. However, these animals have become increasingly expensive and in some countries their supply and maintenance is problematic.
For pertussis vaccine potency and safety tests, mice have to be used. In a study on the possible influence of mouse strain on the assayed potency of tetanus vaccines, Hardegree et al. (4) tested a batch of tetanus vaccine in parallel with the International Standard for Tetanus Toxoid in five different mouse strains. A significant difference in relative potency between the two vaccines was found for the individual strains. This is a recurrent problem and the difficulty of relating potency test data obtained in mice to results obtained by the traditional method in guinea-pigs has not been completely resolved.

New text

Manual should be revisited following revision of guidelines
Year
2013
Page
11
Section
I.4.3
Manual for Quality Control of Diphtheria, Tetanus and Pertussis Vaccines
DTP vaccines
WHO/IVB/11.11
Microbiological quality
Miscellaneous

Original text

Whatever the disadvantages and problems associated with the use of animals as a “measuring device” in the quality control of vaccines, no test system is known which can replace animal models completely. The use of a reference can partly overcome the effect of external factors on test results. However, attention should be paid to the care and handling of laboratory animals to minimize effects of environment and nutrition and to maximize efficacy in their use, particularly in the quality control of bacterial vaccines. Animals should be bred and maintained in such a way that the maximum possible standardization and reproducibility are obtained.

New text

Manual should be revisited following revision of guidelines
Year
2013
Page
14
Section
I.4.4
Manual for Quality Control of Diphtheria, Tetanus and Pertussis Vaccines
DTP vaccines
WHO/IVB/11.11
Potency in guinea pigs by challenge
Potency

Original text

The challenge potency test for diphtheria vaccine (adsorbed) is determined by comparing the dose of the vaccine to that of a reference preparation required to protect guinea pigs from either an erythrogenic toxic effect (toxin administered intradermally, i.d.) or a lethal toxic effect (toxin administered subcutaneously, s.c.) [1,2]. For this comparison, a reference preparation of diphtheria toxoid (adsorbed) calibrated in International Units (IU) and a suitable preparation of purified diphtheria toxin is required. The current International Standard for diphtheria toxoid with an assigned activity of
213 IU/ampoule (based on results obtained in guinea pig lethal and i.d. challenge assays, NIBSC code 07/216) was established in 2009 for determining the potency of vaccines containing diphtheria toxoid [3]

New text

Manual should be revisited following revision of guidelines
Year
2013
Page
24
Section
II.1.2