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How do vaccines get on the CDC schedule? Two important meetings occur before a product is added to the schedule: Vaccines and Related Biological Products Advisory Committee (VRBPAC) + Advisory Committee on Immunization Practices (ACIP).
Vaccine recommendations originate in the FDA’s Vaccines and Related Biological Products Advisory Committee (VRBPAC). They meet approximately eleven times a year and are open to the public.
Per the FDA, the committee consists of 15 voting members invited by the FDA Commissioner to serve for overlapping terms of up to four years.
How does the FDA handle potential conflict of interests for committee members voting on vaccine matters? Per the FDA, if an individual selected to serve on an advisory committee has financial interests that may be impacted by the individual’s work on the advisory committee, they can still vote if:
- the serving member’s financial interest falls within an applicable regulatory exemption, listed at 5 C.F.R. 2640 (shown below), for certain financial interests which are too remote or too inconsequential to affect the integrity of the services of the member.
- the FDA certifies in writing that the need for the serving member outweighs the potential for a conflict of interest posed by the financial interest involved.
“SGE” = special government employee or the committee member
Once a vaccine is recommended by the FDA’s Vaccines and Related Biological Products Advisory Committee (VRBPAC), it passes to the CDC’s Advisory Committee on Immunization Practices (ACIP).
How does the CDC handle potential conflict of interests for committee members voting on vaccine matters? Per the CDC:
“WG” = working group
Upon appointment, each voting member is required to file an Office of Government Ethics 450 form. According to the CDC:
Let’s go back to 5 CFR Part 2640:
An ACIP member may obtain a waiver in spite of the fact the individual has one or more financial interests that would be affected by the activities of the advisory committee.
If you are concerned about the potential conflict of interest with those that are responsible for vaccines added to the CDC recommended schedule, you are not alone. We’ll touch a little more on what you can do in a later section. Before we do, let’s talk about how the decisions made in the above committees lead to vaccine mandates (and how you can be exempt from them).