What are the benefits of recording and evaluating suspected adverse reactions?
The spontaneous reporting system is an essential component in the vaccine safety monitoring. The collection and evaluation of suspected vaccine adverse reactions and vaccine complications reported to the Paul-Ehrlich-Institut serves to identify possible risk signals at an early stage and, if necessary, to take, coordinate or initiate measures to minimise risk.
Suspected case reports are not subject to an individual medical or clinical assessment by the Paul-Ehrlich-Institut.
The data from the spontaneous reports are supplemented by data from the periodic safety update reports (PSURs) specified in the marketing authorisations, which the pharmaceutical companies (marketing authorisation holders) must submit to the committees of the European Medicines Agency (EMA) and thus also to the national drug authorities.
If there is any indication of a new risk signal for an authorised vaccine, the Paul-Ehrlich-Institut will, if necessary, take or initiate measures to minimise the risk or, if necessary, coordinate measures with the sister medicines authorities in the EMA committees and report on them.
Suspected cases of adverse reactions are not identical to adverse reactions as listed in the product information.
Updated: 05.08.2024
Who reports suspected cases of side-effects and vaccine complications following vaccination?
As with other medicinal products under the Institute’s responsibility, the Paul-Ehrlich-Institut receives reports of suspected side effects or vaccine complications following vaccination from the following sources:
- Via public health offices in accordance with the German Infection Protection Act (Infektionsschutzgesetz, IfSG). Doctors and pharmacists who administer vaccines are required by law to report vaccine complications – i.e., health complaints that go beyond the usual extent of a reaction to a vaccine and cannot be clearly attributed to other causes – with names to the responsible public health office, which in turn reports these immediately and in anonymised form (i.e., without any names and addresses of patients) to Paul-Ehrlich-Institut.
- From the Drug Commission of the German Medical Association (AkdÄ) and the Drug Commission of German Pharmacists (AMK).
- From the marketing authorisation holders via the EudraVigilance database of the European Medicines Agency (EMA).
- Directly from doctors.
- From vaccinated persons or their relatives.
Updated: 19.04.2024
What happens to the reports of suspected side effects and complications?
The Paul-Ehrlich-Institut compiles the reports it receives regarding adverse events and vaccination complications. It is important to set the reporting threshold low in order to identify any new safety signals at an early stage. This means that reports linked purely by time and not necessarily causally with the vaccination are also significant. The Paul-Ehrlich-Institut seeks out additional information on a large number of reports and it also receives further data on reports from a variety of reporting sources. The current status of information on the cumulatively submitted reports is analysed on an ongoing basis. The description of the suspected cases may therefore be subject to changes compared to the previous reports as a result of additional information.
The Paul-Ehrlich-Institut carries out "observed-versus-expected" (OE) analyses on an ongoing basis for the early detection of potential safety signals. These analyses compare the frequency of the adverse events reported after vaccination to the Paul-Ehrlich-Institut to the statistically expected frequencies in a comparable (non-vaccinated) population, taking variation in time intervals into consideration. If the reporting rate for an adverse event after vaccination is significantly higher than would be statistically expected in a comparable population, then the Paul-Ehrlich-Institut presumes the presence of a potential safety signal that should be examined further in predominantly epidemiological studies.
The reporting data is also entered into the European database of adverse drug reactions, EudraVigilance, maintained by the European Medicines Agency (EMA), so that they can also be taken into account in risk analyses at the EU level.
Updated: 30.08.2024
How is a suspected adverse event report evaluated?
A suspected adverse event report is assessed by the Paul-Ehrlich-Institut according to the criteria of the World Health Organization (WHO).
In its user manual for the revised WHO classification, the WHO states the following regarding the assessment of an adverse event following immunisation (AEFI):
"Causality assessment is the systematic review of data about an
AEFI case; it aims to determine the likelihood of a causal association between the event and the vaccine(s) received. For individual cases, one tries to apply the evidence available on the basis of the history and time frame of the event to arrive at a causal likelihood. (...) Causality assessment usually will not prove or disprove an association between an event and the immunization. It is meant to assist in determining the level of certainty of such an association. A definite causal association or absence of association often cannot be established for an individual event."
The evaluation of suspected adverse event reports is therefore not about the final evaluation of the individual reports.
Updated: 05.08.2024
Does the possibility of reporting suspected cases in different ways mean that the same suspected case may be reported more than once?
Yes, multiple reports are possible, but they are merged within the database. In individual cases, this may also occur with a time delay if investigations of the report subsequently reveal that it is a duplicated notification.
Updated: 28.03.2024
Do individuals who have reported suspected adverse events receive personalised feedback from the Paul-Ehrlich-Institut?
Individuals who submit a report to the Paul-Ehrlich-Institut via www.nebenwirkungen.bund.de will receive a confirmation of receipt and a specific PEI number after submission of the report. However, this PEI number is not used for personal contact with the vaccinated person or their relatives, only for queries from the Paul-Ehrlich-Institut.
The spontaneous reporting system and the recording of suspected adverse event reports are primarily used to obtain information on possible, previously unknown adverse events in the form of safety signals. Individual case reports are used to carry out an overall evaluation of the corresponding medicinal products. They are not used for assessments of the individual reports nor to provide personal feedback on the individual cases.
The Paul-Ehrlich-Institut is not a clinical institution and therefore cannot offer individual vaccination advice or other feedback. More specifically, it is not possible for the Institute to give recommendations on diagnosis or therapy, as there are many factors to consider when it comes to issuing medical advice. These factors can only be adequately addressed via personal contact between doctor and patient. Please direct these questions to your physician.
Updated: 30.08.2024
Why does the Paul-Ehrlich-Institut publish the number of suspected case reports, but no figures on confirmed suspected cases?
The Paul-Ehrlich-Institut records and evaluates case reports of suspected possible adverse reactions to vaccines and vaccination complications as part of the spontaneous reporting system, an important pillar of medicinal product safety. The spontaneous reporting system has the function of recognising safety signals – indications of a connection between an adverse reaction and the administration of a drug or vaccination – as quickly as possible. Those signals are then followed up by further investigations.
In the case of a safety signal, further investigations are carried out to determine whether the reaction described is actually an adverse reaction caused by the medicinal product. The Paul-Ehrlich-Institut works closely with the EU authorities in the evaluation of safety signals.
No conclusions can be drawn about the frequency of adverse reactions or a causal relationship with the administration of a vaccine or therapeutic on the basis of the suspected case reports submitted to the Paul-Ehrlich-Institut. This is due to the fact that
- adverse reactions can also occur coincidentally after administration of a vaccine or therapeutic and then be reported,
- in the interests of rapid detection of possible new safety signals, it is expressly desired that reactions with a questionable link to vaccination are also reported (low-threshold reporting), and
- reports are often not complete and the assessment of an adverse reaction in an individual case may change with further medical information on a report and/or new scientific findings.
Updated: 05.08.2024
What should be taken into account when using public data on reports of suspected adverse events?
Despite the risk of misinterpretations of the reported information, the Paul-Ehrlich-Institut publishes reported cases of suspected adverse events as defined in the Medicinal Products Act (Arzneimittelgesetz, AMG) and/or vaccine complications as defined in the Infection Protection Act (Infektionsschutzgesetz, IfSG) after the use of COVID-19 vaccines. This data is published on the Paul-Ehrlich-Institut’s website in consideration of the increased demand for information from some sections of the population and in favour of maximum transparency. The information is offered in a user-friendly Excel spreadsheet and supplemented with batch numbers (when available). The Paul-Ehrlich-Institut would also like to call attention to the disclaimer text displayed before the download link and to the explanations included in line one of the tables.
Data on Adverse Drug Reactions
The following text is provided by the Paul-Ehrlich-Institut to inform the interested public regarding the most important facts, along with detailed explanations, connected to the use of the published suspected adverse event reports in order to prevent misinterpretations.
The Spontaneous Reporting System is an Important Pharmacovigilance Tool for Signal Detection. Batch Numbers Have No Primary Significance in Routine Signal Detection.
Spontaneous reports are an important tool in pharmacovigilance for the detection of new safety signals, which can be investigated via such methods as more detailed analyses and comparisons with data from existing clinical studies or literature publications. Reporting a suspected adverse event has been made simple and straightforward for the reporters in order to promote the voluntary submission of reports and to enable everyone to report suspected side effects, regardless of the availability of detailed information. Reports require only the information that can be provided by the reporters without difficulty and that is absolutely necessary in the European context of medicinal product evaluation for the processing and evaluation of the report. The batch numbers are not required information.
The batch numbers have no primary significance for the routine detection of signals. The starting point for signal detection is the reactions reported for the medicinal product or the vaccine. The indication of a specific batch number is also not mandatory for submissions to the EudraVigilance database, the suspected side effect database of the European Medicines Agency (EMA), for this same reason. Information on batch numbers is not published in the EudraVigilance database.
European Database of Suspected Adverse Drug Reaction Reports
Suspected Adverse Event Reports Submitted via the Spontaneous Reporting System are Not Suitable for Making Concrete Statements About the Frequency (Batch-related or Otherwise) of Reactions.
The Paul-Ehrlich-Institut has repeatedly received inquiries from the public in which the information on suspected adverse events received from the spontaneous reporting system is regarded as an appropriate means of observing batch-related frequencies of vaccine adverse events. Such a perspective can lead to the expectation that batch-related evaluations of spontaneous reports should be considered standard. However, this perspective is not expedient from a scientific point of view because suspected adverse event reports submitted via the spontaneous reporting system have various system-inherent limitations and are therefore not suitable for making concrete statements about the frequency of reactions. This data is also only one component in the evaluation of medicinal product safety. Spontaneous reporting data is supplemented by information from clinical or non-interventional studies or by information published in the literature. This data is discussed in the context of periodic safety update reports (PSURs). The pharmaceutical companies (marketing authorisation holders) must submit these reports regularly to the European Medicines Agency (EMA), and the assessment and discussion of the reports takes place within the national medicines authorities.
Suspected adverse events after vaccination or medicinal product therapy are retrospectively recorded in the spontaneous reporting system using the information available to the reporting person. The number of recorded suspected adverse events in the spontaneous reporting system is thus a subset of the totality of the actual adverse events that have occurred. The Paul-Ehrlich-Institut has no way of determining the total number of suspected cases that have occurred within the spontaneous reporting system – e.g. the number of people who have been immunised with a particular vaccine in Germany. The exact number of exposed people is also not known, which is required in addition to the exact number of adverse events to calculate a specific frequency. Therefore, the frequency of the reaction cannot simply be inferred from the number of reports. Unlike the spontaneous reporting system, this information is available in clinical studies, so is possible to calculate the frequency of an adverse event in this context.
A valid vaccine batch is only documented for a limited number of the suspected case reports that are submitted to the Paul-Ehrlich-Institut. A batch-related increase in reports cannot be identified on the basis of the information available in the suspected case reports. A scientifically-accurate extrapolation is not possible on the basis of this incomplete data.
It is not uncommon for the number of suspected case reports per batch to vary. This is partly due to the fact that batches contain very different amounts of vaccine doses. In addition, all of the vaccine doses contained in a released batch are not vaccinated exclusively in one single Member State of the European Economic Area (EEA), such as Germany.
The concern that certain batches of a COVID-19 vaccine were more likely to cause adverse events than others is altogether unjustified. The Paul-Ehrlich-Institut would like to point out as an example that none of the safety signals determined to have a connection to the administration of COVID-19 vaccines – such as thrombosis with thrombocytopenia syndrome (TTS) after administration of vector vaccines or myocarditis/pericarditis after mRNA vaccines – were found to be batch-related.
Reported Suspected Cases are Not Confirmed Adverse Events. Adverse Events are Not to be Equated with Vaccine Damage.
The Paul-Ehrlich-Institut publishes reports of suspected adverse events that it receives within the spontaneous reporting system, one of the building blocks of pharmacovigilance. These reports are intended to provide an early indication of possible vaccine risks. They are not confirmed adverse events. It should be noted here that reported adverse events are chronologically, but not necessarily causally, linked to vaccination. Confirmed adverse events are listed in the vaccine product information. The reactions reported to the Paul-Ehrlich-Institut are also not equivalent to vaccine damage.
According to section 24 of the Social Code (Sozialgesetzbuch, SGB) XIV, persons who have suffered damage to their health due to a prescribed or publicly recommended vaccination that exceeds the usual extent of a reaction to a vaccination or other measure of specific prophylaxis (colloquially: vaccine damage) are to receive benefits under social compensation law. The corresponding prerequisites/criteria are set out in sections 4 and 24 of the SGB XIV. In order to receive these benefits, an application for compensation must be submitted to the Social Welfare Office in the federal state in whose territory the vaccination was carried out in accordance with section 113 subsection 5 of the SGB XIV.
Section 5 of the SGB XIV regulates the degrees of damage and stipulates that temporary health conditions lasting six months or less are not to be considered as damage.
The Paul-Ehrlich-Institut is not responsible for processing applications for benefits under social compensation law.
Updated: 17.01.2025
How is the reporting rate for suspected adverse events defined?
The reporting rate is the ratio of the number of reported suspected adverse events to the number of uses or administered doses of a medicinal product, such as a vaccine.
The reporting rate of suspected adverse events for a medicinal product is often given as a percentage (per 100 uses or administered doses) or in reports per thousand (per 1,000 uses or administered doses).
Updated: 15.01.2025
What is the significance of the reporting rate in the spontaneous reporting system and what does it say about the safety of a medicinal product?
The reporting rate is an important indicator in the spontaneous reporting system, which is used to detect abnormalities – known as signals – with the help of the observed versus expected (OE) analysis. These analyses compare the frequency of the adverse events reported to the Paul-Ehrlich-Institut (after vaccination, for example) to the statistically expected frequencies in a comparable (non-vaccinated) population, taking variation in time intervals into consideration. If the reporting rate for an adverse event after vaccination is significantly higher than would be statistically expected in a comparable population, then the Paul-Ehrlich-Institut presumes the presence of a potential safety signal that should be examined further in predominantly epidemiological studies.
The reporting rate of suspected adverse events does not allow direct statements about the safety of a medicinal product. However, it can serve as a first indicator in medicinal product monitoring to detect abnormalities, such as previously unknown possible adverse events.
Important to know: the frequency of (confirmed) adverse reactions cannot be inferred from the number of suspected case reports received by the Paul-Ehrlich-Institut as part of the spontaneous reporting system alone, nor from their reporting data.
Example: reporting rates within the spontaneous reporting system
Let's suppose there are two vaccines: Vaccine A and Vaccine B.
- Vaccine A was administered a million times in one year and 100 suspected adverse events were reported.
Reporting rate = 100 reports per 1,000,000 uses = 0.01% - Vaccine B was only administered 10,000 times in the same year, but 100 suspected adverse events were also reported.
Reporting rate = 100 reports per 10,000 uses = 1%
Although the same absolute number of suspected case reports have been received for both vaccines, vaccine B has a significantly higher reporting rate: 1% compared to 0.01%. This higher reporting rate could be a signal that the adverse events connected to vaccine B are more common and should be investigated more closely.
In the spontaneous reporting system, the reporting rate can help to identify medicinal products that may be at an increased risk of certain adverse events, so that further analyses and investigations can be initiated by the medicinal product safety experts.
Updated: 15.01.2025
What are some potential limitations of the observed versus expected analysis?
It should be noted that an observed versus expected analysis (OE analysis) can indicate a safety signal, but only further investigations will show whether or not there is actually a risk. An OE analysis is not suitable for confirming a risk. A safety signal indicated by means of a method such as an OE analysis should be further investigated by additional studies (Guideline in good vigilance practices (GVP): Product- or Population-Specific Considerations I: Vaccines for prophylaxis against infectious diseases EMA/488220/2012 Corr*).
The following aspects pose limitations for an OE analysis: variance in the information on background incidence rates in the original sources, lack of information regarding both the time interval between vaccination and start of symptoms as well as the exposure level, reporting delays, and somewhat shorter observation times post-vaccination for the last dose administered. In addition, age stratifications can only be carried out to the extent that data from the literature on the background incidence is available for individual age groups. Therefore, the individual analyses also differ in regards to the age groups presented.
Updated: 16.04.2024