125742 S31 M1 response 28jul2021

Pfizer Documents (PHMPT/FDA)

Pfizer Bla Submission

Pfizer 16 Plus Documents

17

Document text

BNT162b2
BLA STN 125742/0
M 1.11.3 Response to FDA Information Request
PFIZER CONFIDENTIAL
Page 1BNT162b2 (COMIRNATY)
BLA STN 125742/0
Response to CBER 28 July2021Information Request Regarding Post- marketing
SafetyStudy(ies)
August2021
090177e197b93e4d\Approved\Approved On: 03-Aug-2021 22:37 (GMT)
FDA-CBER-2021-5683-0950173
BNT162b2
BLA STN 125742/0
M 1.11.3 Response to FDA Information Request
PFIZER CONFIDENTIAL
Page 2TABLE OF CONTENTS
1. INTRODUCTION ................................ ................................ ................................ ................. 4
2. CBER REQUESTS AND SPONSOR RESPONSES ................................ ............................ 4
2.1. CBER Request 1................................ ................................ ................................ ........4
2.2. CBER Request 2................................ ................................ ................................ ......13
3. REFERENCES ................................ ................................ ................................ .................... 15
090177e197b93e4d\Approved\Approved On: 03-Aug-2021 22:37 (GMT)
FDA-CBER-2021-5683-0950174
BNT162b2
BLA STN 125742/0
M 1.11.3 Response to FDA Information Request
PFIZER CONFIDENTIAL
Page 3List of Abbreviations and Definitions of Terms
Abbreviation Definition
DoD Department of Defense
ECG Electrocardiogram
EU European Union
MHS Military Health System
NHLBI National Heart, Lung and Blood Institute
NIH National Institutes of Health
PHN Pediatric Heart Netw ork
PY Person-years
RR Relative risk
TBD To be determined
US United States
VSD Vaccine Safety Datalink
090177e197b93e4d\Approved\Approved On: 03-Aug-2021 22:37 (GMT)
FDA-CBER-2021-5683-0950175
BNT162b2
BLA STN 125742/0
M 1.11.3 Response to FDA Information Request
PFIZER CONFIDENTIAL
Page 41.INTRODUCTION
Reference is made to BLA STN 125742/0 for COVID- 19 mRNA Vaccine (COMI RNATY), 
for active immunization to prevent COVID -19 caused by  SARS-CoV-2 in individuals 
≥16years of age and to CBER’s Information Request received via email on 28July2021.
CBER request s are presented in bold italics followed b y Pfizer-BioNTech responsein plain 
text.
2.CBER REQUESTS AND SPONSOR RESPONSES
Please include the following information for the postmarketing study(ies) proposal: study 
designs, sample sizes and justification of sam ple sizes including number of subjects 
≤30years of age, information to be collected at baseline, frequency and methods for 
follow-up data collection, plan for duration of long term follow ‐up and information to be 
collected in follow ‐up, study timeline and milestone dates (final protocol submission date, 
study completion date, and final study report submission date; please provide dates in 
mm/dd/yyyy format).
2.1. CBER Request1
1. Please propose postmarketing observational safety study(ies) to assess myo /pericarditis 
following administration of COMIRNATY to:
a.Quantify the magnitude of risk by age, sex, and dose
b.Include follow up cases (e.g., via a registry) for recovery status and long -term 
sequelae
Sponsor Response
Response to 1A : Quantifying the magnitud e of myocarditis/pericarditis risk
As previously  communicated, post -authorization safet y studies C4591009 (US), C4591011 
(US), C4591012 (US), and C4591021(EU) use large electronic healthcare databases to assess 
increased risk of safet y events of interest, including m yocarditis/pericarditis, following 
vaccination with COMIRNATY during a 2 -3 year study period.  In these studies, the 
incidence of m yocarditis/pericarditis will be described overall, and stratified by  age group, 
gender, race/ethnicity (if feasibl e), dose, and risk interval using structured information and 
following case confirmation via medical record review where feasible.  To assess the 
magnitude of risk, these studies include comparative methods (self -controlled anal yses, and 
analyses involving a separate comparator group).  Relative risk (RR) estimates from 
comparative anal yses will be obtained overall and stratified by  the same factors as described 
above when supported by  sufficient cell counts.
090177e197b93e4d\Approved\Approved On: 03-Aug-2021 22:37 (GMT)
FDA-CBER-2021-5683-0950176
BNT162b2
BLA STN 125742/0
M 1.11.3 Response to FDA Information Request
PFIZER CONFIDENTIAL
Page 5Given the demographics of their source populatio ns, studies C4591009, C4591011, and 
C4591021 are expected to capture data on individuals aged 30 years and younger. In 
C4591012, the largest sub -population of y ounger individuals includes veterans aged 30-
39years; therefore, individuals 12- 39 years of age will be included in this analy sis.
Table1provides a range of estimates of the numbers of COMIRNATY -exposed persons and 
myocarditis cases that would be required to be included in the study  in order to have 
sufficient power to detect R Rs for various magnitudesof risk of vaccine -associated 
myocarditis under different assumptions within a self-controlled case series anal ysis. These 
estimates are based estimates of myocarditis/pericarditis background rate sused byCDC in 
signal evaluation s, ranging from 1/100,000 (person- years) PY to 10/100,000 PY .1
Table1.Required Number of Cases to Detect Myocarditis Risk Under Different 
Assumptions of Background Rates
80%power, alpha = 0.05
Required number 
of myocarditis 
casesRequired number of 
COMIRNATY -exposed 
persons, assumed incidence 
(1/100,000 PY)Required number of 
COMIRNATY -exposed 
persons, assumed incidence 
(10/100,000 PY)
14-day risk window
  RR=2.0
RR=5.0
RR=10.0469
52
1823,008,737
2,414,759
767,5242,300,874
241,476
76,753
21-day risk window
  RR=2.0
RR=5.0
RR=10.0319
37
1315,503,995
1,659,091
516,3231,550,400
165,910
51,633
60% power, alpha = 0.05
Required number 
of myocarditis 
casesRequired number of 
COMIRNATY -exposed 
persons, assumed incidence 
(1/100,000 PY)Required number of 
COMIRNATY -exposed 
persons, assumed incidence 
(10/100,000 PY)
14-day risk window
  RR=2.0
RR=5.0
RR=10.0262
28
912,853,495
1,300,255
383,7261,285,350
130,026
38,377
21-day risk window
  RR=2.0
RR=5.0
RR=10.0179
20
78,699,734
896,806
278,020869,974
89,681
27,802
Abbreviations: PY=Person -years; RR=Relative risk
In general, studies C4591009, C4591011, C4591012 and C4591021 will include as many 
individuals as possible who meet the eligibility  criteria during the relevant period of study  
without an upper limit (Table2).AsCOMIRNATY is authorized or approved for use 
without significant contraindications, the number of persons enrolled in the studies depends 
on the following:
090177e197b93e4d\Approved\Approved On: 03-Aug-2021 22:37 (GMT)
FDA-CBER-2021-5683-0950177
BNT162b2
BLA STN 125742/0
M 1.11.3 Response to FDA Information Request
PFIZER CONFIDENTIAL
Page 6The number of persons in the source population eligible for the vaccine under current 
authorization
The number in eligible source population who get vaccinated with COMIRNATY
vaccine
The proportion of vaccinated, eligible individuals within the source population whose 
vaccination is documented in the structured data ; this assumes 50% of vaccines 
administered are COMIRNATYand 60% of eligible persons are vaccinated, so 30% 
of the source population would be included in the COMIRNATY-exposed sample.
Table2.Source Populations for Safety Surveillance Studies
Protocol 
IDTitle Data Source Source Population 
(size and type)Estimated 
Number of 
Individuals 
≤30 yearsaEstimated 
Proportion 
≤30yearsof 
Source 
Population 
Administered 
Pfizer Vaccinea
C4591009 A Non-
Interventional 
Post-Approval 
Safety Study of 
Pfizer-BioNTech
COVID-19 
Vaccine in the 
United StatesFive Data 
Research 
Partners in US 
Sentinel 
SystemPfizer-BioNTech
vaccine recipients 
among 100+ million 
individuals in 
general population 
captured in Sentinel 
system data sources; 
includes individuals 
<18 years of age~ 47 millionb~14.1 million
C4591011 Active Safety 
Surveillance of 
the Pfizer-
BioNTech
COVID-19 
Vaccine in the 
United States 
Department of 
Defense 
Population 
Following 
Emergency Use 
AuthorizationUS 
Department of 
Defense 
(DoD) 
Military 
Health System 
(MHS) 
databasePfizer-BioNTech
vaccine recipients 
among about 10 
million active 
military personnel 
and families in DoD
MHS; includes 
individuals <18 
years of age~ 3.5 million ~1.1 millionb
090177e197b93e4d\Approved\Approved On: 03-Aug-2021 22:37 (GMT)
FDA-CBER-2021-5683-0950178
BNT162b2
BLA STN 125742/0
M 1.11.3 Response to FDA Information Request
PFIZER CONFIDENTIAL
Page 7Table2.Source Populations for Safety Surveillance Studies
Protocol 
IDTitle Data Source Source Population 
(size and type)Estimated 
Number of 
Individuals 
≤30 yearsaEstimated 
Proportion 
≤30yearsof 
Source 
Population 
Administered 
Pfizer Vaccinea
C4591012 Post-Emergency 
Use 
Authorization 
Active Safety 
Surveillance 
Study among 
Individuals in 
the Veteran’s 
Affairs Health 
System 
Receiving 
Pfizer-BioNTech 
Coronavirus 
Disease 2019 
(COVID- 19) 
Vaccine US Veterans 
Health 
Administration 
system Pfizer-BioNTech 
vaccine recipients 
among about 9 
million patients in 
Veterans’ Health 
Administration 
system ≤30 years: 
~ 350,000
≤39 years: 
~ 1.2 millionc≤30 years: 
~105,000
≤39 years: 
~ 360,000c
C4591021 Post Conditional 
Approval Active 
Surveillance 
Study Among 
Individuals in 
Europe 
Receiving the 
Pfizer-BioNTech
Coronavirus 
Disease 2019 
(COVID- 19) 
VaccineElectronic 
healthcare 
databases in 
Netherlands, 
Norway, UK, 
Italy, SpainPfizer-BioNTech
vaccine recipients 
among about 39 
million individuals 
in general 
population; includes 
individuals <18 
years of age~13.5 million ~4.1 millionb
aEstimates represent the numbers of individuals in the population before study protocol eligibility criteria are 
applied.
bEstimates based on assumption that 50% vaccines administered are COMIRNATY and 60% of eligible 
persons are vaccinated
cEstimates based on number of actual Pfizer/BioNTech va ccinations as of July 1, 2021.
Given the anticipated number of persons aged ≤30yearsvaccinated with the 
Pfizer/BioNTech vaccineexpected to be captured in the studies, the studies thatare expected 
to have60% and 80% power to detect risks of different magnitudes assuming a range of rates 
of myocarditis temporally  unrelated to vaccine and risk windows are summarized in Table3.
090177e197b93e4d\Approved\Approved On: 03-Aug-2021 22:37 (GMT)
FDA-CBER-2021-5683-0950179
BNT162b2
BLA STN 125742/0
M 1.11.3 Response to FDA Information Request
PFIZER CONFIDENTIAL
Page 8Table3. Post-Authorization Safety Studies With 60% and 80% Power to Detect 
Myocarditis in Persons ≤30 Yearsa, Under Different Assumptions of 
Background Rates
80% power, alpha = 0.05
Assumedincidence (1/100,000 PY)Assumedincidence (10/100,000 PY)
14-day risk window
  RR=2.0
  RR=5.0
  RR=10.0None
1009, 1021
1009, 1011, 10211009, 1021
1009, 1011 , 10121021
1009, 1011, 1012, 1021
21-day risk window
  RR=2.0
  RR=5.0
  RR=10.0None
1009, 1021
1009, 1011, 10211009, 1021
1009, 1011, 1012, 1021
1009, 1011, 1012, 1021
60% power, alpha = 0.05
Assumedincidence (1/100,000 PY)Assumedincidence (10/100,000 PY)
14-day risk window
  RR=2.0
  RR=5.0
  RR=10.01009
1009, 1021
1009, 1011, 10211009, 1021
1009, 1011, 1012 1021
1009, 1011, 1012, 1021
21-day risk window
  RR=2.0
  RR=5.0
  RR=10.01009
1009, 1011, 1021
1009, 1011, 1012, 10211009, 1011, 10 21
1009, 1011, 1012, 1021
1009, 1011, 1012, 1021
a.  Note:  for study 1012 sample size estimates for persons 39 and under w ere used.
Abbreviations: PY=Person -years; RR=Relative risk
Given that governments are making vaccine available at no cost and administration often 
occurs outside of t ypical health care delivery s ystems, capture of vaccination within 
secondary  structured data such as electronic health care records and insurance claims may  be 
incomplete. Capture is expected to vary  by data source and methods to address this potential 
limitation will be discussed in each pro tocolas applicable .
Response to 1b: Follow -up of myocarditis/pericarditis cases
Pfizer and BioNTech have been exploring the feasibility  of conducting studies using real-
world data sources within the US and EU to identify risk factors for and characterize long-
term outcomes of m yocarditis/pericarditis following vaccination with COMIRNATY.
Within the US, we are conducting a broad feasibility  assessment of healthcare data s ystems 
and external partnerships that permit the evaluation of long- term prognosis of p atients with 
myocarditis/pericarditis temporally  associated with COMIRNATYvaccination. As discussed 
with CDC and FDA, including Drs. Sara Oliver, Tom Shimabukuro, and Naray an Nair as 
well as other colleagues, in an informal meeting on July  19th, we unders tand that the CDC is 
conducting enhanced surveillance within the Vaccine Safet y Datalink (VSD) to follow 
vaccine-associated my ocarditis/pericarditis cases for 3 -6 months for s ymptomatic recovery . 
CDC is also exploring methods to follow cases reported to VA ERs.
090177e197b93e4d\Approved\Approved On: 03-Aug-2021 22:37 (GMT)
FDA-CBER-2021-5683-0950180
BNT162b2
BLA STN 125742/0
M 1.11.3 Response to FDA Information Request
PFIZER CONFIDENTIAL
Page 9To complement the CDC’s efforts, we propose the following:
1.Incorporate m yo-/pericarditis -specific anal ytic endpoints in currently  planned or ongoing 
studies C4591009, C4591011, C4591012, and C4591021 to assess the natural history  of 
post-vaccination m yo-/pericarditis, e.g., recovery  status (medical record review) and/or 
identification of serious cardiovascular outcomes (structured data) within 1 year of m yo-
/pericarditis diagnosis among individuals vaccinated with COMIRNATYas well as 
individuals not vaccinated with a COVID -19 vaccine.
2.An additional US study  to be conducted within the Pediatric Heart Network (PHN), in 
collaboration with the National I nstitutes of Health (NIH)/National Heart, Lung and 
Blood Institute (NHLBI).
This study  is proposed in pa rtnership with the PHN, funded by  the NHLBI /NIH.  The 
PHNis a multi-center consortium of major pediatric cardiovascular academic centers 
in the US and Toronto, Canada that has been conducting studies of cardiovascular 
disease in children since 2001.  The PHN has significant experience with both clinical 
trials and observational studies and has done several studies in collaboration with 
pharmaceutical companies and under FDA regulation. To date, a convenience sample 
of ~130 patients <21 years old with COVID-19 vaccine-associated m yocarditis has 
been collected und er waiver of consent. In response to CBER’s urgent request, b elow 
is aproposal based on an initial discussion between Pfizer and PHN/NIHscientists.
Details of study design and research agreement are under discussion . We will 
promptly notify the Agency  ifthere are any  challenges encountered with this 
proposal.
Specific Aims
AIM 1: To characterize the clinical course of acute post -vaccine m yocarditis in 
children and young adults <21 years old
AIM 2: To characterize potential long -term sequelae of post -vaccine myocarditis, and 
quality of life in children and y oung adults <21 y ears old
AIM 3: To compare long -term effects of post- vaccine my ocarditis with those of non -
vaccine m yocarditis, including m yocarditis arising in COVI D-infected children and 
young adults <21 years old
AIM 4: To identify  possible risk factors for post -vaccine m yocarditis in children and 
young adults <21 years old including age, sex, race, ethnicity , obesity, and other 
factors.
Study Population and Testing
AIM 1:  ~130 patients, alread y identified, who presented to PHN main and auxiliary  
sites after receiving a first or second dose of aCOVID-19 vaccine and were 
diagnosed with my ocarditis.  Additional patients continue to present and could be 
090177e197b93e4d\Approved\Approved On: 03-Aug-2021 22:37 (GMT)
FDA-CBER-2021-5683-0950181
BNT162b2
BLA STN 125742/0
M 1.11.3 Response to FDA Information Request
PFIZER CONFIDENTIAL
Page 10enrolled.  In patien ts presenting with clinical s ymptoms suggesting m yocarditis, all 
had elevated troponin levels, which led to additional investigations including ECG, 
echocardiograph y, and cardiac MRI.
AIM 2:  Myocarditis patients identified in AIM 1 will be followed prospe ctively for 
one year to collect data from assessments, such as lab testing , ECG, Holter or Zio 
patch, echocardiogram, cardiac MRI with gadolinium, and exercise stress test s.  
Standard, age -appropriate tools to assess quality  of life and ps ychosocial functi oning 
will also be administered.
AIM 3:  Unvaccinated my ocarditis comparator group:  I dentify through EHR search 
of approximately  previous 3 y ears about 100 patients with confirmed non- vaccine 
myocarditisand obtain clinical course and long -term sequelae. Parameters for 
comparison (descriptive) will include age at diagnosis, sex, co- morbidities, clinical 
features of acute event (need for pressors, day s in ICU, presence and character of 
dysrhythmias, time to discharge, discharge cardiac meds) , long-term sequelae and 
time to recovery .
COVID Myocarditis sub -group:  Identify through EHR search of previous y ear 
available patients with confirmed SARS -CoV-2 infection and confirmed 
myocarditis (but not MI S-C)
AIM 4:  Prospective patients aged 12-21 years who were vaccinated but did not have 
myocarditis.
Summary of C urrent and P roposed S tudies
Table4summarizes the study  design of the current and proposed studies. Pfizer/BioNTech
believe the sestudies provide a comprehensive plan to satisfy  the above CBER requests. 
Formal protocols will be submitted to FDA when available.
090177e197b93e4d\Approved\Approved On: 03-Aug-2021 22:37 (GMT)
FDA-CBER-2021-5683-0950182
BNT162b2
BLA STN 125742/0
M 1.11.3 Response to FDA Information Request
PFIZER CONFIDENTIAL
Page 11Table4. Current and Proposed Post-marketing Safety Surveillance Studies
C4591009 C4591011 C4591012 C4591021 C4591021 substudy Pediatric Heart 
Network Study
Study title A Non-Interventional 
Post-Approval Safety 
Study of Pfizer -
BioNTech COVID-19 
Vaccine in the United 
StatesActive Safety 
Surveillance of the 
Pfizer-
BioNTech COVID-19 
Vaccine in the United 
States Department of 
Defense Population 
Following Emergency 
Use Authori zationPost-Emergency Use 
Authorization Active 
Safety Surveillance 
Study among 
Individuals in the 
Veteran’s Affairs 
Health System 
Receiving 
Pfizer-BioNTech Coron
avirus Disease 2019 
(COVID-19) VaccinePost Conditional 
Approval Active 
Surveillance Study 
Among Individuals in 
Europe Receiving the 
Pfizer-
BioNTech Coronavirus 
Disease 2019 (COVID -
19) VaccinePost Conditional 
Approval Active 
Surveillance Study 
Among Individuals in 
Europe Receiving the 
Pfizer-
BioNTech Coronavirus 
Disease 2019 (COVID -
19) Vaccine (Substudy)TBD
Study design Retrospective cohort 
studyRapid-cycle, 
longitudinal, 
observational cohort 
studyRapid-cycle, 
longitudinal, 
observational cohort 
studyRetrospective cohort 
studyNatural history cohort 
study withina 
retrospective cohort 
studyProspective cohort 
study 
Comparator group Risk:unvaccinated 
comparator
Follow up:myocarditis 
in unvaccinated 
comparatorRisk:Self-controls, 
unvaccinated 
comparator and 
influenza vaccine 
comparator
Follow up:myocarditis
/pericarditis casesRisk:Self-controls, 
unvaccinated 
comparator and 
influenza vaccine 
comparator
Follow up:myocarditis
/pericarditis casesRisk:unvaccinated 
comparator
Follow up:myocarditis 
in unvaccinated 
comparatorRisk:unvaccinated 
comparator
Follow up:myocarditis 
in unvaccinated 
comparatorRisk: unvaccinated 
comparator
Follow up: myocarditis 
in unvaccinated 
comparator 
Suitability for 
identifying risk factors 
(Y/N)Y TBD TBD N Y Y
Suitability to assess 
change in risk over time 
(Y/N)Y Y Y Y Y Y
Information to be 
collected at baselineDemographics and 
clinical characteristics 
includinghealth care 
utilization, comorbiditie
s,comedications, andco
ncurrentvaccinationsDemographics andclini
cal characteristics 
includinghealth care 
utilization, 
comorbidities, and 
concurrent vaccinationsDemographics and 
clinical characteristics 
includinghealth care 
utilization, 
comorbidities, and 
concurrent vaccinationsDemographics and 
clinical characteristics 
includinghealth care 
utilization, comorbiditie
s,comedications, andco
ncurrentvaccinationsDemographics and 
clinical characteristics 
including comorbidities, 
comedications, and 
concurrent vaccinationsDemographics and 
clinical characteristics 
including comorbidities, 
comedications, and 
concurrent vaccinations
090177e197b93e4d\Approved\Approved On: 03-Aug-2021 22:37 (GMT)
FDA-CBER-2021-5683-0950183
BNT162b2
BLA STN 125742/0
M 1.11.3 Response to FDA Information Request
PFIZER CONFIDENTIAL
Page 12Table4. Current and Proposed Post-marketing Safety Surveillance Studies
C4591009 C4591011 C4591012 C4591021 C4591021 substudy Pediatric Heart 
Network Study
Frequency of data 
collectionRetrospective Retrospective Retrospective Retrospective Retrospective 3, 6, and 12 months 
after diagnosis of 
myocarditis
Method of data 
collectionRisk:structured data
Follow up:structured 
dataRisk:structured data
Follow up:medical 
recordsRisk:structured data
Follow up:medical 
recordsRisk:structured data
Follow up:medical 
recordsRisk:structured data
Follow up:medical 
recordsPrimary data collection
Length of follow up Up to 1 year Up to 30 months Up to 30 months Up to 2 years 1 year 1 year
Information collected at 
follow upClinical outcomes Clinical outcomes, labs, 
imagingClinical outcomes, labs, 
imagingClinical outcomes, labs, 
imagingTreatment for 
myocarditis and 
pericarditis, clinical 
outcomes, recoveryClinical outcomes (eg, 
resolution, long term 
sequelae), labs, 
imaging, quality of life 
parameters 
Assessment of impact 
on daily life (Y/N)N N N N TBD Y
Study timelines and 
milestone datesProtocol: 08/31/2021
Monitoring report: 
10/31/2022
Interim report: 
10/31/2023
Final study report: 
10/31/2025Protocol: 01/29/2021
Interim report 1: 
12/31/2021
Interim report 2: 
06/30/2022
Interim report 3: 
12/31/2022
Final study report: 
12/31/2023Protocol: 01/29/2021
Interim report 1: 
06/30/2021
Interim report 2: 
12/31/2021
Interim report 3: 
06/30/2022
Interim report 4: 
12/31/2022   
Final study report: 
12/31/2023Protocol: 05/20/2021
Progress report: 
09/30/2021
Interim report 1: 
03/31/2022
Interim report 2: 
09/30/2022
Interim report 3: 
03/31/2023
Interim report 4: 
09/30/2023
Interim report 5: 
03/31/2024
Final study report: 
09/30/2024Protocol:  12/31/ 2021
Final report:  
09/30/2024Protocol: 11/30/2021
Final report: 10/ 31/2025
Abbreviations: TBD=To be determined; Y=Yes; N=No.
090177e197b93e4d\Approved\Approved On: 03-Aug-2021 22:37 (GMT)
FDA-CBER-2021-5683-0950184
BNT162b2
BLA STN 125742/0
M 1.11.3 Response to FDA Information Request
PFIZER CONFIDENTIAL
Page 132.2. CBER Request2
3.Please also provide your plans to characterize subclinical cases of myocarditis.
Sponsor Response
Myocarditis and pericarditis are inflammatory  conditions of the my ocardium and the 
pericardium respectively . A definitive diagnosis of my ocarditis requires histological or 
immunohistological confirmation of an endom yocardial biopsy or other tissue specimen (e.g. 
from an autops y). Due to their invasive nature, biopsies are rarel y obtained, and therefore a 
diagnosis of m yocarditis is often based upon a compatible clinical scenario associated with 
noninvasive biomarker and imaging feat ures.2This results in case definitions that are very  
complex, potentially  based on multiple parameters (e.g. Brighton Collaboration definitions).3
Abnormal ECG, echocardiogram, or troponin findings consistent with my ocarditis with no 
cardiac symptoms have been reported in association with SARS -CoV-2 infection4but are not 
well characterized phenomena , and there is no widely  accepted definition of subclinical 
myocarditis.
Many different ECG a bnormalities can occur in sy mptomatic m yocarditis, none of which a re 
pathognomonic for the condition.5Similarly, troponin levels can be elevated in a number of 
cardiac and non -cardiac conditions, as well as spuriously .6One study , in 1993 patients 0 to 
21 years of age without history  of cardiac disease, evaluated tropon in T levels in those with 
both cardiac and noncardiac presentations. Troponin was elevated in 9% of patients overall, 
only 60% of whom had a cardiac diagnosis; furthermore, a cardiac diagnosis was made in 
12% of those with a normal troponin level.7Hence neither is specific to symptomatic 
myocarditis, and certainly not subclinical m yocarditis, which makes them unsuitable to serve 
as screening tests for a rare entity  like myocarditis.The background incidence of troponin 
abnormalities in vaccine recipients i s unknown and likely  heterogeneous. 
In this context, a prospective study  to detect subclinical my ocarditis is not practicall y feasible 
at this time, as it would need to enroll a large number of participants, and if performed, 
would not y ield clearl y interpretable data. Furthermore, spurious findings from non- specific 
positive laboratory  results could undermine vaccine uptake and cause unnecessary  work ups 
and vaccinee anxiety .
We therefore propose to anal yze troponin I levels at a central laboratory  in samplesof stored 
sera (drawn <1 year ago) in 12-30- year-old individuals participating in BNT162b2 studies, 
prior to receipt of BNT162b2 (i.e. either at baseline, or at an y visit for placebo recipients). 
This is planned to include 3000 samples, stratified equ ally in the 12-17 -, 18-24-and 25-30-
years age groups. This sample size will provide 95% probability  of observing one abnormal 
result amongst the overall sample if the background rate of abnormality is 0.1%, amongst 
each age stratum if the background rate is 0.3%, as follows ( Table5).
090177e197b93e4d\Approved\Approved On: 03-Aug-2021 22:37 (GMT)
FDA-CBER-2021-5683-0950185
BNT162b2
BLA STN 125742/0
M 1.11.3 Response to FDA Information Request
PFIZER CONFIDENTIAL
Page 14Table5.Probability of Observing 1 Abnormal Result with Given Abnormal 
Result Rates (%)
Abnormal Result Rate (%) N=1000 N=3000
0.01 9.5 25.9
0.05 39.4 77.7
0.1 63.2 95.0
0.2 86.5 99.8
0.3 95.0 100.0
0.4 98.2 100.0
0.5 99.3 100.0
Once we have ascertained timelines in which this can be performed, we will communicate 
them to the Agency .
This will enable us to determine the background rate of abnormality of a potential 
non-invasive biomarker in the relevant population . These data are critical to determining 
what sample size might be required for a potential future clinical study  to distinguish a true 
signal of cardiac findings in the absence of compatible clinical signs and s ymptoms. 
In the meantime, we areaddingmyocarditis and pericarditis as AESI s in all protocols with 
ongoing administration of study  vaccines, as well as the following requi rement:
“Any study participant who reports acute chest pain, shortness of breath, palpitations, or 
any other symptom(s) that might be indicative of my ocarditis or pericarditis within 
4weeks of a study  vaccination should be specifically  evaluated, preferab ly by a 
cardiologist, for possible my ocarditis or pericarditis.”
In addition to a clinical evaluation, the following should be performed:
Electrocardiogram (ECG)
Troponin level
If myocarditis or pericarditis are suspected based upon the initial evaluation, the 
following should also be performed:
Cardiac echocardiogram, and/or
Cardiac magnetic resonance study
Results of these investigations will be recorded in the Case Report Form.”
In addition, we are including routine ECGs in the Study BNT162-17 (submitted to BB-I ND 
19736 on 22 July 2021; SN 0416), which will start shortly, evaluating versions of BNT162b2 
encoding the delta variant S protein, or the alpha and delta variants. This study consists of two 
parts, Part A and Part B, and will evaluate the safety and immunogenicity of a third injection of 
the multivalent vaccine BNT162b2 (B.1.1.7 + B.1.617.2), and the safety and immunogenicity 
of a third injection of the monovalent vaccin
e BNT162b2 (B.1.617.2), in 
090177e197b93e4d\Approved\Approved On: 03-Aug-2021 22:37 (GMT)
FDA-CBER-2021-5683-0950186
BNT162b2
BLA STN 125742/0
M 1.11.3 Response to FDA Information Request
PFIZER CONFIDENTIAL
Page 15participants who have received two doses of the parent vaccine BNT162b2 at 30 µg, at least 
6 months after the second dose of BNT162b2. In addition, it will evaluate the safet y and 
immunogenicit y of a two -dose regimen (21- days apart) of BNT162b2 (B.1.1.7 + B.1.617.2) 
in participants who have not r eceived prior COVID -19 vaccination. Part A will include ~120 
participants 18 to 55 y ears of age: 100 will have been previousl y vaccinated, 80 of whom 
will receive a 3rd dose and 20 of whom will receive a 3rd and 4th dose; 20 vaccine-naïve 
participants will receive 2 primary  doses. Part B will include ~1125 participants: 750 will 
have been previousl y vaccinated and will receive a 3rd dose; 375 vaccine -naïve participants 
will receive 2 primary  doses. ECGs will be obtained for all participants at screening, on the 
day of each vaccination and 1 week after each vaccination.
Finally, Pfizer/BioNTech is also propos ing (in response to a separate CBER information 
request received on 30 July2021)to include blood draws in Studies C4591007 and 
C4591031 to obtain serum samples for potential future troponin testing . Determination 
whether to test some or all of these samples for troponins would be predicated on the anal ysis 
of background rate of troponin abnormalities in study  participants and expert advic e.
3.REFERENCES
1VRBPAC Vaccine Safety Updates (slide 17) . 10June2021. Accessed on 
03 August 2021 at https://www.fda.gov/media/150054/download
2Bozkurt B, Colvin M, Cook J, et al.American Heart Association Committee on Heart 
Failure and Transplantation of the Council on Clinical Cardiology; Council on 
Cardiovascula r Disease in the Young; Council on Cardiovascular and Stroke Nursing; 
Council on Epidemiology and Prevention; and Council on Quality  of Care and 
Outcomes Research. Current Diagnostic and Treatment Strategies for Specific Dilated 
Cardiomy opathies: A Scienti fic Statement From the American Heart Association. 
Circulation. 2016 Dec 6;134(23):e579 -e646.
3Myocarditis/Pericarditis Case Definition: www.brightoncollaboration.us . Accessed on 
20 July 2021
4Daniels CJ, Rajpal S, Greenshields JT, et al.; Big Ten COVID -19 Cardiac Registry  
Investigators. Prevalence of Clinical and Subclinical My ocarditis in Competitive 
Athletes With Recent SARS -CoV-2 Infection: Results From the Big Ten COVID -19 
Cardiac Registry . JAMA Cardiol. 2021 May  27:e212065.
5Buttà C, Zappia L, Laterra G, et al. Diagnostic and prognostic role of 
electrocardiogram in acute my ocarditis: A comprehensive review. Ann Noninvasive 
Electrocardiol. 2020 May ;25(3):e12726. doi: 10.1111/anec.12726.
090177e197b93e4d\Approved\Approved On: 03-Aug-2021 22:37 (GMT)
FDA-CBER-2021-5683-0950187
BNT162b2
BLA STN 125742/0
M 1.11.3 Response to FDA Information Request
PFIZER CONFIDENTIAL
Page 166Roongsritong C, Warraich I , Bradley C. Common causes of troponin elevations in the 
absence of acute m yocardial infarction: incidence and clinical significance. Chest. 
2004 May ;125(5):1877 -84. 
7Dionne A, Kheir JN, Sleeper LA, et al. Value of Troponin Testing for Detection of 
Heart Disease in Previous ly Healthy Children. J Am Heart Assoc. 2020 Feb 
18;9(4):e012897.
090177e197b93e4d\Approved\Approved On: 03-Aug-2021 22:37 (GMT)
FDA-CBER-2021-5683-0950188
Document Approval Record
Document Name:	
 
  
    !"#$% &
' ()*+(,-#(./0$(-(
Document Title:	
 
  
    !"#$% &
' ()*+(,-#(./0$(-(
Signed By: Date(GMT) Signing Capacity
1 &223 2 -4
%
(-( ((54*5- 
2 %66 %72
090177e197b93e4d\Approved\Approved On: 03-Aug-2021 22:37 (GMT)
FDA-CBER-2021-5683-0950189