100A BLA 125742 0 08 20 2021 Memo Other

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Center for Biologics Evaluation and Research  
 Laboratory Quality System  
COMIRNATY (BioNTech Manufacturing GmbH) COVID -19 mRNA Vaccine  
Document ID: 1 25742       Revision Level:   01 
Revision Date:         Effective Date:  
Total Pages:  5  (including this cover page)  
 
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Author Approval:    _______________  
 
- 1 - WARNING:  The information contained in this document is CONFIDENTIAL and should not be released.  See FOIA exemption 
regarding circumvention.  
 
Product Testing Plans  document how CBER currently anticipates regulating licensed products including the circumstances under 
which CBER testing may be used to evaluate a lot of licensed product.  It is the responsibility of each Product Office to dev elop 
Product  Testing Plans for the licensed products under its purview.  
 
Product Trade Name:  COMIRNATY  
License Product Name 
(Proper Name):  COVID -19 mRNA Vaccine  
Product ID (LQDB):  2501  
License Number:  2229  
STN (RMS -BLA):  125742  
Applicant (Supplier):  BioNTech Manufacturing GmbH    
  
Signatures Required to Approve or Update this Product Testing Plan  
Product Office Director  
(or designee):  Marion Gruber, PhD  
Product Division Director : Jerry P. Weir, PhD  
Testing Division Director :  Maryna Eichelberger, PhD  
Director, DMPQ/OCBQ:  John A. Eltermann, Jr., MS, RPh  
Center Lab Quality Mgr:  Suzanne Carter   
 
Mode of Product Regulation  
Based upon Product Office assessment of the product, 
including relevant manufacturing, safety, clinical and other 
considerations, determine which form of CBER review and or release of manufactured product lots is necessary.  Lot Release  – Manufacturer may not distribute product until 
receiving lot -specific release from CBER.  
Surveillance  – Manufacturer may distribute product without 
lot-specific release from CBER.  Manufacturer is required, 
according to the terms of the license, to periodically provide 
CBER  with lot -specific testing information and possibly 
samples.  
Exempt – Manufacturer is free to distribute product post-
licensure without supplying any additional information or 
samples to CBER.  Lot Release   
     Protocol Review   
     Protocol Review and  
        Confirmatory CBER Testing   
----------------------------------------   
Alternative to Lot Release   
     Surveillance   
     Exempt   
     
 
 
FDA-CBER-2021-5683-1150324
Title:  COMIRNATY (BioNTech Manufacturing GmbH) COVID -19 mRNA Vaccine  
Document ID: 125742  
Revision Level: 0 1 
Effective Date:         Page 2 of 5 
 
 
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Justification for Mode of Regulation:  
Briefly, describe how the indicated Mode of Regulation supports CBER’s mission to ensure the purity, potency, safety, efficacy, 
and availability of this biological product including justification for any confirmatory CBER product testing, per 21 CFR 610.2(a ). 
Additionally, for products on Surveillance, summarize the requirements for submission of lot -specific information and sample (if  
required) as described in the license.  
Brief Description: COMIRNATY is a vaccine indicated for active immunization to prevent 
coronavirus disease 2019 (COVID -19) caused by severe acute respiratory syndrome 
coronavirus 2 (SARS CoV 2) in individuals 16 years of age and older.  
 
COMIRNATY is supplied as a frozen suspension in multiple dose vials; each vial must be diluted 
with 1.8 mL of sterile 0.9% Sodium Chloride Injection, USP prior to use to form the vaccine. Each dose of COMIRNATY contains 30 mcg of a nucleoside-modified messenger RNA (modRNA) encoding the viral spike (S) glycoprotein of SARS -CoV-2.  
 
Each dose of the COMIRNATY also includes the following ingredients: lipids (0.43 mg (4 -
hydroxybutyl)azanediyl)bis(hexane-6,1-diyl)bis(2-hexyldecanoate), 0.05 mg 2[(polyethylene 
glycol)-2000] -N,N-ditetradecylacetamide, 0.09 mg 1 ,2-distearoyl-sn -glycero-3-phosphocholine, 
and 0.2 mg cholesterol), 0.01 mg potassium chloride, 0.01 mg monobasic potassium 
phosphate, 0.36 mg sodium chloride, 0.07 mg dibasic sodium phosphate dihydrate, and 6 mg 
sucrose. The diluent (0.9% Sodium Chloride Injection, USP) contributes an additional 2.16 mg 
sodium chloride per dose.  
 COMIRNATY does not contain a preservative. The vial stoppers are not made with natural 
rubber latex.  
 Dosage and Administration:  COMIRNATY multiple dose v ial contains a volume of 0.45 mL, 
supplied as a frozen suspension that does not contain preservative (p rior to dilution) . Each vial 
must be thawed and diluted prior to administration.  
 
Dilution 
• Dilute the vial contents using 1.8 mL of 0.9% Sodium Chloride Injection, USP to form COMIRNATY. Do not add more than 1.8 mL of diluent. 
• ONLY use 0.9% Sodium Chloride Injection, USP as the diluent. Do not use bacteriostatic 0.9% Sodium Chloride Injection or any other diluent.  
• After dilution, 1 vial contains 6 doses of 0.3 mL.  
 COMIRNATY is a suspension for injection. After preparation, a single dose is 0.3 mL.  It is 
administered intramuscularly as a series of 2 doses (0.3 mL each) three weeks apart.   
 Mode of Lot Release :  Protocol review and c onfirmatory CBER testing 
The following discussion forms the rationale for the testing plan for release of this vaccine.  
Safety and Purity – The safety and purity of the vaccine will be evaluated from information 
provided in the lot release protocols for te sts performed on the fi lled vaccine and BNT162b2 
FDA-CBER-2021-5683-1150325
Title:  COMIRNATY (BioNTech Manufacturing GmbH) COVID -19 mRNA Vaccine  
Document ID: 125742  
Revision Level: 0 1 
Effective Date:         Page 3 of 5 
 
 
Document Uncontrolled if Printed 
 drug substance . Refer  to the appendices at the end of this document for a description of the 
items to review on the lot release protocol.  
 
Potency and Identity – The potency and identity of the vaccine will be evaluated from 
information provided in the lot release protocol for tests performed on the t filled vaccine and 
BNT162b2 drug substance.  Refer to the appendices at the end of this document for a 
description of the items to review on the lot release prot ocol.  
 
 
Anticipated CBER product testing:  
List laboratory evaluations to be performed at CBER.   
Document  
ID number  Test Method  Test 
Specifications  Testing 
Frequency1 
NOTE: Testing will be added as testing methods are brought on -line.   
 
Lot Testing algorithm(s):  
For each Test Method listed above describe how the indicated frequency of testing supports the assurance of product quality.   
For each method with testing frequencies other than 100%, describe how lots are pre -selected for testing, i.e. random number 
table, every nth lot submitted, first X lot(s) submitted per time period, decision tree, etc.  
1 Testing may be performed any time an atypical observation is made during lot release protocol review. 
2 The  lots received, then  
 
 
Conditions anticipated to require temporary over -ride of algorithm:  
Specify conditions justifying algorithm over -ride; i.e. Public Health Considerations (e.g. temporary product shortage, sudden 
increase in demand), Operational Considerations (e.g. temporary unavailability of resources), Lot -specific Compliance 
Considerations (e.g. questions raised during lot release protocol review).  
• Public Health Considerations (e.g., temporary product shortage, sudden increase in demand)  
• Operational Considerations (e.g., temporary unavailability of resources   
• Lot-specific Compliance Considerations (e.g., questions raised during lot release protocol review)  
 
  
(b) (5), (b) (7)(E)
(b) (5), 
(b) (7)(E)
(b) (4), (b) (5), (b) (7)(E)
FDA-CBER-2021-5683-1150326
Title:  COMIRNATY (BioNTech Manufacturing GmbH) COVID -19 mRNA Vaccine  
Document ID: 125742  
Revision Level: 0 1 
Effective Date:         Page 4 of 5 
 
 
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 Specifications for Review of Lot Release Protocols  
Note:  The LRS code – Action/Test  indicates under which category this test result will be reviewed.  All 
tests included in this category for the division indicated will be reviewed and found acceptable prior to 
protocol sign off for this category.  
 
Appendix 1:  Specifications for tests o n Filled Vaccine   
Test Specifications  LRS code - Action/Test  
These tests are reviewed by personnel in Division of Biological Standard and Quality Control  (DBSQC )  
Appearance  White to off -white  suspension  Appearance/Volume  
Appearance (Visible  
Particulates)  May contain white to off -white  opaque 
amorphous  particles  Appearance/Volume  
Subvisible Particles  Appearance/Volume  
pH 6.9 - 7.9 Chemical Assay  
Osmolality  Chemical Assay  
Lipid nanoparticles  (LNP)  Size LNP 
LNP Polydispersity  LNP 
RNA Encapsulation  RNA 
content/encapsulation  
RNA content  RNA 
content/encapsulation  
ALC-0315 content  Lipid content/identity  
ALC-0159 content  Lipid content/identity  
DSPC content  Chemical Assay  
Cholesterol content  Chemical Assay  
Vial content  Appearance/Volume  
Lipid identities  Retention times  consistent with  
references (ALC- 0315,  ALC-0159, 
Cholesterol,  DSPC)  Lipid content/identity  
Identity of encoded  RNA 
sequence  Identity  
In Vitro Expression  In vitro expression  
RNA Integrity  RNA integrity  
Bacterial Endotoxin  Purity -LAL 
Sterility  No growth observed  Sterility  
 
  
(b) (4)
(b) (4)
(b) (4)
FDA-CBER-2021-5683-1150327
Title:  COMIRNATY (BioNTech Manufacturing GmbH) COVID -19 mRNA Vaccine  
Document ID: 125742  
Revision Level: 0 1 
Effective Date:         Page 5 of 5 
 
 
Document Uncontrolled if Printed 
 Appendix 2:  Specifications for tests on BNT162b2 Drug Substance   
Test Specifications  LRS code - Action/Test  
These tests are reviewed by personnel in DBSQC  
Clarity  Appearance/Volume  
Coloration  Appearance/Volume  
pH Chemical Assay  
Content (RNA  Concentration)  RNA 
content/encapsulation  
Identity of Encoded  RNA 
Sequence  Identity  
RNA Integrity  RNA integrity  
5’- Cap 
Poly(A) Tail  
Residual DNA Template  Residual n ucleic acid 
Residual dsRNA  Residual nucleic acid  
Bacterial Endotoxin  Purity -LAL 
Bioburden  Sterility  
 
Changes since the last revision  
• N/A New document  
 
 
(b) (4)
(b) (4)
FDA-CBER-2021-5683-1150328