4 BLA 125742 0 06 03 2021 First Committee Meeting Summary

Pfizer Documents (PHMPT/FDA)

Pfizer Bla Submission

Pfizer 16 Plus Documents

9

Document text

First Committee  Meeting Summary  
 
Application number:   BLA STN 125742.0   
Product name:    COVID -19 mRNA Vaccine (COMIRNATY)  
Proposed Indication:  Active immunization to prevent COVID -19 caused by SARS -
CoV-2 in individuals ≥16 years of age  
Applicant:     BioNTech Manufacturing GmbH    
Meeting date & time:  June 3, 2021; 4:00PM  - 5:30PM  EDT 
Committee Chair:  Ramachandra Naik, Ph.D.   
Meeting Recorder s:  CAPT Michael Smith, Ph.D. and  
 Laura Gottschalk, Ph.D.  
  Table 1: Review Committee  (attendees are listed in bold font)  
Review responsibility  Committee Member  Team Leader /  Supervisor (s) Division Director  
Chairperson   Ramachandra Naik,  PhD TL:  Kirk Prutzman,  PhD 
BC:  Elizabeth Sutkowski , PhD  DD:  Loris McVittie , PhD  
SA:  Kirk Prutzman,  PhD (acting)  
Regulatory Project  
Managers  CAPT Mike Smith,  PhD  
Laura Gottschalk,  PhD TL:  Kirk Prutzman,  PhD 
BC:  Elizabeth Sutkowski,  PhD DD:  Loris McVittie,  PhD 
SA:  Kirk Prutzman,  PhD (acting)  
Clinical  Susan Wollersheim,  MD 
CAPT Ann Schwartz,  MD TL:  Lucia Lee,  MD 
BC: Maria Allende,  MD DD:  Doran Fink,  MD, PhD   
Product (CMC)  
 
DVP Regulatory coordinator , 
DVP Product Specialist  Haruhiko Murata,  MD, PhD 
Xiao Wang,  PhD 
Anissa Cheung,  MSc BC:  Keith Peden,  PhD 
BC:  Keith Peden,  PhD DD:  Jerry Weir,  PhD 
DDD:  Robin Levis,  PhD  
DS and DP release assays  
DS and DP release assays  
DS and DP release assays  
DS and DP release assays  
DS and DP release assays  
LRP and Testing Plan Dev.  Hsiaoling Wang,  PhD  
Emnet Yitbarek,  PhD  
Karla Garcia,  MS 
Anil Choudhary,  PhD , MBA  
Esmeralda Alvarado,  PhD 
Marie Anderson,  PhD  TL:  Tao Pan,  PhD 
TL:  Tao Pan,  PhD 
BC:  CDR James Kenney,  DSc 
BC:  Muhammad Shahabuddin, PhD  
BC:  Muhammad Shahabuddin, PhD  
Maryna Eichelberger,  PhD  DD:  Maryna Eichelberger,  PhD 
DDD: N/A  
 
  
  
Toxicology  Nabil Al -Humadi, PhD  BC:  Martin Green, PhD  DD:  Doran Fink,  MD, PhD  
Statistics, both Clinical data  
& assays  Lei Huang,  PhD BC:  Tsai-Lien Lin , PhD  DD:  John Scott , PhD  
DDD:  Shiowjen Lee, PhD  
Epidemiology/  
Pharmacovigilance  Deborah Thompson,  MD,  
MSPH  TL:  LCDR Jane Baumblatt, MD  
BC:  Manette Niu,  MD  DD: Narayan Nair, MD  
DDD: Meghna Alimchandani, MD   
DMPQ Reviewer /Inspector  
 DMPQ Reviewer /Inspector  
 
DMPQ Reviewer  
DMPQ Inspector  
DMPQ  Inspector  
DMPQ Inspector  
Lot Release  
DMPQ RPM  Kathleen Jones , PhD 
 
Laura Fontan, PhD  
 
Gregory Price,  PhD 
Zhongren Wu , PhD  
CDR Donald  Ertel , MS 
Ekaterina Allen , PhD  
Cheryl Hulme  
Iryna Zubkova , PhD TL: Nicole Li   
BC:  Lori Peters,  MS  
TL:  CDR Donald Ertel , MS 
BC:  Lori Peters , MS  
 
  BC:  Anthony Lorenzo  
BC:  Joseph Quander  
BC:  James Crim  DD:  John Eltermann,  RPh, MS  
DDD: Carolyn Renshaw   
BIMO  Haecin Chun , 
MT(ASCP)SBB, MS  BC:  Dennis Cato   DD:  Carrie Mampilly,  MPH  
APLB Labeling  
reviewer  CDR  Oluchi Elekwachi,  
PharmD, MPH  
Dana Jones  BC:  Lisa Stockbridge,  PhD DD:  Robert Sausville  
Container Labeling  Daphne Stewart  BC:  Timothy Nelle, PhD  DD:  Loris McVittie , PhD  
Electronic integrity  CDR David Schwab, MSIS  Loris McVittie , PhD  DD:  Loris McVittie,  PhD 
CDISC consult  Brenda Baldwin,  PhD 
Kirk Prutzman,  PhD BC:  Elizabeth Sutkowski,  PhD DD:  Loris McVittie,  PhD 
FDA-CBER-2021-5683-0652168
STN 125742/0 First Committee Meeting dated June 3, 2021  
 
First Committee Meeting Agend a 2 Other attendees that were not listed in the review committee table:  Maureen Hess,  Leslie 
Taylor, Laura Montague,  Konstan tin Vernik, Cassandra Overking, David Cho, Varsha 
Garnepudi , Hector Izurieta, Jeff Roberts, Joseph Kulinski , Nicki DeVore, Douglas Pratt , Sara 
Gagneten, D avid Rouse, Sudhakar Agnihothram , Tatiana ClarodaSilva, S wati Verma  and 
Nadine Kaelber  
 
Review Timetable ( PDUFA Milestones are in blue ) 
 Review Milestone       Target Due Date  
Submitted 
Roll 1  Submission :      06-MAY -2021  
Roll 2 Submission (final):     18- MAY -2021  
Received:       18- MAY -2021  
Committee Assignment:      09- JUN- 2021 
First Committee Meeting:      03-JUN- 2021 
Proper name designation:      08-JUN- 2021  
Filing checklist /reviews complete:     23- JUN- 2021  
Filing Meeting:       29-JUN- 2021  
Filing Action:       1 6-JUL-2021 
Deficiencies Identified:       31-JUL -2021 
Initial proprietary name review:     1 6-AUG -2021  
Primary Draft Reviews & Reviewer Reports Due   
(4 days prior to Mid- Cycle meeting):    25-AUG -2021  
Mid-Cycle Meeting (Internal):     31-AUG -2021  
Mid-Cycle Communication :     13-SEP- 2021 
Final draft primary reviews with supervisory  
Concurrence  (upload not required) :   01-SEP- 2021 
PLI Inspections completed:     30-JUL-2021  
BiMO Inspections completed:     30-JUL-2021  
PeRC briefing materials due to PeRC:    27- JUL-2021  
PeRC Meeting:       10-AUG -2021 
Final reviews & addenda signed & uploaded:   15-SEP- 2021 
Lot release protocol & testing plan finalized:   30-AUG -2021  
Notify OCOD of pending approval:    30
 -AUG -2021  
Draft SBRA       30-AUG -2021  
Labeling Comments to Applicant:     30-AUG -2021  
Notify Applicant of PMC/PMR:     30-AUG -2021  
Targeted Action Due Date (ADD)   30-SEP- 2021 
PDUFA ADD:       16-JAN- 2022  
 Table 2:  Scheduled Meetings   
PDUFA Meetings:  
• First Committee Meeting:  June 3, 2021,  4:00PM – 5:30PM  
• Filing Meeting:  June 29, 2021,  2:00PM – 3:30PM  
FDA-CBER-2021-5683-0652169
STN 125742/0 First Committee Meeting dated June 3, 2021  
 
First Committee Meeting Agend a 3 • Internal Mid -Cycle:  August 31, 2021,  2:00PM – 3:30PM  
• Mid-Cycle Communication:  September 13 , 2021,  3:00PM – 4:00PM  
Monthly Committee Meetings:  
• July 15, 2021,  3:30PM – 5:00PM  
• August 9, 2021,  1:30PM – 3:00PM  
• September 10, 2021,  12:30PM – 2:00PM  
Labeling Meetings:  
• August 4,  2021,  3:00PM – 5:00PM  
• August 6,  2021,  3:00PM  – 5:00PM  
• August 11,  2021,  3:00PM – 5:00PM  
• August 16, 2021, 11:00AM  – 12:30PM (Carton & Container)  
• August 18, 2021, 3:30PM – 5:00PM (Carton & Container)  
• September 2, 2021,  4:00PM – 5:30PM  
• September  7, 2021, 2:00PM – 4:00PM  
• September 21, 2021, 3:00PM – 5:00PM  
 
Background and Purpose:  
This meeting was  to discuss the new original BLA (STN 125742/0) from BioNTech 
Manufacturing GmbH (in partnership with Pfizer, Inc.) for COVID -19 mRNA Vaccine 
(COMIRNATY, pronounced “koh- MER nah -tee”), for active immunization to prevent COVID -19 
caused by SARS- CoV-2 in individuals ≥16 years of age.  This is a Rolling BLA submission , so it 
will be handled in RMS -BLA, not eMRP . The first roll  containing eCTD sections 2, 4, and 5 w as 
submitted and received on May 6, 2021. The second and final roll containing eCTD Section 3 
(and the rest of Section 1 items) was submitted and received on May 18 , 2021.   
 The purpose of this  First Committee Meeting was to discuss the milestones, roles and 
responsibilities of each member of the review team.  
 Discussion S ummary:  
The Chair provided a brief overview of the submission and highlighted several  important 
points for the review of the BLA.  
• A table of the full  review committee and their corresponding team leaders, 
managers and directors , was included in the agenda for the meeting. The review 
committee was asked to review it and let the regulatory review team know if 
anything needs to be corrected.  
• The submission is a n 8-month Priority Review BLA with a PDUFA Action Due 
Date ( ADD) of January 16, 2022 . However, the targeted ADD is September 30, 
2021.   
• The Chair summarized the review milestones  (as shown on page 2).  
FDA-CBER-2021-5683-0652170
STN 125742/0 First Committee Meeting dated June 3, 2021  
 
First Committee Meeting Agend a 4 • A Late Cycle Meeting (LCM) will likely not take place since the PDUFA deadline 
for the LCM is  November 1, 2021, and this is  after the Target Action Due Date of 
September 30, 2021.  
• In an effort to reduce the burden for reviewers, the Chair questioned whether 
Filing Checklists  should be completed for this submission. Management said that 
they will check with CBER IOD about the requirement for Filing Checklists and let 
the review team know.    
• It was confirmed that a n Advisory Committee Meeting will not be needed for the 
BLA since five Advisory Committee Meetings would have occurred from October 
22, 2020 to June 10, 2021 to di scuss the development, Emergency Use 
Authorization and licensure of COVID -19 vaccines.  
• The Chair asked about the best  method for the review team to provide regular 
status updates to Management. Management  will discuss this internally and will 
provide an answer to the review team soon .  
• The Chair announced that an internal meeting is scheduled for Friday, June 4, 
2021, with the DVP and DBSQC teams to discuss tests that will be part of the lot release protocol and in -support testing.  
Updates from  Discipline Reviewers:  
1. Chair (Ramachandra Naik) :   
 
• See discussion summary above.  
2. Clinical ( Susan Wollersheim  and Ann Schwartz ): 
• The clinical reviewers have found the review  to be more burdensome than 
expected since much of  the clinical information is referenced from the prior 
IND and EUA , plus  the clinical information was not well organized and a 
summary document would be helpful . They will discuss internally to see if 
there is something that can be requested from the Applicant that can aid 
them in their review, including potentially having a teleconference with the Applicant .  The clinical team thought they will likely have a safety data 
information request, but they were going to discuss with the statistical team first.   
3. CMC ( Haruhiko Murata and Xiao Wang ): 
• No issues have been identified.    
 
FDA-CBER-2021-5683-0652171
STN 125742/0 First Committee Meeting dated June 3, 2021  
 
First Committee Meeting Agend a 5 4. DBSQC ( Hsiaoling Wang, Emnet Yit barek, Karla Garcia, Anil Choudhary, 
Esmeralda Alvarado  and Marie Anderson):    
• No issues have been identified.   However, the Lot Release Protocol 
appears to be missing and an i nformation request will be sent to the 
Applicant to request this document .   
5. Toxicology (N abil Al- Humadi) : 
• Dr. Green informed the regulatory team prior to the meeting that the 
toxicology team will not be able to attend the meeting, but no issues have 
been identified  and there should be no problem making the deadlines.  
6. Statistics (Lei Huang) : 
• No issues have been identified.  
7. Epidemiology/Pharmacovigilance (Deborah Thompson) : 
• The reviewer noted that a pregnancy registry was mentioned in the 
submission, and it will need to be determined if it will be considered a PMC.  
8. DMPQ (Kathleen Jones, Laura Fontan, Gregory Price, Zhongren Wu, Donald Ertel, Ekaterina Allen , Cheryl Hulme  and Iryna Zubkova): 
• No issues have been identified and inspections for Wyeth BioPharma 
Division of Wyeth Pharmaceuticals LLC (FEI: 1222181, referred to as Pfizer, Andover ) and Pfizer Manufacturing Belgium NV (FEI: 100654629, 
referred to as Pfizer, Puurs) sites are tentatively being planned for July 19th  
– 23
rd and June 24th - July 2nd, respectively. They are waiting on the EIR 
from the Pharmacia & Upjohn Company (FEI: 1810189, referred t o as 
Pfizer, Kalamazoo) site that was issued by TeamBio to see if the inspection 
can be waived since the site was recently inspected (May 11 -20, 2021) . 
9. BiMO (Haecin Chun) : 
• Bi MO is  not planning on issuing any more inspections since inspections of 
10 study sites were already conducted under  the IND and EUA, under 2 
protocols . The BiMO team stated that the inspections that occurred under 
the IND and EUA did not inspect data integrity because there wasn’t anything to inspect at the time.  However, if th e clinical and stat istical  
reviewers encounter issues relevant to data integrity, BIMO should be made aware as soon as possible so that arrange ments for  inspections can 
be made.   Lastly, the BiMO team noted that the agenda for this meeting 
included a BiMO inspections completed milestone of July 30, 2021, and 
FDA-CBER-2021-5683-0652172
STN 125742/0 First Committee Meeting dated June 3, 2021  
 
First Committee Meeting Agend a 6 they mentioned that this is not feasible and too early in the review cycle if 
inspections were to be assigned. 
10. APLB (Oluchi Elekwachi) : 
• No issues have been identified and the propriety name review will be 
similar to what was submitted under the IND.  
11. Container Labeling (Daphne Stewart) : 
• The reviewer noted that she will have a few minor comments on the carton and container label s early next week.  
12. CDISC (Brenda Baldwin and Kirk Prutzman): 
• D ataset validation will not be done for this BLA . The included datasets are 
the same as those in the EUA  amendment for adolescents 12 through 15 
years of age, which were validated during the review of the EUA amendment.  
 Action Items:  
• Management  
o Find out  if Filing Checklists will be required.  
o Determine the best method for  the review team to keep management apprised of 
the review  progress . 
• Clinical 
o Determine , as soon as possible,  if there are issues that will prevent the review 
from being completed on time and keep management informed  on what is 
decided.  
 Post -meeting update s:   
• CBER IOD informed the regulatory team that discipline reviewer checklists do not need to be completed  for this BLA.  The reviewers were informed of this decision on June 7, 
2021 and encouraged to refer to the checklists for guidance during the review of the 
BLA.  The RPM filing checklist will be completed and uploaded to RMS -BLA/EDR.  
  Explanation of Milestones  
First Committee Meeting:  Committee must meet by this date to discuss the review of the BLA.  
 Filing Meeting:  Meeting at which the review committee determines whether  
the BLA can be filed.  Reviewers must determine whether the information included in the BLA is sufficient to allow  the 
reviewer to conduct an adequate review.  The purpose is not 
FDA-CBER-2021-5683-0652173
STN 125742/0 First Committee Meeting dated June 3, 2021  
 
First Committee Meeting Agend a 7 to determine the acceptability of the data but rather to 
determine whether the appropriate information was submitted to allow the reviewer to conduct a meaningful review.  
 Filing Action:  Date by which a filing letter (either accepting or refusing to 
file the BLA) must be issued.   
 Deficiencies Identified:  Date by which a letter must be issued in which review issues identified to date are conveyed to the applicant.  
 Mid-cycle Meeting:  Meeting at which each reviewer is expected to document 
their review progress and discuss the relevant content of the submission and present an overview.  A draft review memorandum identifying key issues should be completed by the time of the meeting.  First line supervisors for each review discipline as well as the Director and Deputy Director for DVRPA and OVRR, or their representative, should attend 
the meeting.  
 Action Due Date:  Date by which final action regarding the BLA must be conveyed to the applicant (issue Approval or Complete Response letter, depending on review decision).  All review memos, regardless of the Action being taken, must be signed and uploaded to the EDR prior to the date of Action.  
 Explanation of Roles and Responsibilities (See CBER SOPP 8401 for more detail)  
• Chair – Manages the administrative processing of reviews and ensures the 
regulatory and scientific content of submissions and their reviews are appropriate.  
• Director and/or Deputy Director – the Signatory Authority who signs action 
letters and is responsible for content of reviews.     
• Regulatory Project Manager (RPM) – Manages the review of submissions, 
including reviewing assigned portions, performing quality control checks, capturing review committee communications, and ensures that the review and 
review file is administratively complete.  The RPM(s) works in tandem with the Chair to ensure that amendments are disseminated to the appropriate reviewers and that a meaningful short summary is entered into eMRP.  Throughout the review c ycle, the RPM ensures that all FDA documents are 
uploaded into the EDR as they are generated,  and the documentation review 
memo is maintained in real -time.  
• Review Committee – Perform review of all assigned areas of submissions, 
participate in review meetings, and perform and document a review of the submission that is scientifically sound and follows Good Review Management Principles.  Documentation of a discipline review may be in the form of a 
FDA-CBER-2021-5683-0652174
STN 125742/0 First Committee Meeting dated June 3, 2021  
 
First Committee Meeting Agend a 8 primary review, discipline review letter, and a review addendum.  It is imperative 
that the review committee endeavor to follow the review timetable and finish reviews in a timely manner to allow for adequate supervisory review.  It is critical that the review committee keeps management, including senior 
management,  abreast of any significant review issues.        
• Supervisors – Ensure the overall content of reviews are appropriate, all 
administrative processing steps are being completed, including database data entry, and all deadlines are met.  Reviews and approves employees’ review memorandums and other submission documents per CBER policies and procedures.  Supervisory review is considered the Secondary Review.  
 Documentation of Review  
Each discipline reviewer is expected to prepare a written review documenting th eir 
review of the file.  Timely submissions are imperative to allow time for adequate management review.  The following is recommended:  
• Identify all materials assigned  for review and include an executive summary  in 
each final or complete review memo.  
• List and summarize all material reviewed.  The summary should identify each 
amendment reviewed and include a list of the submission dates, sections and 
page numbers etc. , as applicable.  
• A list of questions communicated to the applicant, in letter -ready format, along 
with the responses received and reviewed should be clearly identified.  
• A recommendation for action, approval or CR, based upon the review summary should be clearly stated.  
• Draft reviews should be prepared and discussed with the reviewer’s supervisor and a copy should be given to the Chair by the draft due date(s).  Draft reviews should not  be uploaded to the EDR.  
• Reviewer’s and supervisor’s electronic signatures  should be placed on the final 
PDF version of the review.  A Word version should be attached, and the PDF should be certified  and locked to prevent modification.  The review should be 
entered into eMRP using the date of the Reviewer’s approval stamp as the date 
of the memo  and the certified PDF should be uploaded into the EDR.  
• If a Complete Response (CR) Letter is issued, a complete written review is expected and should reflect all amendments that have been reviewed through the date of the CR decision.  The final signed and certified PDF version of the 
review should be uploaded by the date of the CR action.  
 Communication Plan  
We can communicate with the applicant via several methods such as telecon, secure e-mail, and letter.  The following is recommended:  
• All communicatio n regarding requests for information or advice for the applicant 
will be coordinated by the RPM s and communicated either via telecon or secure 
email.  Please contact Ramachandra Naik (Chair), Mike Smith  and Laura 
Gottschalk (RPMs)  if you need to communicate with the applicant.  
FDA-CBER-2021-5683-0652175
STN 125742/0 First Committee Meeting dated June 3, 2021  
 
First Committee Meeting Agend a 9 • Although every effort should be made to include the RPMs and/or Chair when 
communicating with the applicant, in rare instances it may be appropriate, with permission from Ramachandra Naik  and/or Laura Gottschalk and Mike Smith , 
to co mmunicate some requests for information (e.g., something that is relatively 
simple) to the applicant via a telecon.  Please ensure that all such communication is formally documented (i.e., write up a telecon memo and send it to the RPMs to include in the f ile).   
• Formal telecons with the applicant can be scheduled to address issues for which a direct discussion is helpful.  The RPMs will coordinate this if/when it is needed.  
• Letters can also be used to communicate review issues to the applicant.  Although both secure e- mail and letters provide the necessary documentation 
for the file, letters are a more formal process than secure e- mail (letters must go 
through more levels of supervisory review and concurrence) so typically letters are reserved for communication of policy or serious review issues.  
• Please “cc” the Chair on significant e- mail communication and meetings 
(internal and external).  It is helpful for the Chair to have a general overview of the review status and review issues in the various disciplines (allows for more effective communication with internal upper level management and the applicant when necessary).   
• Supervisory concurrence will be sought, when appropriate, prior to sending communications to the applicant (e.g., memos with request for information, providing advice, etc.).  
FDA-CBER-2021-5683-0652176