Courtesy Copy BLA 125742 45 04 11 2022 Memo Committee Memo Statistical Review

Pfizer Documents (PHMPT/FDA)

Pfizer Bla Submission

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Statistical Review 
STN: 125742/45 
 
 
  Page i Application T ype BLA Supplement 
STN 125742/45 
CBER Received Date December 16, 2021 
PDUFA Goal Date June 17, 2022 
Division / Office DVRPA/OVRR 
Committee Chair Ramachandra Naik 
Clinical Reviewer(s) Susan Wollersheim 
Project Mana ger Michael Smith; Laura Gottschalk 
Priorit y Review Yes 
Reviewer Name Ye Yang, Mathem atical Statistician, DB/VEB 
Review Completion Date / 
Stamped Date  
 
Concurrence Lei Huan g, Concurrin g Reviewer, DB/VEB 
  
 
Supervisory Concurrence Tsai-Lien Lin, Branch Chief, DB/VEB 
  
 
Applicant  BioNTech Manufacturing GmbH (in 
partnership with Pfizer, Inc.) 
Established Name COVID-19 Vaccine, mRNA 
(Proposed) Trade Name COMIRNATY 
Dosage Form(s) and Route(s) of 
Administration  Injectable Suspension, Intramuscular 
Dosin g Regimen Two 0.3 mL doses, three weeks apart 
 Indication(s) and Intended 
Population(s) Active immunization to prevent coronavirus 
disease 2019 (COVID-19) caused by severe 
acute respiratory syndrome coronavirus 2 
(SARS-CoV-2) in individuals 12 through 15 
years of a ge 
 
  
 
Statistical Review 
STN: 125742/45 
 
 
  Page ii Table of Contents 
Glossary ...................................................................................................................... ....... 3  
1. Executive Summary ...................................................................................................... 4  
2. Clinical and Regulatory Background ......................................................................... 5  
3. Submission Quality and Good Clinical Practices ...................................................... 5  
3.1 Submission Quality and Completeness ....................................................................................... ...... 5  
3.2 Compliance With Good Clinical Pr actices And Data Integrity ......................................................... 5  
4. Significant Efficacy/Safety Issues Rela ted to Other Review Disciplines.................. 5  
5. Sources of Clinical Data and Other Information Considered in the Review .......... 5  
5.1 Review Strategy ........................................................................................................... ..................... 5  
5.2 BLA/IND Documents That Serve as the Ba sis for the Statistical  Review ........................................ 5  
5.3 Table of Studies/Cli nical Trials .......................................................................................... ............... 6  
6. Discussion of Individual Studies/Clinical Trials ........................................................ 6  
6.1 Study C4591001 ............................................................................................................ .................... 6  
6.1.1 Objectives .............................................................................................................. .................. 6  
6.1.2 Design Overview ......................................................................................................... ............ 7  
6.1.3 Population .............................................................................................................. ................. 7  
6.1.4 Study Treatments or Agents Ma ndated by the Protocol .......................................................... 7  
6.1.6 Sites and Centers ....................................................................................................... .............. 7  
6.1.7 Surveillance/Monitoring ................................................................................................. ......... 7  
6.1.8 Endpoints and Criteria for Study Success ............................................................................... 7 
6.1.9 Statistical Considerations & Statistical Analysis Plan ............................................................ 8  
6.1.10 Study Population and Disposition ....................................................................................... .. 9 
6.1.11 Efficacy Anal yses ...................................................................................................... .......... 10  
6.1.12 Safety Analyses ........................................................................................................ ........... 13  
7. Integrated Overview of Efficacy ................................................................................ 17  
8. Integrated Overview of Safety ................................................................................... 17  
9. Additional Statistical Issues ....................................................................................... 17  
10. Conclusions ............................................................................................................... . 17 
10.1 Statistical Issues and Collective Evidence ............................................................................... ...... 17  
10.2 Conclusions and Re commendations .......................................................................................... .... 18  
 
 
  
Statistical Review 
STN: 125742/45 
 
 
  Page 3 GLOSSARY  
ADaM   Analysis Data Model AE   Adverse Event BIMO   Bioresearch Monitoring BLA   Biologics License Application BNT162b2  Pfizer-BioNTech COVID-19 Vaccine CI   Confidence Interval COVID-19  Coronavirus Disease 2019 EUA   Emergency Use Authorization GMT   Geometric Mean Titer GMR   Geometric Mean Titer Ratio NAAT   Nucleic Acid Amplification Test RT-PCR  Reverse Transcription-Polymerase Chain Reaction SAE   Serious Adverse Event SAP   Statistical Analysis Plan SARS-CoV-2  Severe Acute Resp iratory Syndrome Coronavirus 2 
SDTM   Study Data Tabulation model SRR   Seroresponse Rate VE   Vaccine Efficacy  
                           
Statistical Review 
STN: 125742/45 
 
 
  Page 4 1. Executive Summary 
The Pfizer-BioNTech COVID-19 Vaccine  (BNT162b2, COMIRNATY) was licensed on 
August 23, 2021 for active immunization to prevent Coronavirus Disease 2019 (COVID-
19) caused by Severe Acute Respiratory Syndrome Coronavirus 2 ( SARS-CoV-2) in 
LQGLYLGXDOV • \HDUV RI D JH 3IL]HU VXEPLWWHG D Biologics License Application 
Supplement (sBLA; STN 125742/45) on Decemb er 16, 2021 to seek licensure of 
COMIRNATY for use in individuals 12 through  15 years of age. The sBLA is supported 
by data from Study C4591001. This statisti cal review focuses on the efficacy, 
immunogenicity, and safety data from adoles cents 12 through 15 years of age in the 
Phase 3 part of Study C4591001 collected up to the September 2, 2021 data cutoff. 
 Study C4591001 is an ongoing, randomized, plac ebo-controlled, observer-blinded Phase 
1/2/3 study being conducted in the United States, Argentina, Brazil, Germany, South 
Africa, and Turkey among participants •12 years of age. Adolescents 12 through 15 
years of age, included in the Phase 3 porti on of the study under a pr otocol amendment, 
were enrolled at selected sites in the Un ited States, where 2,264 participants were 
randomized 1:1 to receive two doses of  BNT162b2 or placebo 21 days apart. 
Immunogenicity was assessed at 1 month after Dose 2. A random sample of 280 adolescents was selected to support imm unobridging to a random  sample of 280 young 
adults 16 to 25 years of age from the sa me study. Supplementary to immunobridging, 
adolescents were surveilled fo r potential cases of COVID-19. 
 The prespecified immunobridging success criterion comparing 12 to 15 year-old 
geometric mean neutralizing titers (GMTs) to 16 to 25 year-old GMTs from Study C4591001 was met (GMT ratio [GMR]=1.77; 95%  Confidence Interval [CI]: 1.50 to 
2.09). High efficacy against protocol-defined COVID-19 was observed among participants in the Evaluable Efficacy Popul ation without evidence of prior SARS-CoV-2 
infection starting at 7 days post Dose 2 (V accine Efficacy [VE]=100%; 95% CI: 86.8% to 
100%) and among participants in the Dose 1 All-Available Efficacy  Population starting 
after Dose 1 (VE=94.0%; 95% CI: 81.3% to 98.8 %). The lack of severe COVID-19 cases 
observed precludes assessment of efficacy against severe disease in this population. 
 The frequency and severity of  local and systemic reactions  were generally higher among 
BNT162b2 recipients than among placebo reci pients after either dose. The most 
commonly reported adverse reactions were in jection site pain, fatigue, and headache. 
There was no notable difference in the frequen cy of any unsolicited  adverse event (AE) 
between arms during blinded follow-up, while a higher percentage of BNT162b2 
recipients reported any serious AE (SAE; 0.9 %) compared to placebo recipients (0.2%). 
Of note, no SAE reported during blinded follow -up was considered by the investigator to 
be related to the study interv ention. No participants died  as of the September 2, 2021 
cutoff. One SAE of myocarditis was reported in a 15-year-old male participant 2 days 
after receiving the second cr ossover dose of BNT162b2. One SAE of appendicitis in a 
12-year-old female participant was reported  3 days after the s econd crossover dose and 
was considered by the investigator to  be related to the study vaccination. 
 
Statistical Review 
STN: 125742/45 
 
 
  Page 5 Overall, the clinical data support the e ffectiveness of BNT162b2. While there is some 
reactogenicity associated with BNT162b2, th e majority of solicite d adverse reactions 
were mild or moderate in severity and of s hort duration. I defer to the clinical reviewer, 
Dr. Susan Wollersheim, on the overal l safety conclusi on for BNT162b2.  
2. Clinical and Regulatory Background  
The Pfizer-BioNTech COVID-19 Vaccine (BNT162b2, COMIRNATY) was authorized 
under an Emergency Use Authorization (EUA) on December 11, 2020 for active immunization to prevent COVID-19 caused by SARS-CoV-2 in LQGLYLGXDOV • \HDUV RI
age, which was amended to include indivi duals 12 through 15 years of age on May 10, 
2021. &20,51$7<ZDVOLFHQVHGIRU XVHLQLQGLYLGXDOV•\ears of age on August 23, 
2021. Pfizer submitted an sBLA (STN 125742/45) on December 16, 2021 to seek 
licensure of COMIRNATY for use in i ndividuals 12 through 15 years of age. 
3. SUBMISSION QUALITY AND GOOD CLINICAL PRACTICES  
3.1 Submission Quality and Completeness 
The submission was adequately organized fo r conducting a complete statistical review 
without unreasonable difficulty. 
3.2 Compliance With Good Clinical  Practices And Data Integrity 
Please refer to Kanaeko Ravenell’s Biores earch Monitoring inspections review memo. 
4. SIGNIFICANT EFFICACY /SAFETY ISSUES RELATED TO OTHER REVIEW  
DISCIPLINES  
Please refer to reviews of other review disciplines. 
5. SOURCES OF CLINICAL DATA AND OTHER INFORMATION CONSIDERED IN 
THE REVIEW  
5.1 Review Strategy 
This statistical revi ew focuses on the efficacy, immunoge nicity, and safety data from 
adolescents 12 to 15 years of age in the Phase 3 part of Study C4591001 collected up to 
the September 2, 2021 data cutoff. 
5.2 BLA/IND Documents That Serve as th e Basis for the St atistical Review 
The following documents submitte d to the sBLA are reviewed: 
 
STN 125742/45: 
1. Amendment 0 (submitted on 12/16/2021) 
x Module 2. Common Technical Document Summaries 
x Module 5. Clinical Study Reports 
2. Amendment 2 (submitted on 2/2/2022) 
Statistical Review 
STN: 125742/45 
 
 
  Page 6 x Module 1. Administrative Informatio n and Prescribing Information 
3. Amendment 4 (submitted on 3/11/2021) 
x Module 1. Administrative Informatio n and Prescribing Information 
4. Amendment 7 (submitted on 3/18/2021) 
x Module 1. Administrative Informatio n and Prescribing Information 
5.3 Table of Studies/Clinical Trials 
Data from one ongoing clinical st udy were submitted to support licensure in adolescents 
(Table 1). Study C4591001 is a multi-center, Phase 1/2/3, randomized, double-blinded, 
placebo-controlled study to evaluate safet y, immunogenicity, and ef ficacy of BNT162b2.  
 
Table 1. Clinical Study Supporting Licensure in Adolescents 12 Through 15 Years of Age 
Study Description BNT162b2 (N) Placebo (N) Status 
C4591001 
 Phase 1/2/3, randomized, 
placebo-controlled, observer-blind study to evaluate the safety, immunogenicity, and efficacy of BNT162b2 1134 (Phase 3 
adolescents only) 1130 (Phase 3 
adolescents only) Ongoing 
N=number of randomized participants. 
Source: Summarized by the reviewer based on in formation provided in Clinical Overview.  
6. DISCUSSION OF INDIVIDUAL STUDIES /CLINICAL TRIALS  
6.1 Study C4591001 (Phase 3) 
6.1.1 Objectives 
Primary Safety Objective: 
x To define the safety profile of BNT162b2 in participants 12 to 15 years of age. 
 Secondary Immunogenicity Objective: 
x To demonstrate the noninferiority of  the immune response to BNT162b2 in 
participants 12 to 15 years of  age compared to participan ts 16 to 25 years of age. 
 Exploratory Efficacy Objective: 
x To describe the efficacy  of prophylactic BNT162b2 ag ainst confirmed COVID-19 
occurring from 7 days after the second dose through the blinded follow-up period 
in participants without, a nd with and without, eviden ce of infection before 
vaccination. 
 Reviewer comment: 
x Demonstration of efficacy was liste d as an exploratory objective as 
immunobridging was the basis for infe rring effectiveness of BNT162b2 among 
adolescents. 
Statistical Review 
STN: 125742/45 
 
 
  Page 7 6.1.2 Design Overview  
Study C4591001 is an ongoing, randomized, plac ebo-controlled, observer-blinded Phase 
1/2/3 study being conducted in the United States, Argentina, Brazil, Germany, South 
Africa, and Turkey among participants •12 years of age. Adolescents 12 through 15 
years of age, included in the Phase 3 porti on of the study under a pr otocol amendment, 
were enrolled at selected sites in the United States, where 2,264 participants were randomized 1:1 to receive two doses of  BNT162b2 or placebo 21 days apart. 
 Immunogenicity was assessed at 1 month after Dose 2. A sample of 280 participants was 
randomly selected from each age group (12 to  15 years and 16 to 25 years) to support 
immunobridging. Supplementary to immunobr idging analyses, adolescents were 
surveilled for poten tial cases of COVID-19. Those w ho developed acute respiratory 
illness were tested for SARS-CoV-2 infec tion using reverse transcription-polymerase 
chain reaction (RT-PCR) in an illness visit. Pa rticipants originally randomized to placebo 
who became eligible to receive BNT162b2 we re offered the opportunity to receive 
BNT162b2 no later than 6 m onths post Dose 2. 
 All adolescents were to reco rd local reactions, systemic events, and antipyretic/pain 
medication usage from Day 1 through Day 7 af ter each dose. Unsolicited AEs and SAEs 
were collected starting from Dose 1.  
6.1.3 Population  
The study enrolled participants •12 years of age who, in the judgement of the 
investigator, were at higher  risk for acquiring COVID-19, in cluding but not limited to use 
of mass transportation, relevant  demographics, and frontline essential workers. The age 
groups considered in this review are adol escents 12 to 15 years of age and young adults 
16 to 25 years of age randomly sa mpled to support  immunobridging. 
6.1.4 Study Treatments or Agents Mandated by the Protocol 
The study interventions were 30 μg of BNT162b2 and saline placebo. 
6.1.6 Sites and Centers 
A total of 29 sites in the United Stat es enrolled adolescents in the study. 
6.1.7 Surveillance/Monitoring 
Please refer to Dr. Susan Wollers heim’s clinical  review memo. 
6.1.8 Endpoints and Criteria for Study Success  
The immunobridging endpoint was the neutralizi ng antibody titer at 28 days after Dose 2. 
Effectiveness of BNT162b2 among adolescents was inferred by bridging their GMT of 
neutralizing antibodies to the GMT from a random subset of young adults 16 to 25 years 
of age from the same study. Success would be  declared if the lower bound of the two-
sided 95% CI for the GMR, where GMR is de fined as GMT of adolescents divided by 
GMT of young adults, was >0.67. Difference in seroresponse rates (SRRs) was evaluated 
Statistical Review 
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  Page 8 descriptively. Seroresponse was defined as a change from a baseline  (pre-Dose 1) titer 
below the LLOQ to •4*LLOQ 28 days after Dose 2, or D • -fold rise in titer from 
baseline when the baseline titer is •LLOQ. 
 Efficacy was assessed descri ptively based on cases of c onfirmed COVID-19, defined as 
having a positive nucleic acid am plification test (NAAT) pl us at least one of the 
following symptoms: fever, cough, shortness of breath, chills, muscle pain, new loss of 
taste or smell, sore throat, diarrhea, or vomiting. Severe COVID-19 was defined as a confirmed COVID-19 plus at l east one of the following: 
 
x Clinical signs at rest indicative of severe sys WHPLFLOOQHVV UHVSLUDWRU\ UDWH•
EUHDWKV SHU PLQXWH KHDUW UD WH • EHDWV SHU PLQXWH 6S2
2 ” RQ URRP DLU DW
sea level, or PaO 2/FiO 2 <300 mm Hg); 
x Respiratory failure (defined as needing high-flow oxygen, noninvasive 
ventilation, mechanical ventilation, or ECMO); 
x Evidence of shock (systolic blood pressure  <90 mm Hg, diastolic blood pressure 
<60 mm Hg, or requiring vasopressors); 
x Significant acute renal, hepati c, or neurologic dysfunction; 
x Admission to an ICU; 
x Death. 
 Solicited safety endpoints included the occurrence of local (redness, swelling, injection site pain) and systemic (fever , fatigue, headache, chills, vo miting, diarrhea, muscle pain, 
joint pain) reactions within 7 days of each dos e. Unsolicited safety endpoints included the 
occurrence of AEs and SAEs within three different risk windows: 1) Dose 1 to 1 month post Dose 2, 2) Dose 1 to 6 months post Dose 2, unblinding, or the September 2, 2021 
data cutoff, whichever was earlier , and 3) unblinding to the cutoff. 
6.1.9 Statistical Considerations & Statistical Analysis Plan 
GMR and 95% CIs were obtained by exponent iating the difference and associated 95% 
CIs of the mean log-titers based on the t-dist ribution. The confidence interval for the SRR 
difference was estimated via the Miet tinen-Nurminen met hod. The primary 
immunobridging analysis was based on the Evaluable Immunogenicity Population, defined as participants who: 1) received both doses of the ra ndomized vaccine, with Dose 
2 within 19 to 42 days after Dose 1, 2)  had at least 1 valid and determinate 
immunogenicity result collected within 28 to 42 days after Dose 2, and 3) had no other 
important protocol deviations. In addition, for the primary anal ysis, participants must not 
have any evidence of SARS-CoV-2 infection up to 1 month after Dose 2.  VE was estimated as 1 minus the incidence rate ratio of COVID-19 relative to placebo, 
with associated 95% CI calculated by  the Clopper-Pearson method adjusted for 
surveillance time. Analysis was based on the Evaluable Efficacy P opulation, defined as 
participants who received the randomized intervention within the predefined window and 
had no major protocol deviations up to 7 days  post Dose 2, and the Dose 1 All-Available 
Efficacy Population, defined as all randomized participants w ho received at least 1 dose 
of the intervention. Participants  were analyzed according to  the intervention randomized. 
Statistical Review 
STN: 125742/45 
Page 9 VE in the Evaluable Efficacy Population was descriptively presented among participants: 
1) without evidence of SARS-CoV-2 infection up  to 7 days post Dose 2, and 2) with or
without evidence of prior infection.
Solicited safety analyses were based on partic ipants who received at  least one dose of the 
study intervention and responded yes or no to any reaction within 7 days of each dose. 
Unsolicited safety analyses were based the Sa fety Population, defined as all participants 
who received at least 1 dose of  study intervention, analyzed ac cording to the intervention 
received. Safety endpoints were  summarized descriptively. 
6.1.10 Study Population and Disposition 
6.1.10.1 Populations Enrolled/Analyzed 
Table 2 shows the disposition of randomized adol escents 12 to 15 years of age. A total of 
2,264 adolescents were randomized. The percenta ges of participants who received each 
dose were similar between the vaccine and pl acebo groups. In addition, 280 participants 
12 to 15 years old and 280 participants 16 to 25 years old were selected for 
immunobridging, of which 208 (74%) and 190 (6 8%), respectively, had a determinate 
immunogenicity result available after Dose 2. The lower number of participants with an 
available immunogenicity result, noted by the Applicant on March 15, 2021, was due to 
an insufficient supply of a critical assay reag ent leading to a halt to  laboratory testing. A 
total of 190 (68%) and 170 ( 61%) participants, respective ly, were included in the 
Evaluable Immunogenicity Population without evidence of infection. 
Table 2. Subject Disposition 
Source: Adapted from Tables 4 and 10 of Interim Clinical Study Report. 
6.1.10.1.1 Demographics 
Table 3 presents the demogra phic characteristics of the adolescent Safety Population. 
Demographic characteristics were generally similar with regard to age, sex, race, 
ethnicity, and baseline SARS-CoV-2 serost atus between participants who received 
BNT162b2 and those who received placebo. Among all participants who received either - BNT162b2 
n (%) Placebo 
n (%) Total 
n (%) 
Randomized 1134 (100) 1130 (100) 2264 (100) 
Not vaccinated 3 (0.3) 1 (0.1) 4 (0.2) 
Vaccinated 1131 (99.7) 1129  (99.9) 2260 (99.8) 
Dose 1 1131 (99.7) 1129 (99.9) 2260 (99.8) 
Dose 2 1124 (99.1) 1117 (98.8) 2241 (99.0) 
Withdrawn from the study 5 (0.4) 14 (1.2) 19 (0.8) 
Lost to follow-up 3 (0.3) 2 (0.2) 5 (0.2) 
Withdrawal by subject 1 (0.1) 7 (0.6) 8 (0.4) 
Withdrawal by parent/guardian 1 (0.1) 5 (0.4) 6 (0.3) 
Dose 1 All-Available Efficacy Populatio n 1131 (99.7) 1129 (99.9) 2260 (99.8) 
Evaluable Efficacy Population 1119 (98.7) 1109 (98.1) 2228 (98.4) 
Without evidence of infection 1057 (93.2) 1030 (91.2) 2087 (92.2) 
Statistical Review 
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Page 10 intervention, 51.0% were male, 85.5% were  White, 4.8% were Black or African 
American, 6.3% were Asian, and 0.3% were  American Indian or Alaska Native. 
Demographic characteristics in the Evaluable Efficacy Population were generally similar 
to those in the Safety Population. 
Table 3. Demographics Characteristics of the Safety Population 
Source: Table 11 of Interim Clinical Study Report. 
6.1.11 Efficacy Analyses 
6.1.11.1 Analyses of Immunogenicity Endpoints 
Table 4 presents the immunobridging analysis of GMR at 28 days after Dose 2 in the 
Evaluable Immunogenicity Population without evidence of SARS-CoV-2 infection up to 
1 month post Dose 2. The GMR comparing 12 to  15 year-old GMTs to  16 to 25 year-old 
GMTs was 1.77 (95% CI: 1.50 to 2.09), meetin g the prespecified success criterion. 
Table 4. Geometric Mean Titer Ratio – Evaluable Immunogenicity Population 
Group GMT (95% CI) 
12-15 Years of Age
N=190 GMT (95% CI) 
16-25 Years of Age
N=170 GMR (95% CI) 
12-15 Years/16-
25 Years
BNT162b2 1253.6 (1117.7, 1406.1) 708.1 (625.9, 801.1) 1.77 (1.50, 2.09) 
N=number of participants with available titer at 1 month after Dose 2. 
Source: Summarized by the reviewer based on re sponse to March 7, 2022 information request.  - BNT162b2 
N=1131 
n (%) Placebo 
N=1129 
n (%) Total 
N=2260 
n (%) 
Sex - - - 
Male 567 (50.1) 585 (51.8) 1152 (51.0) 
Female 564 (49.9) 544 (48.2) 1108 (49.0) 
Race - - - 
White 970 (85.8) 962 (85.2) 1932 (85.5) 
Black/African-American 52 (4.6) 57 (5.0) 109 (4.8) 
American Indian/Alaskan Na tive 4 (0.4) 3 (0.3) 7 (0.3) 
Asian 72 (6.4) 71 (6.3) 143 (6.3) 
Native Hawaiian/Other Pacific Islander 3 (0.3) 0 3 (0.1) 
Multiracial 24 (2.1) 29 (2.6) 53 (2.3) 
Not Reported 6 (0.5) 7 (0.6) 13 (0.6) 
Ethnicity - - - 
Hispanic/Latino 132 (11.7) 130 (11.5) 262 (11.6) 
Non-Hispanic/Non-Latino 997 (88.2) 996 (88.2) 1993 (88.2) 
Not Reported 2 (0.2) 3 (0.3) 5 (0.2) 
Age (years) - - - 
Mean (Standard Deviation) 13.6 (1.1) 13.6 (1.1) 13.6 (1.1) 
Median (Minimum, Maximum) 14.0 (12, 15) 14.0 (12, 15) 14.0 (12, 15) 
Baseline SARS-CoV-2 status - - - 
Positive 46 (4.1) 50 (4.4) 96 (4.2) 
Negative 1083 (95.8) 1078 (95.5) 2161 (95.6) 
Missing 2 (0.2) 1 (0.1) 3 (0.1) 
Statistical Review 
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Page 11 Table 5 presents descriptive analysis result s for the SRR difference. Overall, 97.2% and 
96.8% of adolescents and young adults, respec tively, in the Evaluable Immunogenicity 
Population without evidence of  SARS-CoV-2 infection achie ved seroresponse, resulting 
in an SRR difference of 0.4%  (95% CI: -4.2% to 5.5%). 
Table 5. Seroresponse Rate Differen ce – Evaluable Immunogenicity Population 
Group Seroresponse 
n (%, 95% CI) 
12-15 Years of Age
N=143 Seroresponse 
n (%, 95% CI) 
16-25 Years of Age
N=124 Seroresponse % 
Difference (95% CI) 
12-15 Years Minus 16-25
Years 
BNT162b2 139 (97.2) 
(93.0, 99.2) 120 (96.8) 
(91.9, 99.1) 0.4 (-4.2, 5.5) 
N=number of participants with available titer befo re vaccination and at 1 month after Dose 2. 
n=number of participants achieving sero response at 1 month after Dose 2. 
Source: Summarized by the reviewer based on re sponse to March 7, 2022 information request. 
Reviewer comment: 
xAnalyses of GMR and SRR difference based on the same population were used to
support the May 10, 2021 EUA. Of note, the applicant discovered that the assay
LLOQ should have been 41 instead of  in the submitted datasets. The resultspresented in Tables 4 an d 5 reflect the updated LLOQ.
6.1.11.2 Analyses of Efficacy Endpoints 
In the Evaluable Efficacy Population wit hout evidence of SARS-CoV-2 infection, 28 
COVID-19 cases among placebo recipients and none among BNT162b2 recipients were 
observed during blinded follow-up from 7 days  post Dose 2 to the September 2, 2021 
cutoff (Table 6), resu lting in a VE point estimate of  100% (95% CI: 86.8% to 100%). A 
similar VE was observed among participants with or wit hout evidence of infection 
(VE=100%; 95% CI: 87.5% to 100%). These an alyses were based on a median follow-up 
of 4.4 months post Dose 2. 
Figure 1 shows the cumulative incidence of  COVID-19 in the Dose 1 All-Available 
Efficacy Population, where 48 cases in th e placebo group and 3 cases in the BNT162b2 
group were observed during blinded follow- up starting after Dose 1 (VE=94.0%; 95% 
CI: 81.3% to 98.8%). All 3 cases from BNT162b2 recipients occurred prior to Dose 2. 
No protocol-defined severe COVID-19 was obs erved in either group as of the cutoff. (b) (4)
Statistical Review
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Page 12Table 6. Efficacy by Population and Time Period
Population/Surveillance Period BNT162b2
n (1000-py)Placebo
n (1000-py)VE (95% CI)
Evaluable Efficacy Population without 
evidence of infectionN=1057 N=1030 -
• GD\V DIWHU 'RVH  0 (0.343) 28 (0.322) 100.0 (86.8, 100.0)
• GD\V WR  PRQWKV DIWHU Dose 2 0 (0.138) 15 (0.133) 100.0 (73.2, 100.0)
• PRQWKV WR PRQWKV DIWHU 'RVH  0 (0.148) 10 (0.139) 100.0 (58.0, 100.0)
• PRQWKV DIWHU 'RVH  0 (0.057) 3 (0.050) 100.0 (-112.1, 100.0)
Evaluable Efficacy Population with or without evidence of infectionN=1119 N=1109 -
• GD\V DIWHU 'RVH  0 (0.362) 30 (0.345) 100.0 (87.5, 100.0)
• GD\V WR  PRQWKV DIWHU 'RVH  0 (0.146) 17 (0.142) 100.0 (76.4, 100.0)
• PRQWKV WR PRQWKV DIWHU 'RVH  0 (0.155) 10 (0.148) 100.0 (57.4, 100.0)
•months after Dose 2 0 (0.061) 3 (0.055) 100.0 (-117.8, 100.0)
Dose 1 All-Available EfficacyPopulationN=1131 N=1129 -
After Dose 1 3 (0.450) 48 (0.434) 94.0 (81.3, 98.8)
Dose 1 to before Dose 2 3 (0.065) 12 (0.065) 75.1 (7.6, 95.5)
Dose 2 to <7 days after Dose 2 0 (0.021) 5 (0.021) 100.0 (-8.7, 100.0)
• GD\V DIWHU 'RVH  0 (0.364) 31 (0.348) 100.0 (87.9, 100.0)
N=number of participants in the population; n= number of participants meeting the primary 
endpoint definition; py=person-years of surveillance.
Source: Tables 12, 13, and 15 of Interim Clinical Study Report.
Figure 1  Cumulative Incidence of COVID- 19 – Dose 1 All-Available Effic  opulation
Source: Figure 1 of Interim Clinical Study Report.
igure  1 Cumulative  Incidence  of COVID
 19 
Dose  1 All
Available  Efficacy  Population
Statistical Review 
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Page 13 6.1.11.3 Subpopulation Analyses 
Table 7 presents the subgroup efficacy anal ysis results for the Dose 1 All-Available 
Efficacy Population. Overall, hi gh efficacy was observed rega rdless of sex or ethnicity 
and among White participants. The limited number of cases observed among non-White 
participants precludes meani ngful interpretation of efficacy within this subgroup. 
Table 7. Efficacy Starting at Dose 1 by Subgro up – Dose 1 All-Available Efficacy Population 
Population/Surveillance Period BNT162b2 
n (1000-py) Placebo 
n (1000-py) VE (95% CI) 
Overall 3 (0.450) 48 (0.434) 94.0 (81.3, 98.8) 
Sex - - - 
Male 3 (0.227) 26 (0.223) 88.7 (63.0, 97.8) 
Female 0 (0.223) 22 (0.211) 100.0 (82.7, 100.0) 
Race - - - 
White 2 (0.384) 45 (0.367) 95.8 (83.8, 99.5) 
Black or African American 0 (0.024) 2 (0.026) 100.0 (-479.7, 100.0) 
Other 1 (0.042) 1 (0.042) 1.4 (-7638.0, 98.7) 
Ethnicity - - - 
Hispanic/Latino 1 (0.055) 11 (0.051) 91.6 (42.3, 99.8) 
Non-Hispanic/Non-Latino 2 (0.394) 37 (0.382) 94.8 (79.7, 99.4) 
n=number of participants meeting the primary endpoint definition. 
py=person-years of surveillance. 
Source: Table 14.13 of Interi m Clinical Study Report. 
Reviewer Comment: 
xThe immunogenicity and efficacy data re ported by the applicant were consistent
with the Study Data Tabulation Model (SDTM) data.
6.1.12 Safety Analyses 
Solicited Local and Systemic Reactions 
Table 8 shows the frequency by severity of each solicited local and systemic reaction 
within 7 days of each dose among adolescents. In general, incidence of any redness, swelling, injection site pain, fever, fatigue, headache, chills, vomiting, new or worsened 
muscle pain, and new or worsened joint pain was higher among BNT162b2 recipients 
than among placebo recipients after either dose. 
Injection site pain, fatigue, and headache were the most frequently reported solicited 
adverse reactions. The incidenc es of solicited local reactions were slightly higher after 
Dose 1 than after Dose 2, while the incide nces of solicited systemic reactions were 
generally higher after Dose 2 with th e exception of vomiting and diarrhea. 
Among BNT162b2 recipients, the me dian onset day of solicite d local reactions was Day 
1 (i.e. day of vaccination) to Day 2 after eith er dose, with a median duration of 2 days. 
The median onset day of soli cited systemic reac tions was Day 2 to Day 3 after either 
dose, with a median du ration of 1 to 2 days. 
Statistical Review 
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  Page 14 Table 8. Frequency of Solicited Reac tions Within 7 Days of each Dose 
- BNT162b2 
Dose 1 
N=1127 
n (%) Placebo 
Dose 1 
N=1127 
n (%) BNT162b2 
Dose 2 
N=1097 
n (%) Placebo 
Dose 2 
N=1078 
n (%) 
Redness  - - - - 
Any (>2.0 cm) 65 (5.8) 12 (1.1) 55 (5.0) 10 (0.9) 
Mild 44 (3.9) 11 (1.0) 29 (2.6) 8 (0.7) 
Moderate 20 (1.8) 1 (0.1) 26 (2.4) 2 (0.2) 
Severe 1 (0.1) 0 (0.0) 0 (0.0) 0 (0.0) 
Swelling - - - - 
Any (>2.0 cm) 78 (6.9) 11 (1.0) 54 (4.9) 6 (0.6) 
Mild 55 (4.9) 9 (0.8) 36 (3.3) 4 (0.4) 
Moderate 23 (2.0) 2 (0.2) 18 (1.6) 2 (0.2) 
Severe 0 (0.0) 0 (0.0) 0 (0.0) 0 (0.0) 
Pain at the injection site - - - - 
Any 971 (86.2) 263 (23.3) 866 (78.9) 193 (17.9) 
Mild 467 (41.4) 227 (20.1) 466 (42.5) 164 (15.2) 
Moderate 493 (43.7) 36 (3.2) 393 (35.8) 29 (2.7) 
Severe 11 (1.0) 0 (0.0) 7 (0.6) 0 (0.0) 
Fever - - - - 
•ႏ  114 (10.1) 12 (1.1) 215 (19.6) 7 (0.6) 
•ႏWR ႏ  74 (6.6) 8 (0.7) 107 (9.8) 5 (0.5) 
>ႏ WR ႏ  29 (2.6) 2 (0.2) 83 (7.6) 1 (0.1) 
>ႏ WR ႏ  10 (0.9) 2 (0.2) 25 (2.3) 1 (0.1) 
!ႏ  1 (0.1) 0 (0.0) 0 (0.0) 0 (0.0) 
Fatigue - - - - 
Any 677 (60.1) 457 (40.6) 726 (66.2) 264 (24.5) 
Mild 278 (24.7) 250 (22.2) 232 (21.1) 133 (12.3) 
Moderate 384 (34.1) 199 (17.7) 468 (42.7) 127 (11.8) 
Severe 15 (1.3) 8 (0.7) 26 (2.4) 4 (0.4) 
Headache - - - - 
Any 623 (55.3) 396 (35.1) 708 (64.5) 264 (24.5) 
Mild 361 (32.0) 256 (22.7) 302 (27.5) 170 (15.8) 
Moderate 251 (22.3) 131 (11.6) 384 (35.0) 93 (8.6) 
Severe 11 (1.0) 9 (0.8) 22 (2.0) 1 (0.1) 
Chills - - - - 
Any 311 (27.6) 109 (9.7) 455 (41.5) 74 (6.9) 
Mild 195 (17.3) 82 (7.3) 221 (20.1) 53 (4.9) 
Moderate 111 (9.8) 25 (2.2) 214 (19.5) 21 (1.9) 
Severe 5 (0.4) 2 (0.2) 20 (1.8) 0 (0.0) 
Vomiting - - - - 
Any 31 (2.8) 10 (0.9) 29 (2.6) 12 (1.1) 
Mild 30 (2.7) 8 (0.7) 25 (2.3) 11 (1.0) 
Moderate 0 (0.0) 2 (0.2) 4 (0.4) 1 (0.1) 
Severe 1 (0.1) 0 (0.0) 0 (0.0) 0 (0.0) 
Diarrhea - - - - 
Any 90 (8.0) 82 (7.3) 65 (5.9) 44 (4.1) 
Mild 77 (6.8) 72 (6.4) 59 (5.4) 39 (3.6) 
Statistical Review 
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  Page 15 - BNT162b2 
Dose 1 
N=1127 
n (%) Placebo 
Dose 1 
N=1127 
n (%) BNT162b2 
Dose 2 
N=1097 
n (%) Placebo 
Dose 2 
N=1078 
n (%) 
Moderate 13 (1.2) 10 (0.9) 6 (0.5) 5 (0.5) 
Severe 0 (0.0) 0 (0.0) 0 (0.0) 0 (0.0) 
New or worsened muscle pain - - - - 
Any 272 (24.1) 148 (13.1) 355 (32.4) 90 (8.3) 
Mild 125 (11.1) 88 (7.8) 152 (13.9) 51 (4.7) 
Moderate 145 (12.9) 60 (5.3) 197 (18.0) 37 (3.4) 
Severe 2 (0.2) 0 (0.0) 6 (0.5) 2 (0.2) 
New or worsened joint pain - - - - 
Any 109 (9.7) 77 (6.8) 173 (15.8) 51 (4.7) 
Mild 66 (5.9) 50 (4.4) 91 (8.3) 30 (2.8) 
Moderate 42 (3.7) 27 (2.4) 78 (7.1) 21 (1.9) 
Severe 1 (0.1) 0 (0.0) 4 (0.4) 0 (0.0) 
Antipyretic use 413 (36.6) 111 (9.8) 557 (50.8) 95 (8.8) 
N=number of subjects responding yes or no  for any reaction within 7 days of dosing. 
n=number of subjects with the specified reaction. Source: Summarized by the reviewer based on re sponse to March 14, 2022 information request. 
 
Unsolicited Adverse Events 
 Tables 9 and 10 present the numbers and per centages of adolescent  participants who 
reported any unsolicited AE, SAE,  nonserious AE, or AE leading to withdrawal after 
Dose 1. These numbers are reported for three separate risk windows: 1) Dose 1 to 1 
month post Dose 2, 2) Dose 1 to 6 months  post Dose 2, unblinding, or the September 2, 
2021 data cutoff, whichever was earlier , and 3) unblinding to the cutoff. 
 The percentages of subjects who reported any AE were similar between BNT162b2 and 
placebo recipients from Dose 1 to 1 mont h after Dose 2, while a slightly higher 
percentage of placebo recipients reported a ny AE from Dose 1 to 6 months after Dose 2. 
A higher percentage of BNT162b2 recipients reported any AE considered by the investigator to be related to the study inte rvention in both risk windows. A total of 10 
(0.9%) BNT162b2 recipients and 2 (0.2%) plac ebo recipients reported any SAE up to 6 
months post Dose 2, none of which was considered  by the investigator to  be related to the 
study intervention. No participants died as of  the cutoff. The median  duration of blinded 
follow-up after Dose 2 was approximate ly 4.4 months among all participants. 
 A total of 1,010 subjects who originally r eceived placebo received at least 1 dose of 
BNT162b2 after unblinding prior to the September 2, 2021 cu toff. Among these subjects, 
6 (0.6%) reported any SAE, of whom a 12 ye ar-old female participant reported an SAE 
of appendicitis 3 days after the second crossover dose that was considered by the 
investigator to be related to vaccinati on. The median duration of follow-up after 
unblinding was approximately 4 months  among all unblinde d participants. 
 
  
Statistical Review 
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  Page 16 Table 9. Number of Subjects Reporting at L east 1 AE by Time Period – Safety Population 
- BNT162b2 
1 Month Post 
Dose 2 or 
Unblinding 
N=1131 
n (%) Placebo 
1 Month Post 
Dose 2 or 
Unblinding 
N=1129 
n (%) BNT162b2 
6 Months Post 
Dose 2 or 
Unblinding 
N=1131 
n (%) Placebo 
6 Months Post 
Dose 2 or 
Unblinding 
N=1129 
n (%) 
Any AE 74 (6.5) 77 (6.8) 95 (8.4) 113 (10.0) 
Related 36 (3.2) 24 (2.1) 36 (3.2) 24 (2.1) 
Severe 7 (0.6) 2 (0.2) 13 (1.1) 5 (0.4) 
Life-Threatening 1 (0.1) 1 (0.1) 2 (0.2) 1 (0.1) 
Any SAE 4 (0.4) 1 (0.1) 10 (0.9) 2 (0.2) 
Related 0 0 0 0 
Severe 2 (0.2) 0 7 (0.6) 1 (0.1) 
Life-Threatening 0 1 (0.1) 1 (0.1) 1 (0.1) 
Any nonserious AE 72 (6.4) 76 (6.7) 89 (7.9) 111 (9.8) 
Related 36 (3.2) 24 (2.1) 36 (3.2) 24 (2.1) 
Severe 5 (0.4) 2 (0.2) 6 (0.5) 4 (0.4) 
Life-Threatening 1 (0.1) 0 1 (0.1) 0 
Any AE leading to withdrawal 1 (0.1) 0 1 (0.1) 0 
N=number of subjects who received at le ast 1 dose of the study intervention. 
n=number of subjects reporting at least 1 event. Source: Adapted from Table P of  508 Tables and Table 18 of In terim Clinical Study Report. 
 Table 10. Number of Subjects Reporting at Least 1 AE After Unblinding – Safety Population 
- BNT162b2 
Unblinding to Cutoff 
N=1107 
n (%) Placebo – BNT162b2 
Crossover to Cutoff 
N=1010 
n (%) 
Any AE 18 (1.6) 265 (26.2) 
Related 4 (0.4) 242 (24.0) 
Severe 3 (0.3) 12 (1.2) 
Life-Threatening 0 0 
Any SAE 4 (0.4) 6 (0.6) 
Related 0 1 (0.1) 
Severe 1 (0.1) 3 (0.3) 
Life-Threatening 0 0 
Any nonserious AE 14 (1.3) 262 (25.9) 
Related 4 (0.4) 241 (23.9) 
Severe 2 (0.2) 9 (0.9) 
Life-Threatening 0 0 
Any AE leading to withdrawal 0 0 
N=number of subjects who received at le ast 1 dose of the study intervention. 
n=number of subjects reporting at least 1 event. Source: Tables 25 and 35 of Interim Clinical Study Report.  
 
Reviewer Comments: 
x The solicited and unsolicited AEs reported in  the interim clinical study report 
were consistent with the SDTM data. 
Statistical Review 
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  Page 17  
Myocarditis and Pericarditis 
 
No myocarditis or pericarditis was repor ted during blinded follow-up. One SAE of 
myocarditis was identified in a 15-year-old male participant 2 days after receiving the 
second crossover vaccination dose of BNT162b2. 
7. INTEGRATED OVERVIEW OF EFFICACY   
No integrated analysis of efficacy was performed. 
8. INTEGRATED OVERVIEW OF SAFETY   
No integrated analysis of safety was performed. 
9. ADDITIONAL STATISTICAL ISSUES  
There are no additional statistical issues. 
10. CONCLUSIONS  
10.1 Statistical Issues and Collective Evidence 
No major statistical issues  affecting study conclusions were identified for the 
immunogenicity, efficacy and safety data. The prespecified immunobridging success 
criterion comparing 12 to 15 year-old neut ralizing GMTs to 16 to 25 year-old GMTs 
from Study C4591001 was met (GMR=1.77; 95% CI : 1.50 to 2.09). High efficacy against 
protocol-defined COVID-19 was observed among participants in the Evaluable Efficacy 
Population without evidence of prior SARS-CoV-2 infection st arting at 7 days post Dose 
2 (VE=100%; 95% CI: 86.8% to 100%) and am ong participants in the Dose 1 All-
Available Efficacy Popula tion starting after Dose 1 (VE=94.0%; 95% CI: 81.3% to 
98.8%). The lack of observed severe COVID- 19 precludes assessment of efficacy against 
severe disease in this population.  The frequency and severity of local and syst emic reactions were generally higher among 
BNT162b2 recipients than among placebo reci pients after either dose. The most 
commonly reported adverse reactions were in jection site pain, fatigue, and headache. 
There was no notable difference in the frequ encies of any unsolicited AE between arms 
during blinded follow-up, while a higher per centage of BNT162b2 recipients reported 
any SAE (0.9%) compared to placebo recipi ents (0.2%).  Of note, no SAE reported 
during blinded follow-up was considered by the investigator to be related to the study 
intervention. No participants died as of the cutoff. One SA E of myocarditis was reported 
in a 15-year-old male particip ant 2 days after receiving th e second crossover vaccination 
dose of BNT162b2. One SAE of appendicitis in  a 12-year-old fema le participant was 
reported 3 days after the second crossover dose and was considered by the investigator to 
be related to th e study vaccination. 
Statistical Review 
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  Page 18 10.2 Conclusions and Recommendations 
Overall, the clinical data support the e ffectiveness of BNT162b2. While there is some 
reactogenicity associated with BNT162b2, th e majority of solicite d adverse reactions 
were mild or moderate in severity and of s hort duration. I defer to the clinical reviewer, 
Dr. Susan Wollersheim, on the overal l safety conclu sion for BNT162b2.