93 Courtesy Copy 2 BLA 125742 0 Statistical Review COMIRNATY

Pfizer Documents (PHMPT/FDA)

Pfizer Bla Submission

Pfizer 16 Plus Documents

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Document text

Stati stical  Review  
STN: 125742/0 
 
 
  Page i Application Type  BLA, Original Application  
STN  125742/0  
CBER Received Date  May 18, 2021  
PDUFA Goal Date  January 16, 2022  
Division / Office  DVRPA  /OVRR  
Committee Chair  Ramachandra Naik  
Clinical Reviewer(s)  Ann Schwartz; Susan Wollersheim  
Project Mana ger Mike Smith ; Laura Gottsch alk 
Priority Review  Yes 
Reviewer Name(s)  Lei Huang  
Review Completion Date / 
Stamped Date   
Supervisory Concur rence  Tsai-Lien Lin, Bra nch Chief, VEB, DB, 
OBE  
 John A. Scott, Director, DB, OBE  
Applicant   BioNTech Manufacturi ng GmbH  (in 
partners hip with Pfizer, Inc. ) 
Established Name  COVID -19 Vaccine , mRNA  
(Proposed) Trade Name  COMIRNATY  
Pharmacologic Class  Vaccine  
Formulation(s), including 
Adjuvants, etc  After preparation, each 0.3 mL dose 
contains 30ug modified mRNA encoding 
SARS -CoV -2 spike glycoprotei n  
Dosage Form(s) and Route(s) of 
Administration   Injectable Suspension, Intramuscular  
Dosing Regimen  Two 0.3 mL  doses , 3 weeks ap art  
 Indication(s) and Intended 
Population(s)  Active immunization to prevent 
coronavirus disease 2019 (C OVID- 19) 
caused by severe acute respiratory 
syndrome coronavirus 2 (SARS- CoV -2) in 
individuals 16 years of age  and older.   
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  Page ii Table of Contents  
Glossary  ............................................................................................................................. 3 
1. Executive Summary  ...................................................................................................... 3 
2. Clinical and Regulatory Background  ......................................................................... 4 
3. Submission Qualit y and Good Clinic al Practices  ...................................................... 4 
3.1 Submission Quality and Completeness  ................................ ................................ ..........................  4 
3.2 Compliance With Good Clinical Practices And Data Integrity  ................................ ...................  4 
4. Significant Efficacy/Safety Issues Related to Other Review Disciplines.................. 5 
5. Sources of Clinical  Data and Other Information Considered in th e Review  .......... 5 
5.1 Review Strategy  ................................ ................................ ................................ ...............................  5 
5.2 BLA/IND Documents That Serve as the Basis for the Statistical Review  ................................ ... 5 
5.3 Table of Studies/Clinical Trials  ................................ ................................ ................................ ...... 6 
6. Discussion of Individual Studies/Clinical Tri als ........................................................ 7 
6.1 Study C4591001 ................................ ................................ ................................ ...............................  7 
6.1.1 Objectives  ................................ ................................ ................................ ................................  7 
6.1.2 Design Overview  ................................ ................................ ................................ .....................  8 
6.1.3 P opulation  ................................ ................................ ................................ .............................  10 
6.1.4 Study Treatments or Agents Mandated by the Protocol  ................................ ........................  10 
6.1.6 Sites and Centers  ................................ ................................ ................................ ...................  10 
6.1.7 Surveillance/Monitoring  ................................ ................................ ................................ ........  10 
6.1.8 Endpoints and Cr iteria for Study Success  ................................ ................................ .............  11 
6.1.9 Statistical Considerations & Statistical Analysis Plan  ................................ ..........................  11 
6.1.10 Study Population and Disposition  ................................ ................................ .......................  12 
6.1.11 Efficacy Analyses  ................................ ................................ ................................ ................  16 
6.1.12 Safety Analyses  ................................ ................................ ................................ ...................  25 
7. Integrated Overview of Efficacy  ................................................................................ 25 
8. Integr ated Overvie w of Safety  ................................................................................... 25 
9. Additional Statistical Issues  ....................................................................................... 25 
10. Conclusions  ................................................................................................................ 25 
10.1 Statistical Issues and Collective Evidence  ................................ ................................ .................  25 
10.2 Conclusions and Recommendations ................................ ................................ ...........................  26 
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  Page 3 GLOSSARY  
BIMO  Bioresearch Monitoring  
BNT162b 2 Pfize rBioNTech COVID -19 Vaccin e  
CDC  Centers for Disease Control an d Preventio n  
CI Confidence interval  
COVID -19 coronavirus disease 201 9  
EUA  Emergency Use Authorizatio n  
HHS Health and Human Serv ices  
HIV human immunodeficiency viru s  
IM intramuscula r  
IR Information request  
LNP  lipid nanoparticl e  
modRN A nucleoside -modified messenger RNA  
NAA T nucleic acid amplification -based tes t  
PY person -years 
RT-PCR  reverse transcription -polymerase c hain reactio n  
SAR S-CoV -2 severe acute respiratory syndrome coronavirus 2  
VE vaccine efficac y  
VRBPAC  Vaccines and Related Biological Products Advisory Committe e  
WHO  World Health Organization  
  
1. EXECUTIVE SUMMARY  
Pfizer submitted a Biologics Licen se Application ( BLA 125742/0) on May 18, 2021 to 
seek licensure of the Pfizer -BioNTech COVID-19 Vaccine (BNT162b2) for active 
immunization to prevent Coronavirus Disease 2019 (COVID -19) caused by Severe Acute 
Respiratory Syndrome C oronavirus 2 ( SARS -CoV-2) in individual s 16 years of age and 
older. The BLA is supported by safety, efficacy, and immunogenicity data from two ongoing studies (C4591001 and BNT-162- 01). This statistical review focuses on the 
analyses of efficacy  data collect ed during the blinded, placebo -contro lled follow-up in the 
Phase 2/3 portion of Study C4591001.  Study C4591001 is an ongoing, randomized, placebo-controlled, observer-blinded Phase 
1/2/3 study being conducted in the United States, Argentina, Brazil, Germany, South Africa, and T urkey. In the Phase 2/3 portion of the study, 44,165 subjects aged 16 and 
above were randomized 1:1 to receive two doses of BNT162b2 or placebo 21 days apart . 
Randomization was stratified by age group. Starting  December 14, 2020, following 
issuance of an Emergency Use Authorization (EUA) , participants 16 years of age and 
older were systematically unblinded when e ligible per local recommendations and 
offered BNT162b2 vaccination if they had been randomized to placebo.  
 In the updated effic acy analysis f or cases accrued during blinded placebo -controlled 
follow-up (cut off date: March 13, 2021) of Study C4591001 in parti cipants  16 years of 
age and ol der, the estimated vaccine efficacy ( VE) against confirmed COVID -19 
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  Page 4 occurring at least  7 days after Dose 2 was 91. 1% (95% CI: 88.8%, 93.1%), with 77 
COVID- 19 cases in the B NT162b2 group comp ared to 833 cases in the placebo gro up 
among participants without evidence of SARS-CoV-2 infection before and during the 
vaccination regimen; the estimated vaccine efficacy ( VE) against confirmed COVID-19 
occurring at least  7 days after D ose 2 was 9 0.9% (95% CI: 88. 5%, 92.8%), with 81 
COVID- 19 cases in the BNT162b2 group compared to 854 cases in the placebo group  
among participants with or without evidence of SARS- CoV-2 infection before and during 
the vaccination regimen .  
 
With respect to  efficacy  against severe COVID- 19 cases occurring  at least 7 days after 
Dose 2, the estimated V E was 95.3% (95% CI: 71.0%, 99.9%), with 1 and 21 cases in the 
BNT162b2 and placebo groups, respectively, among participants without evide nce of 
SARS -CoV-2 infec tion; the VE r esult was the same among participants with or without 
evidence of SARS -CoV- 2 infection . 
 Overall, the updated efficacy analysis results show that BNT162b2 provided high VE  in 
preventing sympt omatic COVID-19 and severe COVID -19 cases.  
 
2. CLINICAL AND REGULATORY BACKGROUND  
Coronavirus disease 2019 (COVID-19) is an infectious disease caused by  SARS -CoV-
2, a novel coronavirus that emerged in late 2019 in patients with pneumoni a of unknown 
cause. On January 31, 2020, the United States  Secretary of Health and Human  
Services ( HHS ) made the declarati on that COVID-19 constitutes a nationwide public 
health emergency. On March 11, 2020, the World Health Organization (WHO) declar ed 
the C OVID-19 outbreak a pandemic. 
 The BNT162b2 vaccine, developed by BioNTech Manufacturing GmbH in partners hip 
with Pfizer, Inc. , was granted  Fast Track Designa tion on July 7, 2020 for individuals ≥ 18 
years of age. An Emergency Use Authorization ( EUA) was  granted in the U.S. on 
December 11, 2020 for individuals ≥ 16 years of age (EUA 27034). An amendment to the 
EUA was submitted  on May 10, 2021 to support emergency use in participants 12 to 15 
years of age.  
 
3. SUBMISSION QUALITY AND GOOD CLINICAL PRACTICES  
3.1 Subm ission Quality and Completeness  
The submission was adequately organized and integrated to accommodate the conduct of a complete statistical review .   
3.2 Compliance With Good Clinical Pract ices And Data  Integrity  
Please refer to Haecin Chun’s Bior esearch Monitoring ( BIMO ) review memo.  
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  Page 5 4. SIGNIFICANT EFFICACY /SAFETY ISSUES RELATED TO OTHER REVIEW  
DISCIPLINES  
Please refer to other review disci plines ’ memo s.  
5. SOURCES OF CLINICAL DATA AND OTHER INFORMATION CONSIDERE D IN THE  
REVIEW  
5.1 Review Strat egy 
This me mo fo cuses on the statistical review of clinical  efficacy data. Plea se refer to  Dr. 
Ye Yang ’s memo for the statistical review of clinical safety data, and to Dr. Xinyu 
Tang ’s memo for the  statistical review of non -clinical data.  
 To demonstrate e fficacy of BN T162b2, the applicant provided the efficacy  results from 
the interim analys is (cutoff date: November 4, 2020) , the final analysis ( cutoff date: 
November 14, 2020), and an updated anal ysis for cases accrued during blinded placebo -
controlled f ollow-up (cutoff date: March 13, 2021) for Study C4591001. As the efficacy 
results from th e interim and final analyses supported the issuance of an EUA  and have 
been r eviewed under EUA 27034, this statistical review primarily focuses on the updated 
efficacy results .  
5.2 BLA/IND Documents That Serve as the Basis f or the Statistical Review  
The f ollowing documents submitted to the BLA are reviewed: 
 125742/0 (submitted on 5/6/2021)  Module 2. Common Te chnical Document Summaries  
• Clinical O verview 
• Summary of Clinical Efficacy  
 Module 5. Clinical Study Reports 
• C4591001 Statistical Analysis Plan  
• C4591001 Interim 6- Month  Report 
 125742/0.3 (submitted on 5/19/2021)  Module 1.11. 3 Clinical Information Amendmen t 
• Response to FDA 18 Ma y 2021 IR  
 125742/0.17 (submitted on 7/26/2021)  Module 1.11.3 Clinical Information Amendment  
• Response to CBER Clinical 22 July 2021 Info  Request 
 125742/0.18 (submitted on 7/28/2021) 
 Module 1.11.3 Cli nical Information Amendment  
• Response to CBER  22 July 2021 Info  Request  
 125742/0.27 (subm itted on 8/2/2021) 
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  Page 6  Module 1.14.1 Draft L abeling  
 125742/0.28 (submitted on 8/02/2021) 
 Module 1.11.3 Clinical Information Amendment  
• Response to CBER Clinical 22 J uly 202 1 Information  Request 
 125742/0.32 (submitted on 8/05/2021) 
 Module 1.11.3 Clinical Info rmation Amendment  
• Response 22 Jul 2021 – Follow-up #3  
Module 5 Clinical Study Reports  
• C4591001 – 508 Efficacy Tables  
 125742/0.38 (submitted on 8/09/2021) 
 Module 1.14.1 Draft Lab eling 
Module 5 C linical Study Reports  
• C4591001 – Source Vaccine Efficacy Tables  
 125742/0.49 (submitted on 8/16/2021) 
 Module 1.14.1 Draft Lab eling 
Module 5 C linical Study Reports  
• C4591001 – Follow Up  Table  (with and without evidence of infection ) 
 
5.3 Table of Studies/Clinical Trials  
Data from two o ngoing clinical stu dies were submitted to support the licensing 
application for BNT162b2 and are summarized in Table 1 below. The pivotal d ata are 
derived from a single s tudy, C4591001, which is a mu lti-center, Phase 1/2/3, randomized, 
double-blinded, placebo- controlled safety, immuno genicity, and efficacy study; the 
second study, BNT162-01, is a Phase 1 safety and immunog enicity study evalua ting 
various vaccine candidates and dose levels.  
 
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  Page 7 Table 1. Clinical  Trials  Support ing Licensure of the Pfizer -BioNTe ch COVID -19 Vaccine  
Study  Num ber/ 
Country  Description  BNT162b2  (30 µg)*  
participants  
(N) Placebo  
participant s 
(N) Study  
Status  
C4591001  
Argentina,  Brazil,  
Germany, S. 
Africa,  Turkey, 
U.S.A.  Phase  1/2/3 randomized,  placebo -
controlled,  observer -blind;  to 
evaluate  safety,  immunogenicity  
and efficacy  of COVID- 19 
vaccine  Phase  1a: 24  
Phase 2/3b: 22085  Phase  1a: 6 
Phase 2/3b: 22080  Ongoing  
BNT16 2-01 
Germany  Phase  1/2 randomized,  open -label;  
to evaluate safety  and 
immunogenicity,  dose escalation  24 0 Ongoing  
N= total number of randomized participants  16 years of age and older , as of  March  13, 2021 Placebo: 
saline.    
- Studies C4591001 and BNT162- 01 started in April 2020 (first participant, first visit).   
* Phase 1 studies included additional participants vaccin ated with other dose levels a nd other mRNA 
vaccine candidates.    
a Phase 1 : enrolled individuals  18-85 years  of age  
b Phase 2/3:  Phase 2:  enrolled individuals  ≥18 years of age (stratified as 18 to 55 years and 56  to 85 
years);  Phase 3:  enrolled individual s ≥16 years of age (stratifie d as 16-55 years  and >55 years of age).   
Source: Summarized by reviewer based o n information provided in Modul e 2 - Clinical Overvi ew. 
 
6. DISCUSSION OF INDIVIDUAL STUDIES /CLINICAL TRIALS  
6.1 Study C4591001  
Title : Phase 1/2 /3, Placebo -Controlled, Randomized, Observer-Blind, Dose-Finding 
Study to Evaluate the Safety, Tolerability, Immunogenicity, and Efficacy of S ARS -CoV-
2 RNA Vaccin e Candidates Against  COVID- 19 in Healthy Individuals  
First Subject First Visit : April 29, 2020  
Data Cut -off: Mach 13, 2021 
 
6.1.1 Objectives  
The objectives and endpoints are presented below are for the Phase 2/3 portion of the 
study. The objectives for the Phase 1 portion are described in Section 6.1.2 (Design 
Overview ). 
 Primary efficacy objectives 
1. To evaluate the efficacy  of BNT162b2 against confirmed COVID-19 occurring 
from 7 days after Dose 2 in part icipants without evidence of  SARS-CoV- 2 infection 
before vaccination.  
 
Endpoint: COVID-19 disease based on laboratory-confi rmed nucleic acid 
amplification -based test (NAAT ) in participants with no serological or vi rological 
evidence (up to 7 days after Do se 2) of past SARS -CoV-2 infection.  
 
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  Page 8 2. To evaluate the efficacy of BNT162b2 against confirmed COVID-19 occurring 
from 7 days after Dose 2 in participants with and without evi dence of SARS- CoV-2 
infection before vaccination. 
 
Endpoint : COVID- 19 disease based on laboratory- confirmed  NAAT  
 Secondary efficacy obje ctives  
• To evaluate the eff icacy of B NT162b2 against confirmed COVID-19 occurring 
from 14 day s after Dose 2 in  
o participants without ev idence of SARS -CoV-2 infection be fore vaccination 
(Dose 1) 
o participants with and without evidence of SARS -CoV-2 infection before 
vaccination (Dose 1) 
 
Endpoint: COVID-19 disease based on laboratory- confirmed NAAT  
 
• To evaluate the  efficacy of BNT162b2 agai nst severe COVID-19 occurring from 7 
days and from 14 days after Dose 2 in  
o participants without evidence of SARS -CoV-2 in fection be fore vaccination  
o participants with and without evidence of SARS -CoV-2 infection before 
vaccination 
 
Endpoint : Severe COVID-19 disease  
 
• To describe the efficacy of BNT162b2 against confirmed COVID- 19 (CDC-defined 
symptoms) occurr ing from 7 days and from 14 days after Dose 2 in  
o participants without evidence of SARS -CoV-2 infe ction before vaccin ation  
o partic ipants with and without evidence of infection before vaccination 
 
Endpoint : COVID-19 disease (CDC-defined sympto ms) based on laboratory-
confirmed  NAAT  
 
6.1.2 Design Overview  
Study C4591001 is an ongoing, randomized, placebo-controlled, observer-blinded Phase 
1/2/3 study being conducted in the U .S., Argentina, Brazil, Germany, South Africa and 
Turkey. In itially the study was designed as a Phase 1/2  study in healthy adults in the U .S. 
for vaccine cand idate and dosage selection , as well as evaluation of immunogenicity and 
preliminary efficac y. The protocol was expan ded to include a P hase 2/ 3 portion o f 
the study to evaluat e clinical disease efficacy  endpoint in individuals 12 years of age and 
older in the U .S. an d additional sites  outside of the U .S. This review will focus on 
data collect ed from participants 16 years of age and older.   
  The Phase 1  portion of the study was designed  to identify a pref erred vaccine 
candidate(s) and vaccine  dose level(s ) for furthe r development based on safety, 
tolerability, and immunogenicity. To this end, two age groups were evaluated in separate 
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  Page 9 cohorts : younger adult s 18 through 55 years of age (N=45) and older adult s 65 through 
85 years of age (N=45). The study population included healthy men and wom en and 
excluded participants at high risk of SARS- CoV- 2 infection or with serological evidence 
of pr ior or current SA RS-CoV-2 infection. Two different vaccine candidates were 
evaluated, a nd younger participants received e scalating d ose levels E valuation of 
escalating dose levels in the older age group (65 through 85 years), we re based on 
recommendations from an internal review committee that rev iewed safety and 
immunogenicity da ta. For each vaccine candidate and dose level, participants were 
randomized 4:1, such that 12 participants received the vaccine candi date and 3 
particip ants received placebo. Review of the safety and immunogenicity from Phase 1, in 
combination with d ata fr om Study BNT162-01 (see S ection 6.2 of this  review ), supported 
the final vaccine candidate and dose level (BNT162b2 at 30 μ g, given 21 days apart) to 
proceed into Phas e 2/3.  
  In Phase 2/3, participants were initially enrolled with stratification by  age (younger 
adults: 18 through 55 years of age; older adults: over 55 years of age) and a goal of 40% enrollment in the older adult age group. Adolescents 16- 17 years of age ( and 
subsequently 12-15 years of age) were added to the protocol later, based on  review of 
safety data in younger adults enrolled in the ongoing study. The study population for Phase 2/3 includes participants at higher risk for acquiring COVID-19 and at higher risk 
of severe COVID -19 disease, such as participants working in the healthcare field, 
participants with autoimmune disease, and participants with chronic but stable medical conditions such as hypertensi on, asthma, diab etes, and infe ction with HIV, hepatitis B or 
hepatitis C. Participants were randomized 1:1 to receive 2 doses of  either BNT162b2 or 
placebo, 21 days apart. The Phase 2 portion of the study evaluated reactogenicity and immunogenicity for 360 participants en rolled early , and these participants also 
contribute to the overall efficacy and safety data in the Phase 3 port ion.   
  The ongoing Phase 3 portion of the study is  evalua ting the safety and efficacy of 
BNT16 2b2 for the prevention of COV ID-19 disease oc curring at lea st 7 days after the 
second dose of vaccine. Efficacy is being assessed throughout a participant’s follow-up in the study through surveillance for potenti al cases of COVID -19. If, at any time, a 
participant develops acute respi ratory illness, an illness visit occurs. Assessments for 
illness visits include a nasal ( midturbinate ) swab, which is tested at a c entral laboratory 
using a reverse transcription -polymerase chain reaction (RT -PCR) test (e.g., Cepheid; 
FDA authorized under EUA), or other s ufficiently va lidated  NAAT , to detect SARS -
CoV-2. The central laboratory NAAT result is used for the case definition, unless it is not possible to test the sample at t he central laboratory. In that case, the followin g NAAT 
results are acceptable: Cepheid  Xper t Xpress SA RS-CoV-2, Roche cobas SARS -CoV -2 
real-time RT -PCR test (EUA200009/A001), and Abbott Molecular/ RealTim e SARS -
CoV-2 assay (EUA200023/A001).     The study d esign inclu ded a  planned interim analysi s of the fi rst primary efficacy 
endpoint at pre -specified numbe rs of COVID- 19 cases (at least 62, 92, and 120 cases), 
and all primary and secondary efficacy endpoints were analyzed in the final efficacy analysis afte r at least 164 CO VID- 19 cases were accrued (see Statistical Analysis sect ion, 
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  Page 10 below). Participants are expected to participate for a maximum of approximately 26 months.    Starting  December 14, 2020, following issuance of the Emergency Use Authorization for 
the Pfizer -BioNTec h COVID- 19 Vaccine,  study particip ants 16 years of age and older 
have been unblinded t o their treatment assignment when eligible per local 
recommendations, and offered BNT162b2 vaccina tion if they had been randomized to 
placebo.     The study was unblinded in stage s as each participant was either individually unblinded 
upon eligibility for vaccination outside the study or had concluded their 6-month post–Dose 2 study visit. Every p articipant 16 years of age and older who pa rticipated in the 
Phase 2/3 study w as given the opportunity to receive BNT162b2 no later than the 6-
month timepoint after the  second study vaccination. Participants who originally received 
placebo but then went on to receive BNT162b2 were moved to a new visit schedule to receiv e both doses of BNT162b2, 3 weeks apart .  
  
6.1.3 Population  
Individuals 12 years of age and older including those with stable infections and common 
comorbidities .  
6.1.4 Study Treatments or Agents Mandated by the Protocol 
Study C4591001 (Phase 1) evaluat ed a 2 -dose series of investigational vaccine or placebo 
(0.9% norma l saline) administered at a 21 -day interval. Subjects were randomized to 
receive one of three levels of investigational RNA vaccine candidates (or placebo) for 
active immunization against COVID-19. The investigational RNA vaccine candidates 
included:
 
• BNT162b1 ( BNT162 RNA- LNP vaccine uti lizing modRNA and encoding the 
RBD): dose levels 10 μg, 20 μg, 30 μg, 100 μg 
• BNT162b2 (BNT162 RNA- LNP vaccine  utilizing modRNA and encoding the P2 
S): dose levels 10 μg, 20 μg, 30 μg 
 
Based upon the preliminary results, the vaccine candidate selected for f urther evaluation 
in the Phase 2/3 studies was BNT162b2 [BNT162 RNA-LNP vaccine utilizing modRNA 
 mcg/0.5 mL] at a dose o f 30 μg.  
 
6.1.6 Sites and Centers 
The study was conducted in a total of 153 sites:  131 in the U.S., 9 in Turkey, 6 in 
Germany , 4 in South Africa , 2 in Brazil , and 1 in Argentina. 
6.1.7 Surveillance/Monitoring  
Please refer to Drs. Susan Wollersheim and Ann Schwartz ’s clinical rev iew memo.  
(b) (4)
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  Page 11 6.1.8 Endpoints and Criteria for Study Success  
Please refer to Section 6.1.1 for efficacy endpoints.  
 Study success criteria:  
In Phase 2/3, the assess ment of VE is based on posterior probability of VE
1>30% and 
VE 2>30%, where VE 1 represents VE for prophylac tic B NT162b2 against conf irmed 
COVID-19 in participants without evidence of infection before vaccination, and VE 2 
represents VE for p rophylactic BNT162b2 aga inst confirmed COVID -19 in all 
participants after vaccin ation. Only the first prima ry endpoint was  analyzed at interim 
analys es. The criteri a for success at an inter im analysis are based on the posterior 
probability , i.e. P r(VE>30%|data) at the current number of cases. Efficacy will be 
declared if the posterior probability is higher than the success threshold, where the 
success threshold for each interim analysis was calibrated  to maintain a  familywis e type I 
error rate of 2.5%.  I f the first primary objective is met, t he second primary objective will 
be evaluated at the final analysis.  
6.1.9 Stati stical Considerations & Statistical Analysis Plan  
The statistical analyses for the Phase 1  portion w ere descriptive.   
 For Phase 2/3 , the evaluable efficacy population, which included all randomized 
partici pants who received all study interventions as randomized wi thin the predefined 
window and had no other important protocol deviations as determined by the clinicians , 
was t he primary ana lysis population for all efficacy anal yses. Additional analyses based 
on the all- available efficacy  population, which included a ll randomized subjects who 
received either at least 1 dose of vaccine or placebo  (Dose 1 all -available set ) or 2 doses 
(Dose 2 all -available set ), were also performed.  
 The VE is defined as VE = 100 × (1 – IRR), where IRR is calculated as the ratio of the confirmed COVID-19 illness rate in the vaccine group to th e corresponding illness rate in 
the placebo group. Assu ming a true VE of 60% , 164 COVID-19 cases would provide 
90% power to conclude true VE >30%. Because the analyses are based on the number of cases rather than the number of participants, t he total numb er of participants enrolled in 
Phase 2/ 3 would vary depending on the incidence of COVID-19 at the time of 
enrollment, the true underlying VE, and a potenti al early stop for efficacy or futility. Four 
interim analyses were planned to be performed after accr ual of at least 32, 62, 92, and 
120 cas es. However, for operational reasons, the first IA was not performed until 94 
cases were accrued, followed by the final analysis with 170 cases.  
 VE was evaluated using a beta- binomial model and the posterior pro bability of VE being 
>30% was assessed. A minimal ly informative beta prior, beta (0.700102, 1), was 
proposed for θ = r(1 -VE)/(1+r(1 -VE)), wher e r is the ratio of surveillance time i n the 
BNT162b2 group over that in the placebo group. For participants with multiple confirmed cases, only the first case contri buted to the VE calculation. The two primary 
efficacy endpoints were evaluated sequent ially to control the familywise  type I error rate 
at 2.5% (one-sided). For the primary endpoint analysis, missing efficacy data w ere not 
imputed; only particip ants with k nown dise ase status were included . A sensitivity 
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  Page 12 analysis w as performed by imputing missing  values with the assumption of missing at 
random ( MAR ). Secondary endpoints were evaluat ed similarly to the primary endpoints. 
 After the final efficacy  analyses at 170  cases, updated efficacy analyses on primary and 
secondary efficacy endpoints were p erformed with additional data accrued. The point 
estimate of VE in the blinded follow -up period and associated 2-sided 95% C I were 
derived using the Clopper- Pearson m ethod, adjus ting for surveillance time . The posterior 
probability, P r(VE>30%|data) , was also provided.  
  
6.1.10 Study Population and Disposition 
6.1.10.1 Populations Enrolled/Analy zed 
Parti cipants 18 through 55 years of age a nd 56 years of age and older began 
enrollment into Phase 2/3 from July 27, 2020 and participants 16 through 17 years of age 
began enrollment from September 16, 2020.    6.1.10.1.1 Demographics The population for the updated anal ysis of  vaccine efficacy endpoint (March 2021 data 
cutoff) included 42,436 participants 16 years of age and older (21,136 in the BNT162b2 group and 21,300 in the placebo group), with or without  evidence of prior infection with 
SARS -CoV-2 through 7 days after the second dose. Table 2 presents the specific 
demographic characteristics in the studied population.  The evaluable efficacy population who received BNT162b2 included 48.6% females, 81.9% White, 9.5% African American, 4.4% Asian, and <3% from o ther racial groups; 
25.6% of participants were Hispanic/Latino. The median age was 51 years. One or more comorbidities that increase the risk of severe COVID -19 disease were present among 
46% of participants. Evidence of p rior SARS -CoV- 2 infection was  observed in 3% of 
partici pants . Geographically, <2% of participants lived in Germany, Turkey and South 
Africa, 6.8% lived in Brazil, 12.7% lived in Argentina, and 76.4% of participants lived in the U.S.  
 
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  Page 13 Table 2. De mographic s and Other Ba seline Character istics, P articipants  16 Years of Age 
and O lder, With or Without Evidence of Infection Prior to 7 D ays After Dose 2, 
Evaluable Efficacy Population (Data Cutoff March 13, 2021) 
Characteristic  BNT162b2 (30 μg) 
(Na=21136)  
nb (%) Placebo  
(Na=21300)  
nb (%) Total  
(Na=42436)  
nb (%) 
  
 
   Sex: Female  10280 (48.6)  10579 (49.7)  20859 (49.2)  
   Sex: Male  10856 (51.4)  10721 (50.3)  21577 (50.8)   
   Age at Vaccination: Mean years (SD)  49.8 (1 6.0) 49.7 (16.0 ) 49.7 (16.0 ) 
   Age at Vaccination: Median (years)  51.0 51.0 51.0 
   Age at Vaccination: Min, max (years)  (16, 89)  (16, 91)  (16, 91)   
   Age Group: 16 to <18 years  370 (1.8)  362 (1.7)  732 (1.7)  
   Age Group: 18 to 55 years  12120 (57.3)  12252 (57.5)  24372 (57.4)  
   Age Grou p: >55 years  8646 (40.9)  8686 (40.8)  17332  (40.8)  
   Age Group: ≥65 years  4407 (20.9)  4429 (20.8)  8836 (20.8)   
   Race: American Indian or Alaska Native  204 (1.0)  190 (0.9)  394 (0.9)  
   Race: Asian  929 (4.4)  924 (4.3)  1853 (4.4)  
   Race: Black or African American  2009 (9.5)  2036 (9.6)  4045 (9 .5) 
   Race: Native Hawaiian or Other Pacific Islander  56 (0.3)  32 (0.2)  88 (0.2)  
   Race: White  17304 (81.9)  17487 (82.1)  34791 (82.0)  
   Race: Multiracial  545 (2.6)  519 (2.4)  1064 (2.5)  
   Race: Not repor ted 89 (0.4) 112 (0.5)  201 (0.5)   
   Ethnici ty: Hispa nic or Latino  5403 (25.6)  5409 (25.4)  10812 (25.5)  
   Ethnicity: Not Hispanic or Latino  15628 (73.9)  15778 (74.1)  31406 (74.0)  
   Ethnicity: Not reported  105 (0.5)  113 (0.5)  218 (0.5)   
   Obesity: Yesc 7239 (34.2)  7386 (34.7)  14625 (34.5)  
   Obesity: No 13897 (65.8)  13914 (65.3)  27811 (65.5)   
   Comorbidities: Yesd 9712 (46.0)  9736 (45.7)  19448 (45.8)  
   Comorbidities: No  11424 (54.0)  11564 (54.3)  22988 (54.2)   
   Baseline evidence of prior SA RS-CoV-2 infection: 
Negativef 20365 (96.4)  20511 (96.3)  40876 (96.3)  
   Baseline evidence of prior SARS -CoV -2 infection: 
Positivee 627 (3.0)  669 (3.1)  1296 (3.1)  
   Baseline evidence of prior SARS -CoV -2 infection: 
Missing  144 (0.7)  120 (0.6)  264 (0.6)  
 
   Country: Argentina  2686 (12.7)  2710 (12.7)  5396 (12 .7) 
   Country: Brazil  1437 (6.8)  1432 (6.7)  2869 (6.8)  
   Country: Germany  240 (1.1)  243 (1.1)  483 (1.1)  
   Country: South Africa  391 (1.8)  392 (1.8)  783 (1.8)  
   Country: Turkey  241 (1.1)  238 (1. 1) 479 (1.1) 
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  Page 14 Characteristic  BNT162b2 (30 μg) 
(Na=21136)  
nb (%) Placebo  
(Na=21300)  
nb (%) Total  
(Na=42436)  
nb (%) 
  
   Country: United States of Ame rica 1614 1 (76.4)  16285 (76.5)  32426 (76.4)   
Abbreviation: SARS -CoV -2 = severe acute respiratory syndrome coronavirus 2.  
Note: HIV -positive subjects are included in this summary but not included in the analyses of the overall 
study objectives.  a.     N = number  of subjects in the specified group, or the total sample. This value is the denominator for 
the percentage calculations.  
Note: The analysis  was based on t reatment group  as randomized.  
b.     n = Number of subjects with the specified characteristi c.  
c.     Subjec ts who had BMI ≥30 kg/m
2.  
d.     Number of subjects who have 1 or more comorbidities that increase the risk of severe C OVID -19 
disease: defined as subjects who had at least one Charlson comorbidity index category or BMI ≥30 kg/m2.  
e.     Positive N -binding  antibo dy result at Visit 1, positive NAAT result at Visit 1, or medical history of 
COVID -19.  
f.     Negative N-binding antibody result and negative NAAT result at Visit 1 and no medical history of 
COVID -19. 
Source: Table  F of C4591001- 508-efficacy -tables  submitted to STN 125742 /0.32.  
 
6.1.10.1.2 Medical/Behavioral Characterization o f the Enrolled Population 
Please refer to Drs. Susan Wollersheim and Ann Schwartz’s clinical review  memo.  
 6.1.10.1.3 Subject Disposition The disposition of all Phase 2/3 participants 16 years of age and old er is presented  in 
Table 3. During the blinded placebo- controlled follow -up period, most participants 
randomized received Dose 1 (99.7%) and Dose 2 (98.0%).   Table  3. Disposition of Participants 16 Years of Age and Older, Phase 2/3  Subjects, 
Efficacy Popu lation (Data Cu toff March 13, 2021) 
  BNT162b2 
(30 μg)  
na (%) Placebo  
na (%) Total  
na (%) 
  
 
Randomizedb 22085 (100.0)  22080 
(100.0)  44165 
(100.0)   
Dose 1 all -available efficacy population  22009 (99.7)  22008 
(99.7)  44017 
(99.7)  
    Subjects without evidence of infection before Dose 1  21172 (95.9)  21168 
(95.9)  42340 
(95.9)  
Subjects excluded from Dose 1 all -available efficacy population  76 (0.3)  72 (0.3)  148 (0.3)  
Reason for exclusionc       
    Did not receive at least 1 vaccination  55 (0.2)  50 (0.2)  105 (0.2)  
    Data considered poten tially unreliable due to lack of PI oversight 
identified as significant quality event  21 (0.1)  22 (0.1)  43 (0.1)  
 
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  Page 15   BNT162b2 
(30 μg)  
na (%) Placebo  
na (%) Total  
na (%) 
  
Dose 2 all -available efficacy population  21648 (98.0)  21624 
(97.9)  43272 
(98.0)  
    Subjects without evidence of infection pri or to 7 days after Dose 
2 20536 (93.0)  20487 
(92.8)  41023 
(92.9)  
Subjects excluded from Dose 2 all -available efficacy population  437 (2.0)  456 (2.1)  893 (2.0)  
Reason for exclusionc       
    Did not receive 2 vaccinations  374 (1.7)  430 (1.9)  804 (1.8)  
    Data  considered potentially unreliable due to lack of PI oversight 
identified as significant quality event  21 (0.1)  22 (0.1)  43 (0.1)  
    Unblinded prior to 7 days after Dose 2  44 (0.2)  11 (0.0)  55 (0.1)   
Evaluable efficacy (7 days) population  21136 (9 5.7) 21300  
(96.5)  42436 
(96.1)  
    Subjects without evidence of infection prior to 7 days after Dose 
2 20064 (90.8)  20197 
(91.5)  40261 
(91.2)  
Subjects excluded from evaluable efficacy (7 days) population  949 (4.3)  780 (3.5)  1729 (3.9)  
Reason for exclusi onc       
    Randomized but did not meet all eligibility criteria  32 (0.1)  30 (0.1)  62 (0.1)  
    Data considered potentially unreliable due to lack of PI oversight 
identified as significant quality event  21 (0.1)  22 (0.1)  43 (0.1)  
    Did not rece ive all vaccina tions as randomized or did not receive 
Dose 2 within the predefined window (19 -42 days after Dos e 1) 718 (3.3)  729 (3.3)  1447 (3.3)  
    Unblinded prior to 7 days after Dose 2  44 (0.2)  11 (0.0)  55 (0.1)  
    Had other important protocol  deviations on or pr ior to 7 days 
after Dose 2  240 (1.1)  58 (0.3)  298 (0.7)  
 
Note: HIV -positive subjects are included in this summary but not included in the analyses of the overall 
study objectives.  Note: The analysis  was based on t reatment group  as randomized.  
a.     n = Number of subjects with the specified char acteristic.  
b.     These values are the denominators for the percentage calcul ations.  
c.     Subjects may have been excluded for more than 1 reason.  
Source: Table  D of C4591001 -508-efficacy -tables  submitted  to STN 125742 /0.32.
 
 Reviewer Comment  
1. There were more protocol  deviations leading to exclusion from analyses in the 
BNT162b2 group than in the placebo group. The majority of protocol deviations were in the category of investigational products, including dosing /administration 
error and investigational product deemed not suitable for use. Protocol deviations in other categories appeared balanced across the two treatment groups. The additional analysis on the all-available efficacy population may be 
regarded as a sensitivity analysis and showed very simila r efficacy resu lts. 
2. The Dose 1 all-available efficacy population excluded 43 subjects ( 21 in t he 
BNT162b2 group and 22 in the placebo group) due to  a specific protocol 
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  Page 16 deviation, i.e. data considered poten tially u nreliable due to lack of PI oversight 
identified as a sig nificant quality event, while the Dose 1 all-av ailable set is 
defined as all randomized participants who received at least 1 vaccination  in the 
SAP. I conducted a sensitivity analysi s without ex cluding these 43 subjects for 
efficacy analyses using the Dose 1 all-available population, when applicable, and it show ed minimal impact on VE r esults.  
 
6.1
.11 Efficacy Analyses 
6.1.11.1 Analyses of Primary Endpoints 
The Interim and Final Analyses  
At the inter im analysis, there were 4 confirmed COVID -19 cases in the BNT 162b2 group 
and 90 confirmed cases in the placebo group among subjects without evidence of prior SARS -CoV- 2 infection prior to  7 days after Dose 2, resulting in a VE point estimate of 
95.5% (95% credible interval: 88.8 %, 98.4%) and a 99.99% posterior pr obability for the 
true VE being  >30%, which met the prespecified success criterion of posterior probability 
>99.5%. The median follow -up duration for subjects included in the first interim efficacy 
analysis was slightly less than the planned 2 months. In the final analysis, the case spl it 
between the BNT162b2 and placebo groups was 8:162 (VE: 95.0%; 95% credible interval: 90.3%, 97.6%) among subjects without evidence of prior SARS- CoV-2 
infectio n prior to 7 days after Dose 2, and 9:169 (VE: 94.6%; 95% cre dible interval: 
89.9%, 97.3%) among subjects with and without evidence of prior SARS -CoV-2 
infection prior to 7 days after Dose 2. The final analysis extended the median follow-up for these subje cts to greater than 2 months , and the results indicate that the  conclusions 
from the first int erim efficacy analysis would not change when including additional 
follow -up to November 14, 2020. This pre- specified primary efficacy analysis was the 
basis for i ssuan ce of the Emergency Use Authorization ( EUA) for the Pfiz er-BioNTech 
COVID-19 Vaccine on December 10, 2020.  Reviewer Comment  
1. The efficacy results presented above included  88 subjects 12-15 years of age (46 
in the BNT162b2 group and 42 in the placebo group). Since none of these 12-15 years old subjects developed protocol defined cases and the number of subjects is small relative to the evaluable population, the efficacy results excluding these subjects are very similar to the results including them. Based on my calculation, VE fo r 16 years and older subj ects is 9 4.6% (95% credible interval: 90. 3%, 
97.6%). 
2. The interim and final analyses were reviewed under EUA 27034, and hence the review is not replicated for this BLA submission.  
  
Updated Efficacy Analyses  
Updated efficacy analyses were performed with additional co nfirmed COVID- 19 cases 
accrued during blinded placebo- controlled follow -up through March 13, 2021, 
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  Page 17 representing up to 6 months of follow-up after Dose 2 for participants in the efficacy population.  For participants without evidence of SARS -CoV -2 infe ction  prior to 7 days after Dose 2, 
the updated VE against confirmed COVID- 19 occurring at least  7 days after Dose 2 was 
91.1%. The case split was 77 COVID -19 cas es in the BNT162b2 group compared to 833 
COVID- 19 cases in the placebo group  (Table 4 ). 
 Table  4. Updated Efficacy of BNT162b2 Against Confirmed COVID-19 From 7 Days 
After Dose 2  in Participants Without Evidence of Prior SARS -CoV-2 Infection 
– Evaluable Efficacy Population, 16 Years and Olde r (Da ta Cutoff March 13, 2021) 
Pre-specified Age Group  BNT 162b 2 
(Na=19993)  
Cases  
n1b 
Surveillance Timec 
(n2d) Placebo  
(Na=20118)  
Cases  
n1b 
Surveillance Timec 
(n2d) Vaccine Efficacy %  
(95% CI)e 
  
All participants  77 
6.092 
(19711)  833 
5.857  
(19741)  91.1 
(88.8, 93.1)  
16 to 55 years  52 
3.593  
(11517)  568 
3.439  
(11533) 91.2 
(88.3, 93.5)  
>55 years and older  25 
2.499  
(8194)  265 
2.417  
(8208)  90.9 
(86.2, 94.2)  
  
Abbreviations: N -binding = SARS -CoV -2 nucleoprotein –binding; NA AT = nucleic acid amplification test;  
SARS -CoV -2 = severe acute respiratory syndrome coronavirus 2;  VE =  vaccine efficacy.  
Note: Subjects who had no serological or virological evidence (pri or to 7 days after receipt of the last dose) 
of past SARS -CoV -2 infection (i.e. , N-binding antibody [ser um] n egative at Visit 1 and SARS -CoV -2 not 
detected by NAA T [nasal swab] at Visits 1 and 2), and had negative NAAT (nasal swab) at any 
unscheduled visit  prior to 7 days after Dose 2 were included in the analysis.  
a.     N = number of subjects in the specif ied g roup.  
b.     n1 = Number of subjects meeting the endpoin t definition.  
c.     Total surveillance time in 1000 person -years for the given endpoint a cross all subjects within each 
group at risk for the endpoint. Tim e period for COVID -19 case accrual is from 7 days after Dose 2 to the 
end of the surveillance period . 
d.     n2 = Number of subjects at risk for the endpoint.  
e.     Confidence interval (CI)  for VE is derived based on the Clopper and Pearson method adjuste d for 
surveillance time.  
Source: Table  H of C4591001 -508-efficacy -tables  submitted to STN 125742 /0.32. 
 Reviewer Comment  
1. One s ubject (C4591001 ) reported “ covid -19 antibody test 
positive” in  medical history but was included in the VE analysis in participants 
without evidence of pr ior infection in Table 4. An information request ( IR) was 
sent on J uly 22, 2021. In the IR response submitted on July 26, 2021, the 
applicant clarified that “without evidence of prior infection” was based only on 
the NAAT test s at Vis its 1 and 2 and the N-bi nding assay results due to the 
(b) (6)
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  Page 18 potential uncer tainty of a me dical history entry without knowledge of 
circumstances, assay performed, etc. Because this subject received placebo and was not a case, inclusion of subject would result in no real change to the VE 
estimate .  
2. A total of  9 participants in the placebo group w ith COVID-19 symptoms start ing 
on the same day of unblinding with PCR  confirmation either on the same day or a 
few days after, were included in these analyses as pos itive cases.  
3. Initially, there  was one additional case reported in the plac ebo group, for Subject 
C4591001 . This subject reported three COVID symptom 
episodes : from Octo ber 8, 2020 to October 16, 2020, N ovember 2, 2020 to 
December 11, 2020, and December 17, 2020 to January 16, 2021 ( referred to as 
Episodes A, B and C, r espectively ). The PCR tests were negative for the first two 
episodes and positive for Episode C. Since t he three episodes were more than 4 
days apart, they should be t reated as separate episodes per the statist ical analysis 
plan ( SAP) . Hence, this s ubject should be considered  to be a case with an onset 
on December 17, 2020, one day after the unblinding on December 16, 2020, and should be excluded from the analysis. In the IR response submitted on July 26, 2021, the applicant explained that Episodes B and C were merged into one episode as this subject was hospitalized from  to  
, connecting Episodes B and C. We did not agree with t he me rging of the two 
episodes, because hospi taliza tion is not a sympt om or criterion  pre- specified in 
the protocol for COVID -19 definition  and there were no other data that could 
corroborate th at this hospitalization was due to COVID-19. The applicant agreed 
to remove this case and updated efficacy tables were submitted on August 5, 
2021.  
4. The set of subjects used for efficacy analyses excluded those who had reported 
COVID sympt oms but had missing or unknown PCR results at any time. It may be 
reasonable to exclude subjects who had reported COVID symptoms but had 
missing/unknown PCR r esult s prior to 7 days after Dose 2 for efficacy analyses in 
participants without e vidence of prior  infection . However, subjects who reported 
sympt oms and had missing/unknow n PCR results  after 7 days post D ose 2 were 
also excluded from the risk set, while they were at risk for the efficacy endpoint 
(lab-confirmed COVI D-19 starting from 7 days pos t Dose 2 ). An IR was sent  to 
the applicant on July 22, 2021. In the IR response submitted on July 26, 2021, the applicant explained that  subjects who reported symptoms and had 
missing/unknown PCR results do not have a chance to be counted in the numerator and inclusion of these subjects may result in an underestimation of the incidence rate . Since the percentages of such subjects were smal l and sligh tly 
higher in the placebo group, excluding them from the analyses likely had minimal 
impact on VE results. Per our request, the applicant also provided a sensitivity 
analys is under the missi ng at random ( MAR) assumption, where missing efficacy 
endpoint s were imputed based on predicted probability from logistic regression 
model using the fully conditio nal specifica tion method for a total of 648 subjects 
(279 in BNT162b2 group and 369 in placebo group) in the evaluable population 
who reported COVID-19 symptoms from 7 days post Dose 2 but had missing/unknown PCR resu lts. As a supplementary sensitivity analysis, the 
(b) (6)
(b) (6)
(b) (6)
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  Page 19 applicant also applied  a conservative  approach to the model by as sumin g a 
higher than the observed case rate when imput ing missing effi cacy endpoints from 
participants in the BNT162b2 group onl y, to reflect poten tially unknow able 
missing not at random effects that are unfavorable for effi cacy result of the study.  
As sh own i n Table 5, the average VE after imputati on was  90.76% under the M AR 
assumption, which is consistent with the efficacy resul ts reported in  Table 4. The 
sensiti vity analyses under the missing -not-at-random assumptions show that the 
efficacy results are robust, e.g.   at least a  16-fold increase of positivity rate  in the 
BNT162b2 group is require d for the average VE to fall below 70% , which we do 
not consider to be a pl ausible scenario.  
 
Table 5. Sensit ivity and Robustness Analysis of Missing Laboratory Results for V accine 
Efficacy – First COVI D-19 Oc currence From 7 Days Aft er Dose 2 – Subject s Without 
Evidence of  Infection  Prior to 7 Days After Dose 2 – Evaluable Ef ficacy (7 Days ) 
Population  
  
Assumed 
Missing Data 
Mechanism  Average Positive 
Rate (% ) Across 
all Imputations  
(BNT162b2: 
Placebo )a Infectio n Rates 
Based on Existin g 
and Imputed 
Values 
(BNT162b2: 
Placebo )b Median 
Posterior 
Probab ility 
of 
VE>30%   
Median of 
Lower 
Limit of 
95% CI for 
VE  
 
 
 
Median 
VE ( %)  
 
 
 
Average 
VE ( %) 
     
MAR  4.0:28.5  4.21:45.31  100.00  88.56  90.78  90.76  
MNAR1  10.1:2 8.5 5.01:45.31  100.00  86.55  88.97 88.98  
MNAR2  23.3:28.5  6.76:45.31  100.00   82.30 85.12  85.14  
MNAR 3 45.3:28.5  9.69:45.31  100.00  75.36  78.79  78.69  
MNAR 4 69.1:28.5 12.85 :45.31  100.00  67.71  71.78  71.75  
MNAR 5 85.9:28.5  15.08 :45.31  100.00  62.36  66.81  66.85  
Abbre viations: MAR = missing at random; MNAR = m issing not at random; VE = vacc ine efficacy.  
Note: Each row of this table represents summary results from 500 imp utations that were generated using 
SAS PROC MI Ful ly Conditional Specification (FCS)  method. Ea ch im putation filled in the m issing 
laboratory r esults based on a logistic regr ession model at the subject level, under the assumed missing data 
mechanism.  
a. Av erage positive rate for each vaccine group was cal culated as the mean of positive rates across all 
imput ations among subject s with missing data  after each imputation. Under t he MAR assumption, the 
imputation model assumes the probability of positive cases for each vaccine group to be the same as 
observed  from subjects with no missing data in that gr oup. Unde r each MNAR assumpti on, while keeping 
the imputation model for placebo  group unchanged, an increase in the positive rate for the BTN162b2 
group was assu med to reflect a potential conservative and unknow able MNAR  scenario for efficacy results 
of the study. 
b. Infection rate in  each vaccine group  was the number of cases divide d by a total number of subjects in 
that vaccine group times 1000.  
Source: Adapted from Table  1 of response -22jul2021 -followup  submitted to STN 125742 /0.28. 
 
For participants wit h and  without evidence of SAR S-CoV- 2 infection b efore and during 
vaccination re gimen, the updated VE against confirmed COVID -19 occurring at least 7 
days after  Dose 2 was 90.9%, with 81 and 854 cases in the BNT162b2 and placebo 
groups, respectively ( Table  6). 
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  Page 20  
Table 6. Updated Efficac y of BNT162b2 Agains t Confirmed COV ID-19 From 7 Da ys 
After Dose 2  in Participants With or Without Evidence of Prior SARS -CoV- 2 Infection  
– Evaluable Efficacy Population, 16 Years and Older (Data Cutoff March 13, 2021)  
Pre-speci fied Age Group  BNT162b2  
(Na=21047)  
Cases  
n1b 
Surveillance Timec 
(n2d) Placebo  
(Na=21210)  
Cases  
n1b 
Surveillance Timec 
(n2d) Vaccin e Efficacy %  
(95% CI)e 
  
All participants  81 
6.340  
(20533)  854 
6.110  
(20595)  90.9 
(88.5, 92.8)  
16 to 55 years  56 
3.766  
(12088) 584 
3.619 
(12142)  90.8 
(87.9, 93.1)  
>55 yea rs and older  25 
2.573  
(8445)  270 
2.492  
(8453)  91.0 
(86.5, 94.3)  
  
Abbreviations: SARS -CoV- 2 = severe acute r espiratory syndrome coronavirus 2; VE = vaccine efficacy.  
a.     N = number of subjects in the spec ified group.  
b.     n1 = Num ber of subje cts meet ing the endpoint definition.  
c.     Total surveillance time in 1000 person -years for the given endpoint across all subjects within each 
group at risk for the endpoint. Time period for COVID -19 case accrual i s from 7 days after Dose 2 to  the 
end of the sur veillance period . 
d.     n2 = N umber of subjects at risk for the endpoint.  
e.     Confidence interval (CI) fo r VE is derived based on the Clopper and Pearson method adjusted for 
surveillance time.  
Source: Tab le I of C4591001- 508-efficacy -tables  submitted to STN 125742/0.3 2. 
 VE in parti cipants in the all -available efficacy population was similar to results in the  
evaluable efficacy population (Table 7). The  VE for the prevention of COVID -19 disease 
after Dose 1 is 87.6%, in the all- availa ble efficacy popula tion. Based on the number of 
cases accumulated after Dose 1 and before Dose 2, t here seem s to be some protection 
against COVID- 19 disease following one dos e (VE=56.4% ); however, these data do not 
provide info rmation a bout longer term protection beyond 21 days after a si ngle dose.  
 
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  Page 21 Table 7. Primary Efficacy Endpoint – Participants 16  Years of Age and Older –  
Dose 1 All -Available Efficacy Population (Data Cutoff March 13, 2021)  
Efficacy Endpoint Subgroup  BNT162 b2 
(Na=21909) 
Cases  
n1b 
Surve illance Timec 
(n2d) Placebo  
(Na=21908)  
Cases  
n1b 
Surveillance Timec 
(n2d) Vaccine Efficacy %  
(95% CI)e 
  
First COVID -19 occu rrence after Dose 1  128 
8.155  
(21385)  998 
7.874  
(21315)  87.6 
(85.1, 89.8)  
   After Dose 1 to before Dose 2 43 
1.273  
(21385)  98 
1.266 
(21315) 56.4 
(37.0, 70.3)  
   Dose 2 to 7 days after Dose 2  3 
0.403  
(21049)  30 
0.401  
(20952)  90.0 
(68.0, 98.1)  
   ≥7 Days  after Dose 2  82 
6.479  
(21019)  870 
6.207  
(20901)  91.0 
(88.7, 92.9)  
   
Abbreviation: VE = vaccine ef ficacy.  
a.     N = number of subjects in the specified group.  
b.     n1 = Number of subjects meeting the endpoint definition.  
c.     Total surveillance time in 1000 person -years for the given endpoint across all subjects within each 
group at risk for the e ndpoi nt. Time p eriod for COVI D-19 case accrual is from Dose 1 to the end of the 
surveillance period.  
d.     n2 = Number of subjects at risk for t he endpoint.  
e.     Confidence interval (CI) for VE is derived based on the Clopper and Pearson method adjusted for 
surveillan ce time.  
Sourc e: Table  O of C4591001 -508-efficacy -tables  submitted to STN 125742 /0.32.  
 
Reviewer Comment  
As mentioned, the Dose 1 all-availa ble efficacy population excluded 43 subjects with a 
protocol deviation of data  being considered pote ntially u nreliable due to lack  of PI 
oversight identified as a signifi cant quality event . In my additional analys is with these 
subject s included, t he case split for the first COVID- 19 occurrence after dose 1 is 
129:1003, result ing in a n estimated VE of 87.6% ( 95% CI: 85.1%, 89.7% ). Hen ce, the 
exclusion  of these subjects likely had minimal impact on the VE results.  
 
6.1.11.2 Ana lyses of Secondary End points  
Protocol -Defined Severe cases  
Updated efficacy analyses of the secondary efficacy endpoint f or the use  of BN T162b2 
for the preventio n of severe COVID- 19 were also evaluated. Vaccine efficacy against 
severe COVID -19 is presented in Table 8 for par ticipant s without prior SARS -CoV- 2 
infection. In the updated analysis, among participants without evidence of pr ior in fection, 
the estimated V E against severe COVID -19 disease occurring at least 7 days after Dose 2 
was 95.3% (71.0%, 99.9%) , with one subject  who rec eived BNT162b2 and 21 
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  Page 22 participants who received placebo  experiencing severe disease. The same number of 
severe cases were reported a mong partic ipants with or without evidence of prior infection 
and the estimated VE was the same (95.3%). These updated analyses of the secondary  
vaccine efficacy with a larger number of severe cases now shows more definitive 
evidence of protec tion against s evere COVID- 19 disease offered by BNT162b2 (the data 
from the November 14, 2020 cut -off were limited to 4 total seve re cases ). 
 
Table 8. First Severe COVI D-19 Occ urrence From 7 Days After Dose 2 – Subjects 
Without Evidence of Infection Prior to 7 Days Afte r Dos e 2 – Participant s 16 Years of 
Age and Older – Evaluable Efficacy Population (Data Cutoff March 13, 2021)  
Secon dary Effi cacy Endpoint  BNT162b2  
(Na=19993) 
Cases 
n1b 
Surveillance 
Timec 
(n2d) Placebo  
(Na=20118)  
Cases  
n1b 
Surveillance 
Timec 
(n2d) Vaccine 
Effic acy %  
(95% CI)e 
  
First severe COVID -19 occurrence from 7 days after Dose 
2 in participants without evidence of pri or SARS -CoV -2 
infection  1 
6.103  
(19711)  21 
5.971  
(19741)  95.3 
(71.0, 99.9)  
   
Abbreviations: N -binding = SARS -CoV -2 nucleoprotein –binding; NAAT = nucleic acid amplification test;  
SARS -CoV -2 = severe acute respiratory syndrome coronavirus 2; VE = vaccine efficacy.  
Note: Subjects who ha d no ser ological or virological evidence (prior to 7 days after receipt of the last dose) 
of past SARS -CoV -2 infection (ie, N-binding antibody [serum]  negative at Visit 1 and SARS -CoV -2 not 
detected by NAAT [nasal swab ] at Visits 1 and 2), and had negative  NAAT (n asal swab) at any 
unscheduled visit prior to 7 days after Dose 2 were included i n the analysis . 
a.     N = number of  subjects in the specified  group.  
b.     n1 = Number of subjects meeting the endpoint definit ion. 
c.     Total surveillance time in  1000 pe rson-years for the given endpoint across all subjects within each 
group at risk for the endpoi nt. T ime period for CO VID- 19 case accrual is fro m 7 days after Dose 2 to the 
end of the surveillance period.  
d.     n2 = Number of subjects at risk for the endpoint.  
e.     Confidence interval (CI) for VE is derived based on the Clopper and P earson method adjus ted for 
surveilla nce time.  
Source: Table  M of C4591001 -508-efficacy -tables  submitted to STN 125742 /0.32.  
  In the all -available efficacy population, 31 parti cipants had severe COVID- 19 disease 
after Dose 1 (one subject who received BNT162b2 and 30 par ticipants who received  
placebo)  as summarized in Table 9.  
  
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  Page 23 Table  9. First Severe COVID -19 Occurrence After Dose 1 – Participants 16 Years of Age 
and O lder – Dose 1 All -Available Efficacy Population (Data Cutoff March 13, 2021)  
Secondary Eff icacy Endpoint  BNT1 62b2  
(Na=21909)  
Cases 
n1b 
Surveillance Timec 
(n2d) Placebo  
(Na=21908)  
Cases  
n1b 
Surveillance Timec 
(n2d) Vaccin e Efficacy %  
(95% CI)e 
  
First sev ere case  occurrence after Dose 1  1 
8.181  
(21385)  30 
8.032  
(21316)  96.7 
(80.3, 99.9)  
   After Dose 1 to befor e Dose 2  0 
1.285  
(21385)  6 
1.293  
(21316)  100.0  
(14.6, 100.0)  
   Dose 2 to 7 days after Dose 2  0 
0.403  
(21056)  1 
0.402  
(20962)  100.0  
NA 
   ≥7 Days after Dose 2  1 
6.493  
(21029)  23 
6.337  
(20940)  95.8 
(73.9, 99.9)  
   
Abbrev iation: VE = vaccin e efficacy.  
a.     N = number of subjects in the specified group.  
b.     n1 = Number of subjects meeting the e ndpoint definition.  
c.     Total surv eillance time in 1000 person -years for the given endpoint across all subjects within each 
group at risk for the endpoi nt. Time  period for COVID -19 case accrual is from Dose 1 to the end of the 
surveillance period.  
d.     n2 = Number of subjects at risk for  the endpoint.  
e.     Confidence interval (CI) for VE is derived based on the Clopper and Pearson method adju sted for 
surveill ance time.  
Source: Table  N of C4591001- 508-efficacy -tables  submitted to STN 125742 /0.32.  
 
Severe Case Based on CDC -Definition  
Vaccine efficacy against severe COVID -19 based on the CDC  defin ition is presented for 
particip ants with or withou t prior S ARS -CoV- 2 infection (Table  10) as the COVID- 19 
case counts in participants without prior SAR S-CoV-2 infection were the same as those 
in part icipants with or without prior SAR SCoV2 infection in both the  vaccine  and 
placebo groups .   
 
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  Page 24 Table 10. Firs t Severe COVID- 19 O ccurrence Based on CDC -Definition From 7 Days 
After Dose 2 – Subjects With or Without Evide nce of Infection  Prior to 7 Days After 
Dose  2 – Participants 16 Years of Age and Older – Evaluable Efficacy Population (Data 
Cutoff March 13, 2021)  
Efficacy Endpoint  BNT162b2  
(Na=21047)  
Cases 
n1b 
Surveillance 
Timec 
(n2d) Placebo  
(Na=21210)  
Cases  
n1b 
Surveillance 
Timec 
(n2d) Vaccine 
Efficacy %  
(95% CI)e 
  
First severe COVID -19 occurrence  based on CDC -
defin ition from 7 days after Dose 2  0 
6.345 
(20513) 31 
6.225 
(20593) 100.0 
(87.6, 100.0) 
   
Abbreviations: VE = vaccine efficacy.  
a.     N = number of s ubjects in the specified  group.  
b.     n1 = Number of subjects meeting the endpoint definition.  
c.     Total surveillance time in  1000 pe rson-years for the g iven endpo int across all subjects within each 
group at risk for the endpoint. Time period for COVI D-19 case accrual is fro m 7 days after Dos e 2 to the 
end of the surveillance period.  
d.     n2 = Number of subjects at risk for the endpoint.  
e.     Confidenc e interval  (CI) for VE is derived based on the Clopper and Pearson method adjusted for 
surveillanc e time. 
Source: Adapted from Table  ADC19EF _VE_ SEV_7PD2_CDC_EVAL  of C4591001 -ve-tables  submitted to 
STN 125742 /0.38. 
6.1.11.3 Subpopulation Analyses  
VE point e stimates for the primary end point in participants with out evidence of prior 
infection  were compa rable across sex , age  groups ( 16 to 55 years and >55 years ), race, 
ethnicity,  and country, excluding categories with too few cases to analyze.  Additional 
subgroup analyses wer e performed for  the second vaccine efficacy endpoint  ( i.e. 
COVID- 19 for participants with and without ev idence of infection prior to vaccination )  
because this endpoint may generalize better to the  population who may receive the 
vaccine, as baseline ev idence of prior infection may not be known by all people who 
might re ceive the vaccine. VE point estimat es were generally  high ( >84% ) across the 
subgroups examined  (i.e. sex, age, race, ethnicity, comorb idity, baseline SARS -CoV- 2 
status, and country)  with the except ion of participants identified  as positive or unknown 
for baseline SARS -CoV- 2 status and with un- reported ethnicity , for which there were too 
few COVI D-19 cases to interpret efficacy data for t hese subgroups . 
6.1.11.4 Dropouts and/or Discontinuations  
Dropout s and dis continuations are generally balanced across the gro ups. There were 352 
(1.6%) participants in the  BNT162b2 group and 528 (2.4%) participants in the placebo 
group who discontinued from the vaccinatio n period (Dose 1 to 1 month after Dose 2) . 
Most participants  completed the visit at 1 month post -Dose 2 ( ≥96.4%). Few partic ipants 
in the BNT162b2 and placebo groups were withdrawn from the study (1.6% and 2.2%, 
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  Page 25 respectively),  and most  were  due to withdraw als by the participant, or they were lost  to 
follow -up without other ca use given . 
 
Starting  December 14, 2020, following issuance of the Emergency Use Authorization fo r 
the Pfizer -BioNTec h COVID- 19 Vaccine,  study particip ants 16 years of age and older 
have  been unblinded t o their treatment assignment when eligible per local 
recommendations , and offere d BNT162 b2 vaccination if they had been r andomized to 
placebo.  The length of blind ed follow -up appears  to be balanced between the BNT 162b2 
and placebo  groups. During the blinded placebo -controlled follow -up period, 52.4%  of 
participants in  the BNT162b2 group and 52.6%  of participants in the placebo group in the 
evalua ble efficacy population with  or without  evidence of infection prior to 7 days a fter 
dose 2 had follow -up time  between ≥4 months to <6 months after Dose 2, and 8.4%  in 
the BNT1 62b2 group and 6.1%  in the pl acebo group had follow up ≥ 6 months .  
6.1.11.5 Exploratory and Pos t Hoc Analyse s 
Not Applicable . 
6.1.12 Safety Analyses  
Please re fer to Dr. Ye Yang ’s memo for the statistical review of the clinical safety data of 
Study C4591001. 
7. INTEGRATED OVERVIEW OF EFFICACY    
Data supporting the e ffectiveness of the vacc ine were pr imarily generated in  Study 
C4591001. Consequently, no pooled efficacy ana lyses were performed.  
8. INTEGR ATED OVERVIEW OF SAFETY   
Please re fer to Dr. Ye Yang ’s memo for the statistical rev iew of the clinical safety data. 
9. ADDITIONAL STATISTICAL ISSUES  
Not Applicable.  
10. CONCLUSIONS  
10.1 Statistical Issues and Collective Evidence  
In the updated effic acy analysis f or cases accrued during blinded placebo -controlled 
follow -up (cutoff date: Marc h 13, 2021)  of Study C4591001 in participants  16 years of 
age and ol der, the estimated vaccine efficacy ( VE) against confirmed COVID -19 
occurring at least  7 days after Dose 2 was 91. 1% (95% CI: 88.8%, 93.1% ), with 77 
COVID- 19 cases in the BNT162b2 group compared  to 833 cases in the placebo group  
among participants withou t evidence of SARS -CoV -2 infection before and during the  
vaccination regimen;  the estimated vaccine effi cacy ( VE) against confirmed COVID -19 
occurring at least  7 days after Dose 2 was 9 0.9%  (95% CI: 88.5%, 92.8% ), with 81 
COVID- 19 cases in the BNT162b2 group compared to 854 cases in the placebo group  
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  Page 26 among participants with or without  evidence of SARS -CoV- 2 infection before and during 
the vaccination regimen.  
 
With respect to efficacy  agains t severe COVID- 19 cases occurring  at least 7 days after 
Dose 2, the estimated V E was 95.3% ( 95% CI: 71.0%, 99.9%), with 1 and 21 cases in the 
BNT162b2 and placebo groups, respectively , among participants without  evidence of 
SARS -CoV- 2 infection ; the VE r esult wa s the same among participants with or w ithout  
evidence of SA RS-CoV- 2 infection . 
10.2 Conclusions and Recommendations  
Overall, the updated efficacy an alysis results show that BNT162b2 provided hi gh VE  in 
preventing symptomatic COVID -19 and severe COVID -19 cases th at is consistent with 
the VE resul ts reported in the interim and final analyses .