Comirnaty Epar Risk Management Plan - en
Comirnaty Epar Risk Management Plan - en
Comirnaty Epar Risk Management Plan - en
Rationale for submitting an updated RMP: Responses to the PRAC Rolling Review
Management Plan Updated Assessment Report received on 18 December 2020.
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None
QPPV oversight declaration: The content of this RMP has been reviewed and approved by
the marketing authorisation applicant´s QPPV. The electronic signature is available on file.
1
QPPV name will not be redacted in case of an access to documents request; see HMA/EMA Guidance
document on the identification of commercially confidential information and personal data within the structure
of the marketing-authorisation application; available on EMA website http://www.ema.europa.eu
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LIST OF ABBREVIATIONS
Abbreviation Definition of Term
AE adverse event
AESI Adverse event of special interest
A:G albumin:globulin
BMI body mass index
COVID-19 coronavirus disease 2019
CSR clinical study report
CT clinical trial
DART developmental and reproductive toxicology
DCA data capture aid
DLP data-lock point
ECDC European Center for Disease Control
ED emergency department
EEA European Economic Area
EHR electronic health records
EMA European Medicines Agency
EUA emergency use authorization
EU European Union
FDA (US) Food and Drug Administration
GLP good laboratory practice
HBV hepatitis b virus
HCV hepatitis c virus
HIV human immunodeficiency virus
IA interim analysis
ICU intensive care unit
IFN interferon
IM intramuscular(ly)
IND investigational new drug
LNP lipid nanoparticle
LoQ List of questions
MAA marketing authorization applicant
MedDRA Medical Dictionary for Regulatory Activities
mRNA messenger ribonucleic acid
NDA new drug application
NHP nonhuman primate
PC product complaint
PK pharmacokinetic
RA rheumatoid arthritis
RBC red blood cell
RMP risk management plan
RNA ribonucleic acid
SAE serious adverse event
SARS severe acute respiratory syndrome
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TABLE OF CONTENTS
LIST OF ABBREVIATIONS....................................................................................................4
LIST OF TABLES.....................................................................................................................8
LIST OF FIGURES ...................................................................................................................9
PART I. PRODUCT(S) OVERVIEW .....................................................................................10
PART II. SAFETY SPECIFICATION ....................................................................................12
Module SI. Epidemiology of the Indication(s) and Target Population (s).....................12
Module SII. Non-Clinical Part of the Safety Specification............................................17
Module SIII. Clinical Trial Exposure.............................................................................20
Module SIV. Populations Not Studied in Clinical Trials...............................................57
SIV.1. Exclusion Criteria in Pivotal Clinical Studies Within the
Development Programme ................................................................................57
SIV.2. Limitations to Detect Adverse Reactions in Clinical Trial
Development Programmes...............................................................................59
SIV.3. Limitations in Respect to Populations Typically Under-Represented
in Clinical Trial Development Programmes ....................................................59
Module SV. Post-Authorisation Experience ..................................................................60
SV.1. Post-Authorisation Exposure......................................................................60
SV.1.1. Method Used to Calculate Exposure.........................................61
SV.1.2. Exposure....................................................................................61
Module SVI. Additional EU Requirements for the Safety Specification ......................62
Module SVII. Identified and Potential Risks .................................................................62
SVII.1. Identification of Safety Concerns in the Initial RMP Submission...........62
SVII.1.1. Risks not Considered Important for Inclusion in the List
of Safety Concerns in the RMP .........................................................63
SVII.1.2. Risks Considered Important for Inclusion in the List of
Safety Concerns in the RMP .............................................................66
SVII.2. New Safety Concerns and Reclassification with a Submission of an
Updated RMP...................................................................................................68
SVII.3. Details of Important Identified Risks, Important Potential Risks,
and Missing Information..................................................................................68
SVII.3.1. Presentation of Important Identified Risks and Important
Potential Risks ...................................................................................68
SVII.3.2. Presentation of the Missing Information ................................70
Module SVIII. Summary of the Safety Concerns ..........................................................73
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LIST OF TABLES
Table 1. Distribution and Estimated Cumulative Incidence of Reported
Laboratory-Confirmed COVID-19 Cases, by Gender and Age Group —
United States, 22 January – 30 May 2020 ..........................................................14
Table 2. Preconditions among COVID-19 Patients in EU/EEA and UK, by
Severity of Disease. Case-based Data from TESSy Produced on
24 September 2020 .............................................................................................16
Table 3. Key Safety Findings and Relevance to Human Usage .......................................19
Table 4. Exposure to BNT162b2 by Age Group and Dose (C4591001) ..........................22
Table 5. Exposure to BNT162b2 by Age Group and Dose (BNT162-01) .......................24
Table 6. Exposure to BNT162b2 by Age Group and Dose – Children and Elderly
Subjects (C4591001)...........................................................................................27
Table 7. Exposure to BNT162b2 by Dose (Totals) (C4591001) ......................................28
Table 8. Exposure to BNT162b2 by Dose (Totals) (BNT162-01) ...................................29
Table 9. Exposure to BNT162b2 by Dose, Age Group, and Gender (C4591001) ...........31
Table 10. Exposure to BNT162b2 by Dose, Age Group, and Gender (BNT162-01).........32
Table 11. Exposure to BNT162b2 by Age Group, Dose, and Race/Ethnic Origin
(C4591001) .........................................................................................................34
Table 12. Exposure to BNT162b2 by Age Group, Dose, and Race/Ethnic Origin
(BNT162-01).......................................................................................................38
Table 13. Exposure to BNT162b2 by Dose and Race/Ethnic Origin (C4591001) .............48
Table 14. Exposure to BNT162b2 by Dose and Race/Ethnic Origin (BNT162-01) ..........50
Table 15. Exposure to BNT162b2 (30 μg) by Special Population (C4591001) .................55
Table 16. Exposure of Special Populations included or not in Clinical Trial
Development Programmes..................................................................................59
Table 17. Summary of Safety Concerns .............................................................................62
Table 18. Anaphylaxis ........................................................................................................68
Table 19. Vaccine-Associated Enhanced Disease (VAED), including Vaccine-
Associated Enhanced Respiratory Disease (VAERD)........................................69
Table 20. Use in pregnancy and while breast feeding ........................................................70
Table 21. Use in immunocompromised patients.................................................................71
Table 22. Use in frail patients with co-morbidities (e.g. chronic obstructive
pulmonary disease (COPD), diabetes, chronic neurological disease,
cardiovascular disorders) ....................................................................................71
Table 23. Use in patients with autoimmune or inflammatory disorders.............................71
Table 24. Interaction with other vaccines ...........................................................................71
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LIST OF FIGURES
Figure 1. Age-Gender distribution of COVID-19 Cases as Different Levels of
Severity, EU/EEA and UK. Case-based Data from TESSy produced on
07 August 2020 a .................................................................................................13
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Incidence:
The COVID-19 is caused by a novel coronavirus labelled as SARS-CoV-2. The disease first
emerged in December 2019, when a cluster of patients with pneumonia of unknown cause
was recognized in Wuhan City, Hubei Province, China.1 The number of infected cases
rapidly increased and spread beyond China throughout the world. On 30 January 2020, the
WHO declared COVID-19 a Public Health Emergency of International Concern and thus a
pandemic.2
In the US, the number of confirmed cases had reached over 10 million cases (3,126 per
100,000 people) by the beginning of November 2020. The reported numbers refer only to
cases that have been tested and confirmed to be carrying the virus. There are large
geographic variations in the proportion of the population tested as well as varied quality of
reporting across countries. People who carry the virus but remain asymptomatic are less
likely to be tested and therefore mild cases are likely underreported. The numbers should
therefore be interpreted with caution.3
Prevalence:
The prevalence of SARS-CoV-2 infection is defined as active cases per 100,000 people
including confirmed cases in people who have not recovered or died. On 9 November 2020,
the overall prevalence for EU countries was 37.0 active cases per 100,000. The range of
reported prevalence was 2.8 to 337.7 per 100,000 with Finland, Estonia and Hungary at the
low end and Portugal, Luxembourg and Belgium at the high end.
In the US, the prevalence on the same date was similar to the EU estimates, with 31.5 active
cases per 100,000.3
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Demographics of the population in the proposed indication and risk factors for the
disease:
While anyone can become infected with SARS-CoV-2, symptoms of COVID-19 can range
from very mild (or no symptoms) to severe. Risk factors for developing severe disease,
include age over 60 years, male gender, diabetes, severe obesity, chronic kidney disease and
congestive heart failure.4,5,6,7
The ECDC has since the beginning of the pandemic continuously collected COVID-19
information from all countries who are members of EU/EEA and the UK. In their database
TESSy COVID-19 case-based data, including age and gender, are available for
approximately 40% of the official number of cases reported by ECDC epidemic intelligence.8
All countries included in EU/EEA and UK, except Spain, Slovenia and Liechtenstein, have at
some point during the pandemic provided case-based data to TESSy, enabling estimates of
age and gender distribution representative of the European population.
According to TESSy case-based data, accessed 7 August 2020, (Figure 1), the gender
distribution of persons testing positive for SARS-Cov-2 in the European population is similar
for most age groups. However, males and older age groups are over-represented among the
more severe cases (defined as hospitalized, severe, or fatal). Few cases were reported in
people aged younger than 20 years. This data reflects the age distribution of people who met
the requirements for being tested and is unlikely to reflect the actual distribution of infections
in the population.8 The distribution of age was different in the period of January-May
compared to June-July. Between January and May 2020, 40% of cases were ≥60 years old
and the largest proportion (18.7%) of cases were reported in the 50-59 years age group. In
contrast, between June and July, persons aged ≥60 years accounted for 17.3% of cases and
the largest proportion (19.5%) of cases were reported in the 20-29-year age group.9
Note: ”mild”= a case that has not been reported as hospitalized or a case that resulted in death.
a. Data from ECDC. COVID-19 Surveillance report. Week 31, 2020. 7 August 2020. “2.2 Age-sex pyramids”.10
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In the US, surveillance data collected between 22 January 2020 and 30 May 2020 showed a
similar age distribution of infected cases in both genders (Table 1). Among 1,320,488
laboratory-confirmed COVID-19 cases, overall incidence per 100,000 persons was higher
among individuals aged 40 - 49 years (541.6) and 50 - 59 years (550.5) than among those
aged 60 - 69 years (478.4) and 70 - 79 years (464.2). Estimates were highest among persons
aged ≥80 years (902.0) and lowest among children aged ≤9 years (51.1).11 During
June-August, the COVID-19 pandemic in the US affected a larger proportion of younger
persons than during January–May 2020. In this period, incidence was highest in persons
aged 20-29 years, accounting for >20% of all confirmed cases. The shift toward younger
ages occurred in all four US Census regions, regardless of changes in incidence during this
period, and was reflected in COVID-19–like illness-related ED visits, positive SARS-CoV-2
reverse transcription-polymerase chain reaction test results, and confirmed COVID-19
cases.12
Of the 599,636 (45%) cases with information on both race and ethnicity in US surveillance
data collected between 22 January 2020 and 30 May 2020, 36% were non-Hispanic white,
33% were Hispanic, 22% were black, 4% were non-Hispanic Asian, 4% were non-Hispanic,
other or multiple race, 1.3% were American Indian/Alaskan Native, and <1% were
non-Hispanic Native Hawaiian or other Pacific Islander.11 An increased rate ratio of
COVID-19 cases and hospitalization compared to White, non-Hispanic has been reported for
all other race and ethnicity groups, underlying factors including socioeconomic status, access
to health care and occupations are likely to be the actual risk factors.13
Among hospitalized cases with COVID-19 in the US, approximately 90% are over 40 years
old, and between 58% to 66% are at least 60 years old.4,14 The majority (approximately
60%) of COVID-19 patients admitted to hospitals in the US have been male.4,6,14,15,16,17,18
African American COVID-19 patients have been reported to have an increased risk of
hospitalization4,15 and mortality,19 compared to white patients in the US.
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At the time that this vaccine was in advanced development there were other vaccines in
similar late-phase development including vaccines from Moderna (NCT04470427), Sinovac
(NCT04456595), AstraZeneca (NCT04516746), Johnson & Johnson (NCT04505722), which
may subsequently be approved, as may others currently in earlier development. The FDA on
18 December 2020 issued an emergency use authorization for the Moderna COVID-19
vaccine.
The natural history of COVID-19 is not yet fully understood. In the US, 14% of individuals
testing positive for SARS-CoV-2 22 January – 30 May 2020 were reported to require
hospitalization. The rate was lowest (<9%) among age groups <50 years, and highest among
those older than 70 years (33%) and among patients with underlying health conditions
(45.4%).11
Based on rates of severe disease reported in mainland China and assuming severe cases
would be hospitalized, a demography-adjusted and under-ascertainment-adjusted model
estimated the proportion of infected individuals requiring hospitalization. The proportions
ranged from 8.2% in the age group 50-59 years to 18.4% in those older than 80 years. In the
age groups below 50 years, less than 5% of infections were estimated to lead to
hospitalization.20
As of 28 July 2020, the total number of COVID-19 related deaths in the EU and UK was
over 100,000 and, in the US more than 150,000 people had died from COVID-19.3 Overall
reported mortality among hospitalized COVID-19 patients varies from 12.8% to 26% in
Europe5,23,24 and 20%-23% in the US.7,15,17 In the US, studies have also reported up to 40%
mortality in patients admitted to the ICU.14,15,17 Age older than 60 years, male gender,
hypertension, cardiovascular disease and chronic pulmonary disease, have been shown to be
independently associated with in-hospital death of COVID-19 patients.7,14,24
Important co-morbidities:
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been reported to be lower in mild cases and higher among fatal cases, as shown in Table 2
below.
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Nonclinical studies in mice and NHP for BNT162b2 (COVID-19 mRNA vaccine)
demonstrated both a strong neutralizing antibody response and a Th1-type CD4+ and an
IFN+ CD8+ T-cell response. The Th1 profile is characterized by a strong IFNγ, but not IL-4,
response indicating the absence of a potentially deleterious Th2 immune response and is a
pattern favored for vaccine safety and efficacy.25 Rhesus macaques (Study VR-VRT-10671)
that had received two IM immunizations with 100 µg BNT162b2 or saline 21 days apart
were challenged with 1.05 × 106 plaque forming units of SARS-CoV-2 (strain
USA-WA1/2020), split equally between the intranasal and intratracheal routes.26 BNT162b2
provided complete protection from the presence of detectable viral RNA in the lungs
compared to the saline control with no clinical, radiological or histopathological evidence of
vaccine-elicited disease enhancement.
An intravenous rat PK study, using an LNP with the identical lipid composition as
COVID-19 mRNA vaccine, demonstrated that the novel lipid excipients in the LNP
formulation, ALC-0315 and ALC-0159, distribute from the plasma to the liver. While there
was no detectable excretion of either lipid in the urine, the percent of dose excreted
unchanged in feces was ~1% for ALC-0315 and ~50% for ALC-0159. Further studies
indicated metabolism played a role in the elimination of ALC-0315. Biodistribution was
assessed using luciferase expression as a surrogate reporter formulated like COVID-19
mRNA vaccine, with the identical lipid composition. After IM injection of the
LNP-formulated RNA encoding luciferase in BALB/c mice, luciferase protein expression
was demonstrated at the site of injection 6 hours post dose and expression decreased over
time to almost reach background levels after 9 days. Luciferase was detected to a lesser
extent in the liver; expression was present at 6 hours after injection and was not detected by
48 hours after injection. After IM administration of a radiolabeled LNP-mRNA formulation
containing ALC-0315 and ALC-0159 to rats, the percent of administered dose was also
greatest at the injection site. Outside of the injection site, total recovery of radioactivity was
greatest in the liver and much lower in the spleen, with very little recovery in the adrenal
glands and ovaries. The metabolism of ALC-0315 and ALC-0159 was evaluated in blood,
liver microsomes, S9 fractions, and hepatocytes from mice, rats, monkeys, and humans. The
in vivo metabolism was examined in rat plasma, urine, feces, and liver samples from the PK
study. ALC-0315 and ALC-0159 are metabolized by hydrolytic metabolism of the ester and
amide functionalities, respectively, and this hydrolytic metabolism is observed across the
species evaluated.
In GLP toxicity studies, two variants of the COVID-19 mRNA vaccine candidate were
tested, designated “variant 8” and “variant 9” (V8 and V9, respectively). The variants differ
only in their codon optimization sequences which are designed to improve antigen
expression, otherwise the amino acid sequences of the encoded antigens are identical.
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COVID-19 mRNA vaccine (V9) was evaluated clinically and submitted for application.
Two GLP-compliant repeat-dose toxicity studies were performed in Wistar Han rats; one
with each variant. Both studies were 17 days in duration with a 3-week recovery period. A
DART study in Wistar Han rats has been completed. Safety pharmacology, genotoxicity and
carcinogenicity studies have not been conducted, in accordance with the 2005 WHO vaccine
guideline.27
The IM route of exposure was selected for nonclinical investigation as it is the clinical route
of administration. Rats were selected as the toxicology test species as they demonstrated an
antigen-specific immune response to the vaccine and are routinely used for regulatory
toxicity studies with an extensive historical safety database.
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BNT162-01 is not conducted under the US IND application but is being conducted under a
German Clinical Trial Application. The protocol for this study is provided in
Module 5.3.5.1.
Four vaccine candidates were evaluated in Study BNT162-01. Based on safety and
immunogenicity results from this study, 2 vaccine candidates, BNT162b1 and BNT162b2,
were selected for evaluation in Study C4591001 (provided in Module 5.3.5.1), which is a
Phase 1/2/3 randomized, placebo-controlled, observer-blind, dose-finding, vaccine
candidate-selection, and efficacy study in healthy adults.
Both vaccine candidate constructs were safe and well tolerated. BNT162b2 at the 30-µg
dose level was selected and advanced to the Phase 2/3 expanded cohort and efficacy
evaluation primarily because:
the reactogenicity profile for BNT162b2 was more favourable than BNT162b1 in both
younger and older adults with similar immunogenicity results;
in the NHP challenge study (VR-VTR-10671 – cross ref. with Module SII), a trend toward
earlier clearance of BNT162b2 was observed in the nose.
Phase 2 of the study (for which enrolment has completed) comprised the evaluation of safety
and immunogenicity data for the first 360 participants (180 from the active vaccine group
and 180 from the placebo group, with each group divided between the younger and older age
cohorts) entering the study after completion of Phase 1.
The Phase 3 part of the study (which is ongoing) evaluates the efficacy and safety in all
participants (including the first 360 participants from Phase 2). Phase 3 introduced
enrolment of adolescents 16 to 17 years of age to be evaluated with the 18- to 55-year-old
cohort, as well as enrolment of a 12- to ≤16-year-old cohort, and immunogenicity data from
adolescents 12- to ≤16 years of age are anticipated to bridge to the 16- to 25-year-old cohort.
The pivotal study was initially planned to enrol approximately 30,000 participants, which
would have a probability of 78% of detecting an AE with a frequency of 0.01% (1/1000) and
a probability of 95% of detecting an AE with a frequency of 0.02% (1/500). The protocol
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was amended to enrol 44,000 participants, which slightly enhanced the ability to detect AEs.
However, rarer events might not be detected.
Participants are planned to be followed for up to 24 months. This is particularly relevant for
assessing the potential for late-occurring adverse reactions, such as the theoretical risk of
VAED including VAERD.
The efficacy evaluation is event-driven, with prespecified interim analyses after accrual of at
least 62, 92, and 120 cases and a final analysis at 164 cases.
Clinical study exposure data are being provided for ongoing studies as of 14 November 2020
for study C4591001 and as of 02 October 2020 for study BNT162-01.
At the DLP, a total of 43,734 participants were vaccinated in the COVID-19 mRNA vaccine
clinical development program:
Population for analysis of CTs data in this RMP includes the following 2 studies:
BNT162-01: A multi-site, phase I/II, 2-part, dose-escalation trial investigating the safety
and immunogenicity of four prophylactic SARS-CoV-2 RNA vaccines against
COVID-19 using different dosing regimens in healthy adults.
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Vaccine 20 µg
2 Doses 12 24
Total 12 24
Vaccine 30 µg
1 Dose 825 825
2 Doses 11830 23660
Total 12655 24485
>55 years
Vaccine 10 µg
2 Doses 12 24
Total 12 24
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Vaccine 20 µg
2 Doses 12 24
Total 12 24
Vaccine 30 µg
1 Dose 323 323
2 Doses 8629 17258
Total 8952 17581
Note: 30 μg includes data from phase 1 and phase 2/3.
PFIZER CONFIDENTIAL SDTM Creation: 17NOV2020 (10:49) Source Data: adsl Table Generation: 19NOV2020 (00:22) (Cutoff date: 14NOV2020,
Snapshot Date: 16NOV2020) Output File: (CDISC)/C4591001_RMP_Phase1_2_3/adsl_s912
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Vaccine 3 µg
1 Dose 0 0
2 Doses 12 24
Total 12 24
Vaccine 10 µg
1 Dose 1 1
2 Doses 11 22
Total 12 23
Vaccine 20 µg
1 Dose 0 0
2 Doses 12 24
Total 12 24
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>55 years
Vaccine 1 µg
1 Dose 0 0
2 Doses 0 0
Total 0 0
Vaccine 3 µg
1 Dose 0 0
2 Doses 0 0
Total 0 0
Vaccine 10 µg
1 Dose 0 0
2 Doses 12 24
Total 12 24
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Vaccine 30 µg
1 Dose 0 0
2 Doses 12 24
Total 12 24
PFIZER CONFIDENTIAL SDTM Creation: 03NOV2020 (21:23) Source Data: adsl Table Generation: 18NOV2020 (14:42) (Cutoff date:02OCT2020, Snapshot Date:
02OCT2020)
Output File: ex_b2_age_dose2.rtf
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Table 6. Exposure to BNT162b2 by Age Group and Dose – Children and Elderly Subjects (C4591001)
≥65 years
Vaccine 10 µg
2 Doses 12 24
Total 12 24
Vaccine 20 µg
2 Doses 12 24
Total 12 24
Vaccine 30 µg
1 Dose 121 121
2 Doses 4435 8870
Total 4556 8991
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Vaccine 10 µg
2 Doses 24 48
Total 24 48
Vaccine 20 µg
2 Doses 24 48
Total 24 48
Vaccine 30 µg
1 Dose 1209 1209
2 Doses 20536 41072
Total 21745 42281
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Vaccine 3 µg
1 Dose 0 0
2 Doses 12 24
Total 12 24
Vaccine 10 µg
1 Dose 1 1
2 Doses 23 46
Total 24 47
Vaccine 20 µg
1 Dose 0 0
2 Doses 24 48
Total 24 48
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Vaccine 10 µg
≥18 years to ≤55 years 5 7 10 14
>55 years 2 10 4 20
Total 7 17 14 34
Vaccine 20 µg
≥18 years to ≤55 years 6 6 12 12
>55 years 5 7 10 14
Total 11 13 22 26
Vaccine 30 µg
≥16 years to ≤17 years 75 63 117 98
≥18 years to ≤55 years 6437 6218 12397 12088
>55 years 4680 4272 9177 8404
Total 11192 10553 21691 20590
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Table 10. Exposure to BNT162b2 by Dose, Age Group, and Gender (BNT162-01)
No. of Subjects Exposed to Total No. of Vaccine Doses
BNT162b2
Dose Male Female Male Female
Age Group
Vaccine 1 µg
≥18 years to ≤55 years 7 5 14 9
>55 years 0 0 0 0
Total 7 5 14 9
Vaccine 3 µg
≥18 years to ≤55 years 5 7 10 14
>55 years 0 0 0 0
Total 5 7 10 14
Vaccine 10 µg
≥18 years to ≤55 years 4 8 8 15
>55 years 8 4 16 8
Total 12 12 24 23
Vaccine 20 µg
≥18 years to ≤55 years 2 10 4 20
>55 years 6 6 12 12
Total 8 16 16 32
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Table 10. Exposure to BNT162b2 by Dose, Age Group, and Gender (BNT162-01)
No. of Subjects Exposed to Total No. of Vaccine Doses
BNT162b2
Dose Male Female Male Female
Age Group
Vaccine 30 µg
≥18 years to ≤55 years 8 4 16 8
>55 years 4 8 8 16
Total 12 12 24 24
PFIZER CONFIDENTIAL SDTM Creation: 03NOV2020 (21:23) Source Data: adsl Table Generation: 18NOV2020 (15:12) (Cutoff date:02OCT2020, Snapshot Date:
02OCT2020)
Output File: ex_b2_age_dose_sex2.rtf
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Table 11. Exposure to BNT162b2 by Age Group, Dose, and Race/Ethnic Origin (C4591001)
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Table 11. Exposure to BNT162b2 by Age Group, Dose, and Race/Ethnic Origin (C4591001)
Vaccine 20 µg
Racial Origin
White 10 20
Black or African American 2 4
Total 12 24
Ethnic Origin
Hispanic/Latino 1 2
Non-Hispanic/non-Latino 11 22
Total 12 24
Vaccine 30 µg
Racial Origin
White 9917 19153
Black or African American 1400 2725
Asian 681 1332
American Indian or Alaska Native 118 211
Native Hawaiian or other Pacific Islander 40 79
Multiracial 418 825
Not reported 81 160
Total 12655 24485
Ethnic Origin
Hispanic/Latino 4001 7807
Non-Hispanic/non-Latino 8590 16557
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Table 11. Exposure to BNT162b2 by Age Group, Dose, and Race/Ethnic Origin (C4591001)
Vaccine 20 µg
Racial Origin
White 12 24
Total 12 24
Ethnic Origin
Non-Hispanic/non-Latino 12 24
Total 12 24
Vaccine 30 µg
Racial Origin
White 7842 15403
Black or African American 671 1312
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Table 11. Exposure to BNT162b2 by Age Group, Dose, and Race/Ethnic Origin (C4591001)
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Table 12. Exposure to BNT162b2 by Age Group, Dose, and Race/Ethnic Origin (BNT162-01)
Age Group No. of Subjects Exposed to BNT162b2 Total No. of Vaccine Doses
Dose
Race/Ethnic Origin
Subjects ≥18 to ≤55 years
Vaccine 1 µg
Racial Origin
White 12 23
Black or African American 0 0
Asian 0 0
American Indian or Alaska Native 0 0
Native Hawaiian or Other Pacific Islander 0 0
Other 0 0
Not Reported 0 0
Unknown 0 0
Total 12 23
Ethnic Origin
Hispanic/Latino 0 0
Non-Hispanic/non-Latino 12 23
Not reported 0 0
Unknown 0 0
Total 12 23
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Table 12. Exposure to BNT162b2 by Age Group, Dose, and Race/Ethnic Origin (BNT162-01)
Age Group No. of Subjects Exposed to BNT162b2 Total No. of Vaccine Doses
Dose
Race/Ethnic Origin
Subjects ≥18 to ≤55 years
Vaccine 3 µg
Racial Origin
White 12 24
Black or African American 0 0
Asian 0 0
American Indian or Alaska Native 0 0
Native Hawaiian or Other Pacific Islander 0 0
Other 0 0
Not Reported 0 0
Unknown 0 0
Total 12 24
Ethnic Origin
Hispanic/Latino 0 0
Non-Hispanic/non-Latino 12 24
Not reported 0 0
Unknown 0 0
Total 12 24
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Table 12. Exposure to BNT162b2 by Age Group, Dose, and Race/Ethnic Origin (BNT162-01)
Age Group No. of Subjects Exposed to BNT162b2 Total No. of Vaccine Doses
Dose
Race/Ethnic Origin
Subjects ≥18 to ≤55 years
Vaccine 10 µg
Racial Origin
White 12 23
Black or African American 0 0
Asian 0 0
American Indian or Alaska Native 0 0
Native Hawaiian or Other Pacific Islander 0 0
Other 0 0
Not Reported 0 0
Unknown 0 0
Total 12 23
Ethnic Origin
Hispanic/Latino 0 0
Non-Hispanic/non-Latino 12 23
Not reported 0 0
Unknown 0 0
Total 12 23
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Table 12. Exposure to BNT162b2 by Age Group, Dose, and Race/Ethnic Origin (BNT162-01)
Age Group No. of Subjects Exposed to BNT162b2 Total No. of Vaccine Doses
Dose
Race/Ethnic Origin
Subjects ≥18 to ≤55 years
Vaccine 20 µg
Racial Origin
White 12 24
Black or African American 0 0
Asian 0 0
American Indian or Alaska Native 0 0
Native Hawaiian or Other Pacific Islander 0 0
Other 0 0
Not Reported 0 0
Unknown 0 0
Total 12 24
Ethnic Origin
Hispanic/Latino 0 0
Non-Hispanic/non-Latino 12 24
Not reported 0 0
Unknown 0 0
Total 12 24
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Table 12. Exposure to BNT162b2 by Age Group, Dose, and Race/Ethnic Origin (BNT162-01)
Age Group No. of Subjects Exposed to BNT162b2 Total No. of Vaccine Doses
Dose
Race/Ethnic Origin
Subjects ≥18 to ≤55 years
Vaccine 30 µg
Racial Origin
White 12 24
Black or African American 0 0
Asian 0 0
American Indian or Alaska Native 0 0
Native Hawaiian or Other Pacific Islander 0 0
Other 0 0
Not Reported 0 0
Unknown 0 0
Total 12 24
Ethnic Origin
Hispanic/Latino 0 0
Non-Hispanic/non-Latino 12 24
Not reported 0 0
Unknown 0 0
Total 12 24
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Table 12. Exposure to BNT162b2 by Age Group, Dose, and Race/Ethnic Origin (BNT162-01)
Age Group No. of Subjects Exposed to BNT162b2 Total No. of Vaccine Doses
Dose
Race/Ethnic Origin
Subjects >55 to ≤85 years
Vaccine 1 µg
Racial Origin
White 0 0
Black or African American 0 0
Asian 0 0
American Indian or Alaska Native 0 0
Native Hawaiian or Other Pacific Islander 0 0
Other 0 0
Not Reported 0 0
Unknown 0 0
Total 0 0
Ethnic Origin
Hispanic/Latino 0 0
Non-Hispanic/non-Latino 0 0
Not reported 0 0
Unknown 0 0
Total 0 0
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Table 12. Exposure to BNT162b2 by Age Group, Dose, and Race/Ethnic Origin (BNT162-01)
Age Group No. of Subjects Exposed to BNT162b2 Total No. of Vaccine Doses
Dose
Race/Ethnic Origin
Subjects >55 to ≤85 years
Vaccine 3 µg
Racial Origin
White 0 0
Black or African American 0 0
Asian 0 0
American Indian or Alaska Native 0 0
Native Hawaiian or Other Pacific Islander 0 0
Other 0 0
Not Reported 0 0
Unknown 0 0
Total 0 0
Ethnic Origin
Hispanic/Latino 0 0
Non-Hispanic/non-Latino 0 0
Not reported 0 0
Unknown 0 0
Total 0 0
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Table 12. Exposure to BNT162b2 by Age Group, Dose, and Race/Ethnic Origin (BNT162-01)
Age Group No. of Subjects Exposed to BNT162b2 Total No. of Vaccine Doses
Dose
Race/Ethnic Origin
Subjects >55 to ≤85 years
Vaccine 10 µg
Racial Origin
White 12 24
Black or African American 0 0
Asian 0 0
American Indian or Alaska Native 0 0
Native Hawaiian or Other Pacific Islander 0 0
Other 0 0
Not Reported 0 0
Unknown 0 0
Total 12 24
Ethnic Origin
Hispanic/Latino 0 0
Non-Hispanic/non-Latino 12 24
Not reported 0 0
Unknown 0 0
Total 12 24
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Table 12. Exposure to BNT162b2 by Age Group, Dose, and Race/Ethnic Origin (BNT162-01)
Age Group No. of Subjects Exposed to BNT162b2 Total No. of Vaccine Doses
Dose
Race/Ethnic Origin
Subjects >55 to ≤85 years
Vaccine 20 µg
Racial Origin
White 12 24
Black or African American 0 0
Asian 0 0
American Indian or Alaska Native 0 0
Native Hawaiian or Other Pacific Islander 0 0
Other 0 0
Not Reported 0 0
Unknown 0 0
Total 12 24
Ethnic Origin
Hispanic/Latino 0 0
Non-Hispanic/non-Latino 12 24
Not reported 0 0
Unknown 0 0
Total 12 24
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Table 12. Exposure to BNT162b2 by Age Group, Dose, and Race/Ethnic Origin (BNT162-01)
Age Group No. of Subjects Exposed to BNT162b2 Total No. of Vaccine Doses
Dose
Race/Ethnic Origin
Subjects >55 to ≤85 years
Vaccine 30 µg
Racial Origin
White 12 24
Black or African American 0 0
Asian 0 0
American Indian or Alaska Native 0 0
Native Hawaiian or Other Pacific Islander 0 0
Other 0 0
Not Reported 0 0
Unknown 0 0
Total 12 24
Ethnic Origin
Hispanic/Latino 0 0
Non-Hispanic/non-Latino 12 24
Not reported 0 0
Unknown 0 0
Total 12 24
PFIZER CONFIDENTIAL SDTM Creation: 03NOV2020 (21:23) Source Data: adsl Table Generation: 17NOV2020 (12:53) (Cutoff date:02OCT2020, Snapshot Date:
02OCT2020)
Output File: ex_b2_age_dose_race.rtf
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Vaccine 10 µg
Racial Origin
White 23 46
Asian 1 2
Total 24 48
Ethnic Origin
Hispanic/Latino 1 2
Non-Hispanic/non-Latino 23 46
Total 24 48
Vaccine 20 µg
Racial Origin
White 22 44
Black or African American 2 4
Total 24 48
Ethnic Origin
Hispanic/Latino 1 2
Non-Hispanic/non-Latino 23 46
Total 24 48
Vaccine 30 µg
Racial Origin
White 17861 34714
Black or African American 2092 4072
Asian 936 1830
American Indian or Alaska Native 160 291
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AIDS/HIV 99 177
Cerebrovascular Disease + Peripheral Vascular Disease + Myocardial Infarction + Congestive Heart 645 1265
Failure
Dementia 7 14
Hemiplegia or Paraplegia 4 8
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Note: Comorbidity is based Charlson Comorbidity Index categories. Participants identified as belonging to these categories were identified by medical history
data collected during the study.
Note: 30 μg includes data from phase 1 and phase 2/3.
Note: Hemiplegia or Paraplegia only includes preferred terms Hemiplegia and Paraplegia.
a. n = Number of subjects reporting at least 1 occurrence of any comorbidity or BMI (≥30.0 kg/m 2).
b. N = number of subjects in the specified group.
PFIZER CONFIDENTIAL SDTM Creation: 17NOV2020 (10:04) Source Data: admh Table Generation: 18NOV2020 (23:16) (Cutoff date: 14NOV2020,
Snapshot Date: 16NOV2020) Output File: (CDISC)/C4591001_RMP_Phase1_2_3/admh_s953
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Inclusion criteria
Healthy participants with pre-existing stable disease, defined as disease not requiring
significant change in therapy or hospitalization for worsening disease during the 6 weeks
before enrolment, can be included. In order for the overall Phase 3 study population to be
as representative and diverse as possible, the inclusion of participants with known
chronic stable infection with HIV, HCV, or HBV was permitted as the study progressed.
Specific criteria for these Phase 3 participants can be found in the C4591001 protocol,
Section 10.8 (please refer to Module 5.3.5.1).
Phase 2/3 only: Participants who, in the judgment of the investigator, are at higher risk
for acquiring COVID-19 (including, but not limited to, use of mass transportation,
relevant demographics, front-line essential workers and others).
Exclusion criteria
The participants enrolled were 12 years of age and older; with the 12- to ≤16-year-old cohort
most recently being included in the protocol. Phase 1 exclusion criteria were stricter than
criteria in Phases 2 and 3 of the study. Participants were excluded from the studies according
to the general criteria listed below:
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Rationale: Safety in study participants with prior infection will be assessed in the pivotal
study.
Rationale: It is not known if maternal vaccination with COVID-19 mRNA vaccine would
have unexpected negative consequences to the embryo or foetus.
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Other medical or psychiatric condition including recent (within the past year) or
active suicidal ideation/behaviour or laboratory abnormality that may increase the
risk of study participation or, in the investigator’s judgment, make the participant
inappropriate for the study
Reason for exclusion: To avoid misleading results deriving from non-compliance to study
procedures.
Rationale: Safety profile of COVID-19 mRNA vaccine is not expected to differ in these
subjects when properly administered.
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SV.1.2. Exposure
Not applicable.
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COVID-19 mRNA vaccine does not have characteristics that would make it attractive for use
for illegal purposes; therefore, there is only a low potential for COVID-19 mRNA vaccine
misuse for illegal purposes.
The vaccine construct and the formulation. The COVID-19 mRNA vaccine consists
of non-infectious, non-replicating RNA in a lipid-based formulation, which delivers the
RNA to cells in the immunized person. Protein expression from the RNA is transient,
and as is RNA itself. There is no toxicity associated with the LNP or its metabolism
(Study reports 38166 and 20GR142). Vacuolation of hepatocytes was observed in rat
toxicity studies and believed to be associated with the uptake of the LNP and was without
evidence of any effect on liver function. The liver vacuolation was reversed
approximately 3-weeks after the last administration.
The degradation of the active substance / antigen and potential impact on safety
related to this; (e.g. for mRNA-based vaccines). Like endogenous mRNA in the
cytosol, vaccine RNA in cytosol is degraded. The COVID-19 mRNA contains no known
toxic products of the degradation of the RNA or the lipids in the formulation.
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SVII.1.1. Risks not Considered Important for Inclusion in the List of Safety Concerns
in the RMP
Not all potential or identified risks for the vaccine are considered to meet the level of
importance necessitating inclusion in the list of safety concerns in the RMP.
Reasons for not including an identified or potential risk in the list of safety concerns in
this RMP include:
Risks with minimal and temporary clinical impact on patients (in relation to the severity of
the disease prevented).
The following reactogenicity events are identified risks not considered as Important:
Injection site pain, Injection site swelling and Injection site redness, Fever, Chills, Fatigue,
Headache, Muscle pain, and Joint pain.
Very rare potential risks for any medicinal treatment, including vaccines, which are well
known to healthcare professionals are not included in the list of safety concerns.
Reactogenicity
At the time of the safety cut-off date (14 November 2020), the Phase 2/3 reactogenicity
subset was comprised of 8183 participants (≥12 years of age), which included the 360
participants in Phase 2. The reactogenicity data were collected by participants’ e-diary for
reporting prompted local reactions and systemic events for 7 days after each dose.
Adolescents 12 to 15 years of age were analysed in a separate group; these are preliminary
data provided in support of the EUA indication which is for ≥16 years of age.
Local Reactions
In the BNT162b2 group, pain at the injection site was reported more frequently in the
younger group (16-55 years) than in the older group (> 55 years), and frequency was similar
after Dose 1 compared with Dose 2 of BNT162b2 in the younger group (83.1% vs 77.8%)
and in the older group (71.1% vs 66.1%).
In the BNT162b2 group, frequencies of redness and swelling were similar in the younger and
older age group after Doses 1 and 2. Frequencies of redness were similar after Dose 1
compared with Dose 2 of BNT162b2 in the younger age group (4.5% vs 5.9%) and in the
older age group (4.7% vs 7.2%). Frequencies of swelling were similar after Dose 1 compared
with Dose 2 of BNT162b2 in the younger age group (5.8% vs 6.3%, respectively) and in the
older age group (6.5% vs 7.5%). In the placebo group, redness and swelling were reported
infrequently in the younger (≤1.1%) and older (≤1.1%) groups after Doses 1 and 2.
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Overall, across age groups, pain at the injection site did not increase after Dose 2, and
redness and swelling were generally similar in frequency after Dose 1 and Dose 2. Most
local reactions were mild or moderate in severity. Few severe local reactions were reported
after either dose. The frequency of any severe local reactions after Dose 1 and after Dose 2
was ≤0.6%. No grade 4 (potentially life-threatening) reactions were reported.
Across age groups, local reactions for the BNT162b2 group after either dose had a median
onset day between Day 1 and Day 3 (Day 1 was the day of vaccination) and ranges were
similar in the younger and older age groups. Across age groups, local reactions for this
group after either dose resolved with median durations between 1 to 2 days, which were
similar in the younger and older age groups.
Systemic Events
Systemic events were generally increased in frequency and severity in the younger age group
(16-55 years) compared with the older age group (> 55 years), with frequencies and severity
increasing with number of doses (Dose 1 vs Dose 2). Vomiting and diarrhoea were
exceptions, with vomiting reported similarly infrequently in both age groups and diarrhoea
reported at similar incidences after each dose.
Systemic events in the younger group compared with the older group, with frequencies
increasing with number of doses (Dose 1 vs Dose 2), were:
fatigue: younger group (47.4% vs 59.4%) compared to older group (34.1% vs 50.5%)
headache: younger group (41.9% vs 51.7%) compared to older group (25.2% vs 39.0%)
muscle pain: younger group (21.3% vs 37.3%) compared to older group (13.9% vs
28.7%)
chills: younger group (14.0% vs 35.1%) compared to older group (6.3% vs 22.7%)
joint pain: younger group (11.0% vs 21.9%) compared to older group (8.6% vs 18.9%)
fever: younger group (3.7% vs 15.8%) compared to older group (1.4% vs 10.9%)
vomiting: reported less frequently in the older group and was similar after either dose
diarrhoea: reported less frequently in the older group and was similar after each dose.
Systemic events were generally reported less frequently in the placebo group than in the
BNT162b2 group, for both age groups and doses, with some exceptions. In the younger
age group, vomiting and diarrhoea (after Dose 1 and Dose 2) were reported at similar
frequencies in the placebo group and the BNT162b2 group. In the older age group, fever
and joint pain (after Dose 1) and vomiting and diarrhoea (after Dose 1 and Dose 2) were
reported at similar frequencies in the placebo group and the BNT162b2 group.
Following both Dose 1 and Dose 2, use of antipyretic/pain medication was slightly less
frequent in the older age group (19.9% vs 37.7%) than in the younger age group (27.8% vs
45.0%) after both doses, and medication use increased in both age groups after Dose 2 as
compared with after Dose 1. Use of antipyretic/pain medication was less frequent in the
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placebo group than in the BNT162b2 group and was similar after Dose 1 and Dose 2 in the
younger and older placebo groups (9.8% to 22.0%).
After the first and second dose and in both age groups, the majority of systemic events were
mild or moderate in severity. Systemic events across age groups after Dose 1 of BNT162b2
were generally lower in frequency than after Dose 2: fever (2.7% vs 13.6%), fatigue (41.5%
vs 55.5%), headache (34.5% vs 46.1%), chills (10.6% vs 29.6%), muscle pain (18.0% vs
33.5%), and joint pain (9.9% vs 20.5). Diarrhoea and vomiting frequencies were generally
similar. The frequency of any severe systemic event after Dose 1 was ≤0.9%. After Dose 2,
systemic events had frequencies of < 2% with the exception of fatigue (3.8%) and headache
(2.0%).
In the placebo group, severe fever was reported at a similar frequency (≤0.4%) after Dose 1
and Dose 2. One participant in the younger BNT162b2 group reported fever of 41.2°C only
on Day 2 after Dose 2 and was nonfebrile for all other days of the reporting period. One
other participant in the younger group reported fever that reached a high temperature of
42.3°C on Day 4 after Dose 1 that lasted in total for 3 days; the participant was nonfebrile at
the end of the reporting period.
Across age groups, median onset day for most systemic events after either dose of
BNT162b2 was Day 2 to Day 3 (Day 1 was the day of vaccination), and ranges were similar
in the younger and older age groups. Across age groups, all systemic events resolved with
median duration of 1 day, which was similar in the younger and older age groups.
Other than fatigue and headache, most systemic events were infrequent in placebo recipients.
Antipyretic/pain medication use in the younger adolescent group was modestly increased
after Dose 2 compared to Dose 1 (30.6% vs 41.3%) and was greater than use in the placebo
group (9.8% vs 13%).
COVID-19 mRNA vaccine study C4591001 did not pre-specify AESI however, Pfizer
utilizes a dynamic list of TME terms to be highlighted in clinical study safety data review.
TMEs include events of interest due to their association with COVID-19 and terms of interest
for vaccines in general and may include Preferred Terms, High Level Terms, High Level
Group Terms or Standardised MedDRA Queries.
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For the purpose of the RMP and summary safety reports, an AESI list was composed taking
into consideration the available lists of AESIs from the following expert groups and
regulatory authorities:
The AESI list is comprised of medical conditions to allow for changes and customization of
MedDRA terms as directed by AE reports and the evolving safety profile of the vaccine:
The AESIs are taken in consideration for all routine and additional pharmacovigilance
activities.
SVII.1.2. Risks Considered Important for Inclusion in the List of Safety Concerns in
the RMP
Important Identified Risk: Anaphylaxis
Risk-benefit impact
Anaphylaxis is a serious adverse reaction that, although very rare, can be life-threatening.
Risk-benefit impact
Although not observed or identified in clinical studies with COVID-19 vaccines, there is a
theoretical risk, mostly based on non-clinical betacoronavirus data, of VAED occurring
either before the full vaccine regimen is administered or in vaccinees who have waning
immunity over time. If VAED were to be identified as a true risk, depending on its incidence
and severity, it may negatively impact the overall vaccine benefit risk assessment for certain
individuals.
Risk-benefit impact
The safety profile of the vaccine is not known in pregnant or breastfeeding women due to
their exclusion from the pivotal clinical study. Accordingly, maternal COVID-19 impact to
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either embryo or foetus is also not known. It is important to obtain long term follow-up on
women who were pregnant at or around the time of vaccination so that any potential negative
consequences to the pregnancy can be assessed and weighed against the effects of maternal
COVID-19 on the pregnancy.
Risk-benefit impact
The safety profile of the vaccine is not known in immunocompromised individuals due to
their exclusion from the pivotal clinical study. The efficacy of the vaccine may be lower in
immunocompromised individuals, thus decreasing their protection from COVID-19.
Missing Information: Use in frail patients with co-morbidities (e.g. chronic obstructive
pulmonary disease (COPD), diabetes, chronic neurological disease, cardiovascular
disorders)
Risk-benefit impact
There is limited information on the safety of the vaccine in frail patients with co-morbidities
who are potentially at higher risk of severe COVID-19.
Risk-benefit impact
There is limited information on the safety of the vaccine in individuals with autoimmune or
inflammatory disorders and a theoretical concern that the vaccine may exacerbate their
underlying disease.
Risk-benefit impact
BNT162b2 mRNA vaccine will be used in individuals who also may receive other vaccines.
Studies to determine if co-administration of BNT162b2 mRNA vaccine with other vaccines
may affect the efficacy or safety of either vaccine have not been performed.
Risk-benefit impact
The long-term safety of BNT162b2 mRNA vaccine is unknown at present, however further
safety data are being collected in ongoing Study C4591001 for up to 2 years following
administration of dose 2 of BNT162b2 mRNA vaccine.
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SVII.3. Details of Important Identified Risks, Important Potential Risks, and Missing
Information
SVII.3.1. Presentation of Important Identified Risks and Important Potential Risks
SVII.3.1.1. Important Identified Risk: Anaphylaxis
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Table 22. Use in frail patients with co-morbidities (e.g. chronic obstructive
pulmonary disease (COPD), diabetes, chronic neurological disease,
cardiovascular disorders)
Evidence source:
The vaccine has been studied in individuals with stable chronic diseases (e.g. hypertension, obesity),
however it has not been studied in frail individuals with severe co-morbidities that may compromise immune
function due to the condition or treatment of the condition. Therefore, further safety data will be sought in
this population.
Population in need of further characterisation:
Safety data will be collected in individuals who are frail due to age or debilitating disease in the active
surveillance studies and through routine pharmacovigilance.
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Pfizer, on behalf of the MAA monitors the safety profile of its products, evaluates issues
potentially impacting product benefit-risk profiles in a timely manner, and ensures that
appropriate communication of relevant safety information is conveyed in a timely manner to
regulatory authorities and other interested parties as appropriate and in accordance with
international principles and prevailing regulations. Pfizer, on behalf of the MAA, gathers
data for signal detection and evaluation commensurate with product characteristics.
Routine pharmacovigilance activities beyond the receipt and review of individual AE reports
(e.g. ADRs) include:
Data Capture Aids have been created for this vaccine. They are intended to facilitate the
capture of clinical details about
the nature and severity of COVID-19 illness in individuals who have received the
COVID-19 mRNA vaccine and is anticipated to provide insight into potential cases of
vaccine lack of effect or VAED. The DCA is provided in Annex 4;
potential anaphylactic reactions in individuals who have received the COVID-19
mRNA vaccine. This DCA is in preparation and will be submitted.
Signal detection activities for the lifecycle of vaccines consist of individual AE
assessment at case receipt, regular aggregate review of cases for trends and statistically
disproportionately reported product-adverse event pairs. Aggregated and statistical
reviews of data are conducted utilizing Pfizer’s software interactive tools. Safety signal
evaluation requires the collection, analysis and assessment of information to evaluate
potential causal associations between an event and the product and includes subsequent
qualitative or quantitative characterization of the relevant safety risk to determine
appropriate continued pharmacovigilance and risk mitigation actions. Signal detection
activities for the COVID-19 mRNA vaccine, will occur on a weekly basis. In addition,
observed versus expected analyses will be conducted as appropriate as part of routine
signal management activity.
Routine signal detection activities for the COVID-19 mRNA vaccine will include routine
and specific review of AEs consistent with the AESI list provided in
PART II.SVII.1.1 – Risks not considered important for inclusion in the list of safety
concerns in the RMP.
In addition, published literature is reviewed weekly for individual case reports and
broader signal detection purposes.
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In addition to routine 6-monthly PSUR production, monthly summary safety reports will be
compiled to support timely and continuous benefit risk evaluations. Topics covered by
monthly summary safety reports will include:
The submission of monthly reports complements the submission of 6 monthly PSURs. The
need and frequency of submission of such reports will be re-evaluated based on the available
evidence from post-marketing after 6 months (6 submissions).
Monthly reports and PSURs will include results of the observed versus expected
analysis for AESI as appropriate, including cases of Bell’s palsy and will present the
results and details of the statistical approach.
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Large scale public health approaches for mass vaccination may represent changes to standard
vaccine treatment process, thereby potentially introducing the risk of medication errors
related to: reconstitution and administration, vaccination scheme, storage conditions, errors
associated with a multi-dose vial, and once other COVID vaccines are available, confusion
with other COVID vaccines. These potential medication errors are mitigated through the
information in the SmPC and available educational materials for healthcare providers.
Traceability
to clearly record the name and batch number of the administered vaccine to improve
traceability (section 4.4);
to report any suspected adverse reactions including batch/Lot number if available (section
4.8).
Traceability is available for every shipping container of COVID mRNA vaccine, which are
outfitted with a unique device that provides real-time monitoring of geographic location and
temperature 24 hours per day, 7 days per week. Each device will also trace the batch/lot of
the associated shipment. The device is activated prior to shipment and information is
transmitted wirelessly to Pfizer at a predefined cadence, on behalf of the MAA, until delivery
to the vaccinator’s practice site. A shipment quality report that indicates if the product is
acceptable for immediate use is generated by Pfizer on behalf of the MAA and transmitted to
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the vaccinator’s practice site upon pressing of the stop button on the data logger, or arrival
notification from the carrier in combination with the data loggers location and/or light signal.
Additionally, alarms and escalation/notification for excursions (per pre-defined
specifications) are programmed into the device. These data may be used for the assessment
of a safety signal.
The vaccine carton labelling also contains a 2-D barcode which has the batch/lot and expiry
embedded within, should there be capability at a vaccination site to utilize this as an
information source.
Further, Pfizer on behalf of the MAA, will make available Traceability and Vaccination
Reminder cards (Annex 7) to vaccinators that may be completed at the time of vaccination.
The Traceability and Vaccination Reminder cards contain the following elements:
In addition, to the Traceability and Vaccination Reminder cards, two stickers per dose,
containing printed batch/lot information, will be made available to support documentation of
the batch/lot on the Traceability and Vaccination Reminder card and vaccinee medical
records in mass vaccination centers. We also acknowledge that some EU member states may
require utilization of nationally mandated vaccination cards or electronic systems to
document batch/lot number; therefore, the available Traceability and Vaccination Reminder
cards and stickers with printed lot/batch information may not be utilized in all member states.
The following milestones are proposed for the availability of the stickers with printed
lot/batch information:
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Multiple modalities will be utilized for quality assurance throughout shipment due to the
required ultra-cold storage for COVID-19 mRNA vaccine.
Each shipment of the vaccine is outfitted with a unique device that provides real-time
monitoring of geographic location and temperature 24 hours per day, 7 days per week
until delivery to a vaccinator’s practice site. Alarms and escalation/notification to Pfizer
on behalf of the MAA and/or to the recipient for excursions (per pre-defined
specifications) are programmed into the device. Additionally, a shipment quality report
that indicates if the product is acceptable for immediate use is generated by Pfizer and
transmitted to the vaccinator’s practice site.
Joint adverse event and product complaint (including available batch/lot information)
trending reviews occur routinely with Global Product Quality.
Additionally, available educational materials for vaccinators will include information
regarding proper handling of the shipment container as temporary storage, and
handling/disposal of dry ice until the received shipment is either placed into an ultra-low
temperature freezer, or is maintained in accord with pre-defined specifications in the
shipment container as temporary storage (i.e. upon receipt of the shipment quality report
noted above), as appropriate.
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Study C4591010 will be conducted in the EU using primary data collection to monitor a
cohort of vaccinees and evaluate risk of safety events of interest reflecting the AESI list.
A draft protocol C4591010 is provided in Annex 2.
Additionally, Pfizer, on behalf of the MAA, will sponsor one or more PASS using
secondary EHR data sources in Europe based on a master surveillance protocol
developed through the ACCESS project, which is funded by EMA and conducted via the
Vaccine monitoring Collaboration for Europe (VAC4EU) (VAC4EU, 2020). The MAA
has initiated a request for proposal with the VAC4EU secretariat. Pfizer on behalf of the
MAA, understands that the master protocol is under development with the EMA and
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notification will be provided once finalized and will provide draft protocols as soon as
available.
In addition to the studies planned for EU, in support of the US EUA application, Pfizer
has submitted to the FDA 2 draft protocols for safety surveillance of COVID-19 mRNA
vaccine in populations expected to receive the vaccination under EUA in the US. These
studies include:
1 study using secondary data from EHR of active military and their families
(C4591011),
1 study using secondary data from EHR of patients included in the Veterans
Healthcare Administration system (C4591012).
The draft protocols for the proposed safety studies in the US (C4591011 and C4591012)
are included in Annex 2.
The MAA agrees that monitoring vaccine safety in pregnant women is critical. Given that a
pregnancy registry based on primary data collection is susceptible to non-participation,
attrition, small sample size and limited or lack of comparator data, Pfizer, on behalf of the
MAA, would like to propose monitoring vaccine safety in pregnancy using electronic health
care data, which could be conducted in a representative pregnant woman population exposed
to the vaccine and minimize selection bias, follow-up bias, and reporting bias. In addition,
internal comparison groups, such as contemporaneous unvaccinated pregnant women or
women receiving other vaccine(s) to prevent COVID-19 (if available) could be included.
Pfizer will conduct, on behalf of the MAA, at least one non-interventional study (test
negative design) of individuals presenting to the hospital or emergency room with symptoms
of potential COVID-19 illness in a real-world setting (C4591014). The effectiveness of
COVID-19 mRNA vaccine will be estimated against laboratory confirmed COVID 19 illness
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C4591012 Post-Emergency Use Assessment of occurrence of Secondary database analysis of US Veteran's Interim reports 30-Jun-2021
Authorization Active safety events of interest, observational data to estimate submission:
Surveillance of including severe or atypical incidence rates of safety events 31-Dec-2021
US Adverse Events of COVID-19 in real-world use of interest and other clinically
Special Interest of COVID-19 mRNA significant events in a cohort 30-Jun-2022
among Individuals in vaccine. of US veterans who receive
the Veteran’s Affairs the COVID-19 mRNA vaccine 31-Dec-2022
Health System under EUA in the US
Receiving Final CSR submission: 31-Dec-2023
Pfizer-BioNTech
Coronavirus Disease
2019 (COVID-19)
Vaccine
Non-Interventional
Planned
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Non-Interventional
Planned
C4591015 A Phase 2/3, Placebo- Planned clinical study to Randomized, placebo- Healthy pregnant women Protocol draft 28-Feb-2021
Controlled, assess safety and controlled, observer-blind 18 years of age or older submission:
Randomized, immunogenicity in pregnant study vaccinated during their
Not available Observer-Blinded women who receive 24 to 34 weeks of
Study to Evaluate the COVID-19 mRNA vaccine gestation
Safety, Tolerability, Safety and immunogenicity
and Immunogenicity of COVID-19 mRNA
of a SARS-CoV-2 vaccine in pregnant women Final CSR submission: 30-Apr-2023
RNA Vaccine
Candidate
(BNT162b2) Against
COVID-19 in Healthy
Pregnant Women 18
Years of Age and
Older
Interventional
Planned
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Non-Interventional
Planned
Co-administration Co-administration of Safety and immunogenicity Not available at this time General population Protocol submission: 30-Sep-2021
study with seasonal BNT162b2 with of BNT162b2 and Final CSR submission: 31-Dec-2022
influenza vaccine seasonal influenza quadrivalent seasonal
vaccine influenza vaccine when
administered separately or
Not available concomitantly.
Interventional
Planned
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The safety information in the proposed product information is aligned to the reference
medicinal product.
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Use in pregnancy and Routine risk minimisation Routine pharmacovigilance activities beyond
while breast feeding measures: adverse reactions reporting and signal
SmPC section 4.6; PL section 2. detection:
None.
Additional risk minimisation
measures:
Additional pharmacovigilance activities:
No risk minimisation measures.
Studies (Final CSR Due Date)
C4591010 a(31-Mar-2024)
C4591011 a(31-Dec-2023)
C4591015 (30-Apr-2023)
ACCESS/VAC4EU a (31-Jan-2024).
Use in Routine risk minimisation Routine pharmacovigilance activities beyond
immunocompromised measures: adverse reactions reporting and signal
patients SmPC sections 4.4 and 5.1. detection:
None.
Additional risk minimisation
measures:
Additional pharmacovigilance activities:
No risk minimisation measures.
Studies (Final CSR or IA Due Date)
BNT162-01 Cohort 13 (IA: 30-Sep-2021,
CSR: 31-Dec-2022)
C4591018 (IA: 31-Dec-2021)
C4591011 (31-Dec-2023)
C4591012 (31-Dec-2023)
ACCESS/VAC4EU (31-Jan-2024).
Use in frail patients with Routine risk minimisation Routine pharmacovigilance activities beyond
co-morbidities (e.g. measures: adverse reactions reporting and signal
chronic obstructive SmPC section 5.1. detection:
pulmonary disease None.
(COPD), diabetes, Additional risk minimisation
chronic neurological measures: Additional pharmacovigilance activities:
disease, cardiovascular No risk minimisation measures. Studies (Final CSR Due Date submission)
disorders) C4591001 subset (31-Aug-2023)
C4591011 (31-Dec-2023)
C4591012 (31-Dec-2023)
ACCESS/VAC4EU (31-Jan-2024)
Safety and immunogenicity in high risk
adults (31-Dec-2022).
Use in patients with Routine risk minimisation Routine pharmacovigilance activities beyond
autoimmune or measures: adverse reactions reporting and signal
inflammatory disorders None. detection:
None.
Additional risk minimisation
measures: Additional pharmacovigilance activities:
No risk minimisation measures. C4591011 (31-Dec-2023)
C4591012 (31-Dec-2023)
C4591018 (31-Dec-2021)
ACCESS/VAC4EU (31-Jan-2024).
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Interaction with other Routine risk minimisation Routine pharmacovigilance activities beyond
vaccines measures: adverse reactions reporting and signal
SmPC section 4.5. detection:
None.
Additional risk minimisation
measures: Additional pharmacovigilance activities:
No risk minimisation measures. Co-administration study with seasonal
influenza vaccine (31-Dec-2022).
Long term safety data Routine risk minimisation Routine pharmacovigilance activities beyond
measures: adverse reactions reporting and signal
None. detection:
None.
Additional risk minimisation
measures: Additional pharmacovigilance activities:
No risk minimisation measures. Studies (Final CSR Due Date or IA CSR
submission)
C4591001 (31-Aug-2023)
C4591010 (31-Mar-2024)
C4591011 (31-Dec-2023)
C4591012 (31-Dec-2023)
ACCESS/VAC4EU (31-Jan-2024).
a. Please note that studies C4591010, C4591011 and ACCESS/VAC4EU address only “Use in pregnancy”.
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This is a summary of the risk management plan (RMP) for Comirnaty. The RMP details
important risks of Comirnaty, how these risks can be minimised, and how more information
will be obtained about Comirnaty's risks and uncertainties (missing information).
Comirnaty's summary of product characteristics (SmPC) and its package leaflet give essential
information to healthcare professionals and patients on how Comirnaty should be used.
This summary of the RMP for Comirnaty should be read in the context of all this information
including the assessment report of the evaluation and its plain-language summary, all which
is part of the European Public Assessment Report (EPAR).
Important new concerns or changes to the current ones will be included in updates of
Comirnaty's RMP.
II. Risks Associated With the Medicine and Activities to Minimise or Further
Characterise the Risks
Important risks of Comirnaty, together with measures to minimise such risks and the
proposed studies for learning more about Comirnaty's risks, are outlined below.
Measures to minimise the risks identified for medicinal products can be:
Specific Information, such as warnings, precautions, and advice on correct use, in the
package leaflet and SmPC addressed to patients and healthcare professionals;
The authorised pack size — the amount of medicine in a pack is chosen so to ensure
that the medicine is used correctly;
The medicine’s legal status — the way a medicine is supplied to the patient (e.g. with
or without prescription) can help to minimise its risks.
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In addition to these measures, information about adverse events is collected continuously and
regularly analysed, including PSUR assessment so that immediate action can be taken as
necessary. These measures constitute routine pharmacovigilance activities.
If important information that may affect the safe use of Comirnaty is not yet available, it is
listed under ‘missing information’ below.
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Table 34. Missing Information: Use in pregnancy and while breast feeding
Risk minimisation Routine risk minimisation measures:
measures SmPC section 4.6; PL section 2.
Additional risk minimisation measures:
No risk minimisation measures.
Additional Additional pharmacovigilance activities:
pharmacovigilance C4591010 a
activities C4591011 a
C4591015
ACCESS/VAC4EU
See section II.C of this summary for an overview of the post-authorisation
development plan.
a. Please note that studies C4591010, C4591011 and ACCESS/VAC4EU address only “Use in pregnancy”.
Table 36. Missing Information: Use in frail patients with co-morbidities (e.g.
chronic obstructive pulmonary disease (COPD), diabetes, chronic
neurological disease, cardiovascular disorders)
Risk minimisation Routine risk minimisation measures:
measures SmPC section 5.1.
Additional risk minimisation measures:
No risk minimisation measures.
Additional Additional pharmacovigilance activities:
pharmacovigilance C4591001 subset
activities C4591011
C4501012
ACCESS/VAC4EU
Safety and immunogenicity in high risk adults
See section II.C of this summary for an overview of the post-authorisation
development plan.
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Annex 3 – Protocols for proposed, on-going, and completed studies in the pharmacovigilance
plan
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Pfizer-BioNTech COVID-19 Vaccine Data Capture Aid
Race: White Black or African American Native American Alaska Native Native Hawaiian Asian Other
Refused or Don’t Know
Reporter Information
Name of reporter completing this form (If other than addressee, provide contact information below):
1st dose
2nd dose
Follow-up Questions
Please provide additional details on a separate page if needed and reference the question number.
1. Does the patient have a positive test for SARS-CoV2? 2. Does the patient have SARS-CoV2 antibodies at diagnosis?
Unknown No Yes If Yes, please provide details Unknown No Yes If Yes, please provide details
(and indicate if this is a new infection or a recurrence) Details: (Please specify date of test, whether IgM /IgG or both and the titer if
Details: (Please specify date of test and type of test – e.g., nasal available)
swab reverse transcription–polymerase chain reaction (RT-PCR) test
or nucleic acid amplification–based test (NAAT) or antigen test)
3. Was/Is the patient hospitalized? 4. Was/Is the patient admitted to an Intensive Care Unit?
Unknown No Yes If Yes, please provide details Unknown No Yes If Yes, please provide details (e.g.,
(e.g., duration of hospitalization) duration of hospitalization)
Details: Details:
5. Is the patient still hospitalized? 6. If discharged, did the patient have SARS-CoV2 antibodies
Unknown No Yes If Yes, please provide details at hospital discharge?
(e.g., duration of hospitalization) Unknown No Yes If Yes, please provide details
Details: Details: (Please specify date of test, whether IgM /IgG or both and the titer if
available)
7. Did the patient display clinical signs at rest indicative 8. Did the patient require supplemental oxygen (including
of severe systemic illness? high flow or ECMO) or receive mechanical ventilation?
Unknown No Yes If Yes, please provide details Unknown No Yes If Yes, please provide details (e.g.,
(e.g., Fever, RR ≥30 breaths per minute, HR ≥125 beats per minute, oxygen requirements, pulse oximetry results)
use of vasopressors to maintain BP, SpO2 ≤93% on room air, Details:
PaO2/FiO2 <300 mm Hg)?)
Details:
9. Please provide information on any new or worsened symptoms/signs during the COVID-19 illness experienced (including
date of onset/worsening)
Multiorgan failure Unknown No Yes If Yes, please indicate which organ systems were affected and provide
information on the applicable systems below
CONFIDENTIAL
Pfizer-BioNTech COVID-19 Vaccine Data Capture Aid
OTHER (e.g. multisystem inflammatory syndrome [MIS]) Unknown No Yes If Yes, please provide details
Details:
10. Did the patient receive any additional therapies for COVID-19?
Remdesivir
Hydroxychloroquine/chloroquine
Azithromycin
Corticosteroids
11. Did the event require the initiation of new medication or other treatment or procedure?
Unknown No Yes If Yes, please provide details
Details:
If outcome is fatal, was an autopsy performed? Unknown No Yes If Yes, please provide autopsy findings
Details:
13. How many days from the SARS-CoV2 diagnosis did it take before the SARS-CoV2 antigen test became negative?
14. Were any of the following laboratory tests or diagnostic studies performed? Please specify laboratory data with units, date
of test, and reference ranges; and please provide printouts and photographs if available:
Date Performed Reference Ranges, if applicable (or
Results with units, if
Laboratory Test or Diagnostic Studies please state if abnormal or
(dd-Mmm-yyyy) applicable
elevated/reduced)
Test for SARS-CoV-2 by PCR, or other
commercial or public health assay
Imaging for COVID-Pneumonia
(e.g.CXR, CT)
17. Was the patient taking any medications routinely prior to the event being reported?
Unknown No Yes If Yes, please provide details
Details:
18. Have any pre-existing diseases worsened during the SARS-CoV2 infection (please specify)
Unknown No Yes If Yes, please provide details
Details:
19. Has the patient been treated with immunomodulating or immunosuppressing medications or received any other vaccines
around the time of COVID-19 vaccination?
Unknown No Yes If Yes, please provide details
Details:
Revision History
Revision Effective Date Summary of Revisions
1.0 07-Dec-2020 New DCA