On December 11, the U.S. Food and Drug Administration (FDA) issued the first emergency use authorization (EUA) for a vaccine for the prevention of COVID-19 caused by SARS-CoV-2 in individuals aged 16 and older. The EUA allows the Pfizer-BioNTech COVID-19 vaccine to be distributed in the United States.
“The FDA’s authorization for emergency use of the first COVID-19 vaccine is a significant milestone in battling this devastating pandemic that has affected so many families in the United States and around the world,” said FDA Commissioner Stephen M. Hahn, MD. “[This] action follows an open and transparent review process that included input from independent scientific and public health experts and a thorough evaluation by the agency’s career scientists to ensure this vaccine met FDA’s rigorous, scientific standards for safety, effectiveness, and manufacturing quality needed to support EUA. The tireless work to develop a new vaccine to prevent this novel, serious, and life-threatening disease in an expedited timeframe after its emergence is a true testament to scientific innovation and public-private collaboration worldwide.”
Stephen M. Hahn, MD
The FDA has determined that the Pfizer-BioNTech COVID-19 vaccine has met the statutory criteria for issuance of an EUA. The totality of the available data provides clear evidence that the Pfizer-BioNTech COVID-19 vaccine may be effective in preventing COVID-19. The data also support that the known and potential benefits outweigh the known and potential risks, supporting the vaccine’s use in millions of people, including healthy individuals. In making this determination, the FDA can assure the public and medical community that it has conducted a thorough evaluation of the available safety, effectiveness, and manufacturing quality information.
The Pfizer-BioNTech COVID-19 vaccine contains messenger RNA (mRNA). The vaccine contains a small piece of the SARS-CoV-2 virus’s mRNA that instructs cells in the body to make the virus’s distinctive “spike” protein. When a person receives this vaccine, the body produces copies of the spike protein, which does not cause disease but triggers the immune system to learn to react defensively, producing an immune response against SARS-CoV-2.
“While not an FDA approval, today’s emergency use authorization of the Pfizer-BioNTech COVID-19 vaccine holds the promise to alter the course of this pandemic in the United States,” said Peter Marks, MD, PhD, Director of the FDA’s Center for Biologics Evaluation and Research. “With science guiding our decision-making, the available safety and effectiveness data support the authorization of the Pfizer-BioNTech COVID-19 vaccine because the vaccine’s known and potential benefits clearly outweigh its known and potential risks. The data provided by the sponsor have met the FDA’s expectations as conveyed in our June and October guidance documents. Efforts to speed vaccine development have not sacrificed scientific standards or the integrity of our vaccine evaluation process. The FDA’s review process also included public and independent review from members of the agency’s Vaccines and Related Biological Products Advisory Committee. [This] achievement is ultimately a testament to the commitment of our career scientists and physicians, who worked tirelessly to thoroughly evaluate the data and information for this vaccine.”
Peter Marks, MD, PhD
FDA Evaluation of Available Safety Data
The Pfizer BioNTech COVID-19 vaccine is administered as a series of two doses, 3 weeks apart. The available safety data to support the EUA include 37,586 of the participants enrolled in an ongoing randomized, placebo-controlled, international study, the majority of whom are U.S. participants. These participants—18,801 of whom received the vaccine and 18,785 of whom received saline placebo—were followed for a median of 2 months after receiving the second dose. The most commonly reported side effects, which typically lasted several days, were pain at the injection site, tiredness, headache, muscle pain, chills, joint pain, and fever. Of note, more people experienced these side effects after the second dose than after the first dose, so it is important for vaccination providers and recipients to expect there may be some side effects after either dose but even more so after the second dose.
It is mandatory for Pfizer Inc. and vaccination providers to report the following to the Vaccine Adverse Event Reporting System for the Pfizer-BioNTech COVID-19 vaccine:
- All vaccine administration errors
- Serious adverse events
- Cases of multisystem inflammatory syndrome
- Cases of COVID-19 that result in hospitalization or death.
FDA Evaluation of Available Effectiveness Data
The effectiveness data to support the EUA include an analysis of 36,523 participants in the ongoing randomized, placebo-controlled, international study, the majority of whom are U.S. participants, who did not have evidence of SARS-CoV-2 infection through 7 days after the second dose. Among these participants, 18,198 received the vaccine and 18,325 received a placebo. The vaccine was 95% effective in preventing COVID-19 disease among these clinical trial participants, with 8 COVID-19 cases in the vaccine group and 162 in the placebo group. Of these 170 COVID-19 cases, 1 in the vaccine group and 3 in the placebo group were classified as severe. At this time, data are not available to make a determination about how long the vaccine will provide protection, nor is there evidence that the vaccine prevents transmission of SARS-CoV-2 from person to person.
The EUA Process
On the basis of the determination by the Secretary of the Department of Health and Human Services on February 4, 2020, that there is a public health emergency with a significant potential to affect national security or the health and security of U.S. citizens living abroad, and then issued declarations that circumstances exist justifying the authorization of emergency use of unapproved products, the FDA may issue an EUA to allow unapproved medical products or unapproved uses of approved medical products to be used in an emergency to diagnose, treat, or prevent COVID-19 when there are no adequate, approved, and available alternatives.
The issuance of an EUA is different from an FDA approval (licensure) of a vaccine. In determining whether to issue an EUA for a product, the FDA evaluates the available evidence and assesses any known or potential risks and any known or potential benefits; if the benefit-risk assessment is favorable, the product is made available during the emergency. Once a manufacturer submits an EUA request for a COVID-19 vaccine to the FDA, the agency then evaluates the request and determines whether the relevant statutory criteria are met, taking into account the totality of the scientific evidence about the vaccine that is available to the FDA.
The EUA also requires that fact sheets provide important information—including dosing instructions and information about the benefits and risks of the Pfizer-BioNTech COVID-19 vaccine—be made available to vaccination providers and vaccine recipients.
The company has submitted a pharmacovigilance plan to FDA to monitor the safety of the Pfizer-BioNTech COVID-19 vaccine. The pharmacovigilance plan includes a plan to complete longer-term safety follow-up for participants enrolled in ongoing clinical trials. The pharmacovigilance plan also includes other activities aimed at monitoring the safety profile of the Pfizer-BioNTech COVID-19 vaccine and ensuring that any safety concerns are identified and evaluated in a timely manner.
The FDA also expects manufacturers whose COVID-19 vaccines are authorized under an EUA to continue their clinical trials to obtain additional safety and effectiveness information and pursue approval (licensure).
The EUA for the Pfizer-BioNTech COVID-19 vaccine was issued to Pfizer Inc. and will be effective until the declaration that circumstances exist justifying the authorization of the emergency use of drugs and biologics for prevention and treatment of COVID-19 is terminated. The EUA may be revised or revoked if it is determined that it no longer meets the statutory criteria for issuance.