Cmin really gone? tmax reappeared? [Regulatives / Guidelines]

posted by d_labes  – Berlin, Germany, 2010-02-01 15:02 (5974 d 03:19 ago) – Posting: # 4680
Views: 27,830

Dear Helmut,

❝ tmax is back (instead of partial AUC truncated at tmax,ref) - but no statistical analysis ("no apparent difference in median tmax and its variability").


What ever this means :surprised:! tmax reappeared as toothless tiger. Report the values, give some descriptive statistics and forget.

I find it very strange that the abhorrence for non-parametric methods leads to such a featureless evaluation guidance, even in the case tmax is clinically relevant.
Implicitly this accepts that tmax can only be analyzed non-parametrically, but "... Non-parametric analysis is not acceptable. ...". Thus we have no statistical method left.

❝ Css,min has vanished.


I liked this, because as we know this is a nasty parameter with sometimes high variability. Likewise it seemed fluctuation (PTF) had also gone.

But I noticed yet this is only true for immediate release products.

The CPMP/EWP/280/96 Corr "Note for Guidance on Modified Release Oral and Transdermal Dosage Forms: SECTION II (Pharmacokinetic and Clinical Evaluation)" mentions explicitly Fluctuation and Cmin in section 4.1.1. Rate and extent of absorption, fluctuation as parameters of interest in multiple dose studies.

Thus we have the situation that we need distinct sets of PK parameters for multiple dose studies depending on the product characteristics immediate or modified release. The question is: Why?

What is now really gone I think is MRT. Ok, this was only an parameter nice to have. Only reported and handled descriptively in BE studies.

Regards,

Detlew

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