Rakesh_20
☆    

India,
2015-01-22 11:26
(3374 d 07:26 ago)

Posting: # 14309
Views: 6,290
 

 Two-Stage Design with Fully replicate for CANADA? [Two-Stage / GS Designs]

Dear Sir,

I have following concern :
For Canadian submission, can we consider the Fully replicated crossover design with two-stage sequential approach for BE study? and how TPD will look at this?

Thanks and Regards,
Rakesh
ElMaestro
★★★

Denmark,
2015-01-22 11:56
(3374 d 06:56 ago)

@ Rakesh_20
Posting: # 14310
Views: 5,402
 

 Two-Stage Design with Fully replicate for Canada

Hi Rakesh,


I am not aware of anyone ever having done it. The theoretical framework is still missing, at least in the public domain, and this is probably because the computational requirements for the necessary simulations could be a serious bottleneck.

If you approach regulators and ask about it then I would be very happy to hear about the outcome :-D

Pass or fail!
ElMaestro
Helmut
★★★
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Vienna, Austria,
2015-01-22 13:37
(3374 d 05:15 ago)

@ Rakesh_20
Posting: # 14311
Views: 5,288
 

 RSABE/TSD-combo

Dear Madam,

why are you shouting at us?

❝ For Canadian submission, can we consider the Fully replicated crossover design with two-stage sequential approach for BE study?


ElMaestro correctly wrote above that no method is published yet. Note that currently HC does not accept refe­rence-scaling. In June 2014 the “Scientific Advisory Committee on Pharmaceutical Sciences and Cli­nical Pharmacology” recommended FDA’s method for implementation but is considering other approaches as well. Let’s see.
If you want to explore RSABE in a TSD with current hard-/software finding and validating an adjusted α would take ~six years. If you believe in Moore’s law (processing power doubles every 18–24 months) and you buy always the fastest available machine it would still take ~1½ years to get a result. Unless you find someone who is able to write some fancy C- or FORTRAN-code for a massive parallel super­computer (which will cost you a fortune) I don’t see a realistic way out.

If you want to run a fully replicate design for conventional ABE (no scaling) IMHO that should be doable. Start your own simulations.

❝ and how TPD will look at this?


With great interest. Report back their response.

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Rakesh_20
☆    

India,
2015-01-23 07:32
(3373 d 11:19 ago)

@ Helmut
Posting: # 14313
Views: 5,218
 

 Fully replicated-conventional ABE/TSD-combo

Dear Both,

Thank you so much for the reply.

❝ If you want to run a fully replicate design for conventional ABE (no scaling) IMHO that should be doable. Start your own simulations.


So, if we consider Fully replicated crossover design-conventional ABE with two-stage sequential approach for BE study then, is it acceptable to canadian submission?

Thanks and Regards,
Rakesh
Helmut
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Vienna, Austria,
2015-01-23 13:41
(3373 d 05:11 ago)

@ Rakesh_20
Posting: # 14316
Views: 5,207
 

 Simulations mandatory

Hi Rakesh,

❝ So, if we consider Fully replicated crossover design-conventional ABE with two-stage sequential approach for BE study then, is it acceptable to canadian submission?


Maybe we were not clear.
  • Nothing is stated in HC’s guidance, but: Alternate approaches to the principles and prac­tices described in this document may be acceptable provided they are supported by ade­quate justification. Alternate approaches should be discussed in advance with the rele­vant program area to avoid the possible finding that applicable statutory or regulatory require­ments have not been met.”
    (my emphases)
  • Since nothing is published, you have to set up Monte Carlo simulations for a matrix of poss­ible combinations of stage 1 sample sizes (n1) and CVs in order to find and validate a suit­able adjusted α (i.e., which maintains the overall type I error at 5%). Due to the slow con­ver­gence you have to simulate 106 BE-studies at a T/R-ratio of 1.25 (for α) and 105 at the ex­pected T/R-ratio (for power) for every combination of n1 and CV. Keep in mind that in a fully replicated design CVWR not necessarily equals CVWT.
Good luck.

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