Regulatory Query for study repeat [Study As­sess­ment]

posted by luvblooms  – India, 2013-07-30 10:28 (4304 d 09:50 ago) – Posting: # 11122
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Dear Sam,

A few more thngs to look at from formulation point of view

❝ ❝ 2. Was there a change in the formulation or process? From pilot batch to scale-up batch...

There was no change in the formulation or process.


Well, how about
  1. the changes in API particle size? Was the PSD range too wide and both the lots (pilot and pivotal). Normally particle size changes doesnt give major difference in FED condition as drug stays in stomach for longer time and have sufficient fat to get solubilized but these changes are prominent in Fasting condition.
  2. Different form of API?: were the form (polymorphic/amorphous) remains same from pilot to pivotal?
  3. Different lot of API?Again to the first point are there any change in lots of API?
  4. Changes in Inactive ingredient grade or quality? Was there any change in amount or grade of any inactive ingerdient that may affect the release from the product. Some very commomly used excipients behave wildly within different grades.

❝ ❝ 3. Have you checked the PK data in details, both pilot and pivotal.

I have checked the Pilot and Pivotal data thoroughly.


Any differences observed in Tmax or shape of C-t curve? That could give you an idea why the product behave was different.

❝ ❝ 4. Any difference in study population between studies?

The study populations are totally different. Pilot are carried out in other CRO and Pivotal in other


How about the meal compositions? Were they remain the same? In India the food varies a lot between Chennai and Ahmedabad and so thus the performance of the formulations (this is based on my experience of some IR and XR products). Get a hold of that too along with the demographic data. Even that might give you some idea. :cool:


Hope this will help..

~A happy Soul~

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