R, packages (e.g. PowerTOST) and regulatory issues (e.g.FDA) [🇷 for BE/BA]

posted by ElMaestro  – Denmark, 2013-03-20 09:11 (4848 d 07:29 ago) – Posting: # 10241
Views: 14,389

Hello Jérôme,

❝ I’m preparing a clinical ANDA BE study for the company I work with and for that purpose I’m using R and the package PowerTOST (I’m computing power and sample size and also I use CVfromCI and CVpooled). I plan to perform both the statistical analysis plan (SAP) and the data analysis.


❝ I’m aware that FDA made recent clear statement about statistical software, but it’s to have your opinions and feedback.


Power is usually the applicant's problem so I woudln't expect FDA to reject any dossier just because power has been calculated with a package that the FDA finds dubious. This is of course not to say that the powerTOST package is dubious; in fact this package is anything but.
Unless the package you use may calculate sample size so wrongly that a study is futile (unethical) there should not be too much trouble.

For evaluation of BE in R you need e.g. Yung-Jin Lee's excellent BEAR or some codelines of your own making and then the issue becomes more important. On basis of FDA's message I would say you can certainly validate an R script and use that.

Pass or fail!
ElMaestro

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