Final version published [Regulatives / Guidelines]

posted by ElMaestro  – Denmark, 2010-01-29 18:02 (5619 d 23:28 ago) – Posting: # 4660
Views: 25,340

Bong Sure,

4.1.8 (Stats):

"The assessment of bioequivalence is based upon 90% confidence intervals for the ratio of the population geometric means (test/reference) for the parameters under consideration."
Population geometric means.. I am sure they will continue to mean LS Means although this is not what that sentence means. Business as usual.

"The terms to be used in the ANOVA model are usually sequence, subject within sequence, period and formulation. Fixed effects, rather than random effects, should be used for all terms."
Implies no more mixed effect modeling? Now, if we do a normal linear model on data from a replicated study then we are certain to violate some basic requirements (correlated errors; those that the Mixed Model intends to solve for us). That also implies that we will not be able to give unbiased or good estimates of the intra-subject variability. In 4.1.10 (HVD's):
"The applicant should justify that the calculated intra-subject variability is a reliable estimate and that it is not the result of outliers."
The wording leaves anybody doing a replicated study in a dilemma. Either use a mixed model and violate 4.1.8 but get healthy withins, or using a fixed effects model as required and get toxic withins.

Next issue of course, is that if we comply with "Fixed effects, rather than random effects, should be used for all terms." then there will NOT be individual withins for Ref (or Test). The recommendation of using swr for scaling purposes does not make sense as long as no mixed effecs model is allowed.

I will stop here, but let me just quote John McEnroe:
"You cannot be serious!"

EM.

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