inter-batch variability? [Regulatives / Guidelines]

posted by d_labes  – Berlin, Germany, 2010-08-04 11:58 (3965 d 00:00 ago) – Posting: # 5715
Views: 13,649

Dear Dan!

» Study 1: 111/116
» Study 2: 84/95
» Study 3: 111/114
» Study 4: 98/97
» The assessor concludes that these different point estimators hint at inter batch variability of the test product [color:red](why not the reference?)/color:red] and therefore a marketing authorisation can not be granted.
(emphasis by me)

:not really:
I never heard about a regulatory criterion requesting that the point estimators between BE studies must not varying. And that you must express articulately against the regulatory body.
I would wonder if there is no variability!

As you have told: the pivotal studies have shown bioequivalence. IMHO that was it. All other concerns are negligible (if not safety is concerned).

More over the assessors judgment is logical flawed:
Considering Study 1/Study 3 with the same reference 1 (batch?), neglecting the fact that study 1 is pilot and therefore not suitable for a reliable point estimator, there is no substantial difference in the point estimators although test 1 and test 2 (batches?) are used.
Since the other 2 studies use different test/reference (batches?) one cannot use them to judge. If judgment of inter-batch variability is ever possible from BE studies which I highly question.

But to cite myself: "Regulators ways are inscrutable!"

Eventually you can argue using not the point estimators but the mean/geometric mean values of the PK metrics themselves. Hopefully they show greater variability between the reference batches.
But IMHO this is clearly nonsense.



Complete thread:

 Admin contact
21,518 posts in 4,498 threads, 1,523 registered users;
online 20 (0 registered, 20 guests [including 8 identified bots]).
Forum time: Saturday 11:58 UTC (Europe/Vienna)

If I find 10,000 ways something won’t work, I haven’t failed.
I am not discouraged, because every wrong attempt discarded
is another step forward.    Thomas Alva Edison

The Bioequivalence and Bioavailability Forum is hosted by
BEBAC Ing. Helmut Schütz