Jay
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India,
2013-09-16 17:39
(4663 d 21:03 ago)

Posting: # 11499
Views: 4,491
 

 EMA MR Draft Guidelines Application [Regulatives / Guidelines]

Hi,

As we know the draft guidelines have been published for modified release dosage forms but its not finalised.

So if one conducts BE study for modified release now so they have to follow current guidelines for BE Study of EMA? If Yes then suppose the draft guidelines get finalised before submission, then will it raise query?

Otherwise can we add statement in the protocol regarding that?

As per current guideline, in SD Cmax & AUCt as primary while in MD, Cminss, Cmaxss and AUCtau as primary.

Shall one add pAUC in secondary parameter considering the draft guidelines? Kindly guide.
jag009
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NJ,
2013-09-16 19:30
(4663 d 19:13 ago)

@ Jay
Posting: # 11501
Views: 3,837
 

 EMA MR Draft Guidelines Application

Hi,

I don't know how EMA run their business. For FDA we always go with the draft guidance even though it's not finalized because
  1. many of the FDA guidances are STILL in draft mode/take forever to finalize
  2. draft and finalized do not deviate much (heck you can always make alternative suggestion and try to convince the agency).
John
Helmut
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Vienna, Austria,
2013-09-17 15:35
(4662 d 23:08 ago)

@ Jay
Posting: # 11504
Views: 3,800
 

 EMA MR Draft Guidelines Application

Hi Jay,

❝ […] If Yes then suppose the draft guidelines get finalised before submission, then will it raise query?


(1) Yes and (2) maybe.

❝ Otherwise can we add statement in the protocol regarding that?


Sure. The more you deviate from the current NfG, the more complicated it gets.

❝ As per current guideline, in SD Cmax & AUCt as primary while in MD, Cminss, Cmaxss and AUCtau as primary.


❝ Shall one add pAUC in secondary parameter considering the draft guidelines?


Why not? The problems start with the truncation time point (which has to be prespecified). I guess I will not have been the only one objecting against τ/2. The first pAUC might be highly variable (though widening of the acceptance range might be possible if the study was performed in a replicate design). If in doubt, go for a scientific advice.

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Jay
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India,
2013-12-23 12:00
(4566 d 01:42 ago)

@ Helmut
Posting: # 12095
Views: 3,354
 

 EMA MR Draft Guidelines Application

Dear John and Helmut,

Thank you for your reply.

❝ Why not? The problems start with the truncation time point (which has to be prespecified). I guess I will not have been the only one objecting against τ/2. The first pAUC might be highly variable (though widening of the acceptance range might be possible if the study was performed in a replicate design). If in doubt, go for a scientific advice.


Any idea about which truncation point to be considered for pAUC?

As pAUC is considered to be more variable as compared to Cmax and AUC. Thus should Sample Size be considered accourdingly? And if it is to be considered more subjects may be required. And for pAUC which literature should we consider for calculation of Sample Size?

Regards,
Jay
Helmut
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Vienna, Austria,
2013-12-23 14:54
(4565 d 22:49 ago)

@ Jay
Posting: # 12096
Views: 3,407
 

 EMA MR Draft Guidelines Application

Hi Jay,

❝ Any idea about which truncation point to be considered for pAUC?


Until the GL gets finalized, we are fishing in foul water. The FDA clearly prefers a clinical justification (based on PD), whereas the EMA seems to prefer PK. However, in my studies I succeeded with the former. As said before, go for a [e]scientific[/e] regulatory advice. Carry clinical data as ammunition with you. Don’t simply ask them. One company doing so went back home from London with AUC0–2 for methlyphenidate in their backpack. :crying:

❝ As pAUC is considered to be more variable as compared to Cmax and AUC.


Likely.

❝ Thus should Sample Size be considered accourdingly?


Sure. You have to show BE for pAUC as well.

❝ […] more subjects may be required.


Yes.

❝ […] for pAUC which literature should we consider for calculation of Sample Size?


The only published data on pAUCs are for methlyphenidate and zolpidem. I’m afraid you have to perform a pilot study – if you assume high variability, in a replicate design.

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Jay
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India,
2013-12-23 15:54
(4565 d 21:48 ago)

@ Helmut
Posting: # 12098
Views: 3,352
 

 EMA MR Draft Guidelines Application

Thanks Helmut for the reply.

Hope the Guideline gets published soon and provides clarity for truncation point of pAUC. If we conduct BE as per draft MR GL, can we submit it even if new MR GL is still in draft?
Helmut
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Vienna, Austria,
2013-12-23 16:41
(4565 d 21:01 ago)

@ Jay
Posting: # 12099
Views: 3,355
 

 Science first!

Hi Jay,

❝ Hope the Guideline gets published soon and provides clarity for truncation point of pAUC.


I expect only a general statement in the MR GL. Maybe we will see particular truncation time-points in the product-specific guidances. However, never follow GLs unreflected.

  Science should always be the basis
of regulatory requirements.
Joachim Röhmel

   Recipe for success:
Treat guidelines like variable constants.
ElMaestro

   Guidelines
are guidelines
are guidelines.
Henrike Potthast


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