Mikkabel
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Belgium,
2025-11-04 10:46
(211 d 13:45 ago)

Posting: # 24476
Views: 2,320
 

 ICHM13A/Multiple Test Product Studies [Regulatives / Guidelines]

Dear all,

We are planning to conduct a comparative pharmacokinetic (PK) study including two test products and one comparator.
According to Section 2.2.5.2 “Multiple Test Products” of ICH M13A, when the objective is to demonstrate bioequivalence (BE) for any of the test formulations, a multiplicity (alpha) adjustment may be required.

Further clarification on this topic is provided in the M13A Q&A document.
In our study, we intend to apply a hierarchical testing approach, considering that one of the formulations has shown more promising in-vitro results.
Specifically, our plan is to first assess BE between Formulation 1 and the comparator. If BE is demonstrated, we would then proceed to assess Formulation 2 versus the comparator.

Could you please confirm whether, under this hierarchical testing approach, an alpha adjustment is required, or if it can be omitted in accordance with the statement from the M13A Q&A:

“Formally, there is no need for multiplicity correction for each individual test, but the type I error (consumer risk) is still controlled.”

Thank you very much for your clarification.

Kind regards,
Mikkabel
Helmut
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Vienna, Austria,
2025-11-04 12:15
(211 d 12:17 ago)

@ Mikkabel
Posting: # 24477
Views: 1,972
 

 α-adjustments?

Hi Mikkabel,

❝ In our study, we intend to apply a hierarchical testing approach, considering that one of the formulations has shown more promising in-vitro results.

❝ Specifically, our plan is to first assess BE between Formulation 1 and the comparator. If BE is demonstrated, we would then proceed to assess Formulation 2 versus the comparator.

❝ Could you please confirm whether, under this hierarchical testing approach, an alpha adjustment is required, or if it can be omitted in accordance with the statement from the M13A Q&A:

❝ “Formally, there is no need for multiplicity correction for each individual test, but the type I error (consumer risk) is still controlled.”

You are right that in hierarchical testing you specify the order of tests in the SAP. Then the tests are performed with unadjusted α.
In your case test 1 = Formulation 1 vs comparator → test 2 = Formulation 2 vs comparator. Now it gets a bit tricky. In hierarchical testing:
  1. If you show BE with test 1, you continue to test 2 (where you may show BE or not).
  2. If you don’t show BE with test 1, you stop, i.e., are not allowed to perform the confirmatory test 2.
    You are only allowed to report the CI of test 2. Even if it would be within the limits, bad luck.
The latter case would be nasty.

Which alternatives do you have?
  • Bonferroni-adjustment of both tests (in your case with α/2). You can pursue approval of any of the passing tests.
  • Bonferroni-Holm. You consider the tests equally ‘important’. Test 1 is performed with α/2 and test 2 with α.
The influence of α on the sample size is overrated by many. I’m not convinced that the risk of failure in hierarchical testing is really worth the efforts:

library(PowerTOST)
CV      <- 0.20
theta0  <- 0.95
target  <- 0.80
alpha   <- 0.05
k       <- 2    # number of tests
alphas  <- alpha / (1:k)
example <- data.frame(alpha = alphas, n = NA_integer_, penalty = "")
for (j in seq_along(alphas)) {
  example[j, 2] <- sampleN.TOST(alpha = alphas[j], CV = CV, theta0 = theta0,
                                targetpower = target, design = "2x2x2",
                                print = FALSE)[["Sample size"]]
  if (j > 1) {
    example[j, 3] <- sprintf("%+.1f%%",
                             100 * ((example$n[j] / example$n[1]) - 1))
  }
}
example$alpha <- signif(example$alpha, 4) # cosmetics
print(example, row.names = FALSE)

 alpha  n penalty
 0.050 20     
 0.025 24  +20.0%



PS: Don’t perform a pooled ANOVA but evaluate the tests according to the ‘Two at a Time’ approach. Whichever α you prefer, in sample size estimation by the [image]-package PowerTOST specify design = "2x2x2" in the function sampleN.TOST().
Don’t specify design = "3x6x3" (Williams’ design) or design = "3x3" (Latin Squares).

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Helmut Schütz
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Mikkabel
☆    

Belgium,
2025-11-04 13:03
(211 d 11:29 ago)

@ Helmut
Posting: # 24478
Views: 1,927
 

 α-adjustments?

Thanks for the clarifications!
it confirms our interpretations of the guidance. Now, we are going to "brainstorm" and choose the best option (Hierarchical or adjustment) as indeed, the N is still acceptable with alpha/2.


Edit: Full quote removed. Please delete everything from the text of the original poster which is not necessary in understanding your answer; see also this post #5[Helmut]
BEQool
★    

2025-11-09 21:08
(206 d 03:24 ago)

@ Mikkabel
Posting: # 24481
Views: 1,878
 

 α-adjustments?

Hello all!

Has anyone ever used Holm-Bonferroni alpha adjustment method? I am wondering if any agency had any questions about it.

Additionally, has anyone ever used Hommel alpha adjustment method? Namely it is more powerful than Holm-Bonferroni method.


BEQool
Helmut
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Vienna, Austria,
2025-11-10 09:56
(205 d 14:35 ago)

@ BEQool
Posting: # 24482
Views: 1,812
 

 Beyond Bonferroni…

Hi BEQool,

❝ Has anyone ever used Holm-Bonferroni alpha adjustment method? I am wondering if any agency had any questions about it.

❝ Additionally, has anyone ever used Hommel alpha adjustment method? Namely it is more powerful than Holm-Bonferroni method.

Not me (none of them).
Maybe you are interested in the EMA workshop on multiplicity issues in clinical trials of 2012, esp. the presentation by Jiří Hofmann (Zentiva) and the discussion by Thomas Lang (AGES and at that time member of the BSWP).
If you have some stamina and really nothing better to do, watch the recording at the end of the page. I got the impression that anything beyond Bonferroni is not what regulators like. Given, 13 years ago.

Dif-tor heh smusma 🖖🏼 Довге життя Україна! [image]
Helmut Schütz
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