Helmut
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Vienna, Austria,
2015-08-16 15:27
(3508 d 23:33 ago)

Posting: # 15273
Views: 6,750
 

 EMA HVD/HVDPs [Design Issues]

Dear all,

can somebody enlighten me? The EMA’s BE-GL states:
  • 4.1.1 Study design / Alternative designs
    […] alternative well-established designs could be considered such as […] replicate designs e.g. for substances with highly variable pharmacokinetic characteristics (see section 4.1.10).
  • 4.1.3 Subjects / Number of subjects
    The number of subjects to be included in the study should be based on an appropriate sample size calculation.
  • 4.1.10 Highly variable drugs or drug products
    If an applicant suspects that a drug product can be considered as highly variable in its rate and/or extent of absorption, a replicate cross-over design study can be carried out.
What does that mean? If neither the CV of Cmax or of AUC is expected to be >30% a replicate design cannot be carried out?

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ElMaestro
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Denmark,
2015-08-16 21:00
(3508 d 18:00 ago)

@ Helmut
Posting: # 15274
Views: 5,605
 

 EMA HVD/HVDPs

Hi Hötzi,

what they really meant was:

4.1.10 Highly variable drugs or drug products
If an applicant thinks there is a realistic risk that rate of absorprion is associated with an intra-subject CV above 30%, regulators may forgive an applicant for using a replicate design for prospective scaling purposes. The regulators will at all times, however, reserve the right to send deficiency letters remarking on any other aspect of trial design, conduct and results, and may depending on their mood on the day use abusive, humiliating and degrading language towards the applicant.

Pass or fail!
ElMaestro
Helmut
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Vienna, Austria,
2015-08-17 01:02
(3508 d 13:57 ago)

@ ElMaestro
Posting: # 15275
Views: 5,588
 

 An applicant suspects…

Hi ElMaestro,

THX for your explanation (especially the lucid last sentence). :pirate:

I was puzzled by the “appropriate sample size calculation” [sic] in 4.1.3. If there are no safety issues I don’t see a reason why not any Xover BE study could be performed in a replicate design.1 Sometimes the clinical capacity might come into play.2
Example: The “best guess” CV is 0.25. You are not sure. You have seen one study with a CV of 0.35. You want to play it safe with the GMR and assume 0.9. The CRO houses 32 beds. Given all that, you opt for a 4-period full replicate. If the CV turns out to be correct, chances for reference-scaling are not very high. But, who knows?
My question: Is a CV of 0.25 “close enough” to the magic 0.30 which would justify a replicate design + optional scaling (GL: “applicant suspects that…”) or do you have to stick to a 2×2 (GL: “If two for­mu­lations are compared, a randomised, two-period, two-sequence single dose crossover design is re­com­mended.”)? That would mean 56 subjects compared to 28 in the replicate design (equal number of ad­mi­nis­trations, similar study costs). Stupid enough the former is beyond the capacity of the CRO. Two groups, etc. etc.
Try:

library(PowerTOST)
CV     <- seq(0.2, 0.4, 0.01)
CV.exp <- 0.25
GMR    <- 0.90
cap    <- 32
des    <- "2x2x4"
n1     <- vector("numeric", length=length(CV))
n2     <- n1
n3     <- n1
for (j in seq_along(CV)) {
  n1[j] <- sampleN.TOST(CV=CV[j], theta0=GMR, design="2x2x2",
    print=F)[["Sample size"]]
  n2[j] <- sampleN.TOST(CV=CV[j], theta0=GMR, design=des,
    print=F)[["Sample size"]]
  n3[j] <- sampleN.scABEL(CV=CV[j], theta0=GMR, design=des,
    print=F, details=F)[["Sample size"]]
}
plot(CV, n1, pch=0, col="red", ylim=c(12, max(c(n1, n2, n3))),
  ylab="sample size", las=1)
points(CV, n2, pch=2, col="black")
points(CV, n3, pch=6, col="blue")
abline(v=0.3, col="red", lty=1)
abline(v=CV.exp, col="blue", lty=3)
abline(h=12, col="red", lty=1)
abline(h=cap, lty=3)
legend("topleft", pch=c(0, 2, 6), col=c("red", "black", "blue"),
  legend=c("2x2x2: ABE", paste(des, "ABE"), paste(des, "ABEL")))



  1. Alfredo told me (in Bonn, 2013): “IMHO, all BE studies should be performed in a 4-period full replicate design. From a statistical perspective replicate designs are superior to two-way cross­overs.”
    Could not agree more.
  2. Anyone can run a computer program to calculate how many subjects are needed for a BE study. […]
    The first question one should ask Clinical in designing a bioequivalence trial is, ‘How many formu­la­tions and doses need to be involved?’ The next question to ask Clinical is, ‘How many beds does the clinical have, and how many subjects can be scheduled?’ (also known as, ‘How many spots are avail­able?’).

       Scott Patterson and Byron Jones
       Bioequivalence and Statistics in Clinical Pharmacology
       Boca Raton 2006. Chapman & Hall / CRC. pp160–1

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d_labes
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Berlin, Germany,
2015-08-17 11:31
(3508 d 03:29 ago)

@ Helmut
Posting: # 15278
Views: 5,463
 

 Paranoia?

Dear Helmut, hi ElMaestro,

❝ THX for your explanation (especially the lucid last sentence). :pirate:


THX from me too :cool:.

❝ I was puzzled by the “appropriate sample size calculation” [sic] in 4.1.3. If there are no safety issues I don’t see a reason why not any Xover BE study could be performed in a replicate design.1 Sometimes the clinical capacity might come into play.2


Beside the statement of our Capt'n I see also no reason why not.

IMHO "... replicate designs e.g. for substances with highly variable pharmacokinetic characteristics ..." doesn't mean only for that example. And if even the Spanish agreed - why to worry? Paranoia after all the bizarrness or curiosities known from regulatory bodies like this last one?

With the advent of PowerTOST every body has the ability to do an "appropriate sample size estimation (!)" for nearly all designs imaginable in BE studies. Thus choose the design which best fit your needs and go on. You can't protect yourself against regulatory curiosities.

Regards,

Detlew
Helmut
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Vienna, Austria,
2015-08-17 17:02
(3507 d 21:57 ago)

@ d_labes
Posting: # 15284
Views: 5,486
 

 Blindness!

Dear Detlew,

❝ IMHO "... replicate designs e.g. for substances with highly variable pharmacokinetic characteristics ..." doesn't mean only for that example. And if even the Spanish agreed - why to worry? Paranoia after all the bizarrness or curiosities known from regulatory bodies like this last one?


Oh, I overlooked these two little letters. THX for making it clear to me.

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