Helmut ★★★ ![]() ![]() Vienna, Austria, 2015-08-16 15:27 (3508 d 23:33 ago) Posting: # 15273 Views: 6,750 |
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Dear all, can somebody enlighten me? The EMA’s BE-GL states:
— Dif-tor heh smusma 🖖🏼 Довге життя Україна! ![]() Helmut Schütz ![]() The quality of responses received is directly proportional to the quality of the question asked. 🚮 Science Quotes |
ElMaestro ★★★ Denmark, 2015-08-16 21:00 (3508 d 18:00 ago) @ Helmut Posting: # 15274 Views: 5,605 |
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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 ★★★ ![]() ![]() Vienna, Austria, 2015-08-17 01:02 (3508 d 13:57 ago) @ ElMaestro Posting: # 15275 Views: 5,588 |
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Hi ElMaestro, THX for your explanation (especially the lucid last sentence). ![]() 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:
— Dif-tor heh smusma 🖖🏼 Довге життя Україна! ![]() Helmut Schütz ![]() The quality of responses received is directly proportional to the quality of the question asked. 🚮 Science Quotes |
d_labes ★★★ Berlin, Germany, 2015-08-17 11:31 (3508 d 03:29 ago) @ Helmut Posting: # 15278 Views: 5,463 |
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Dear Helmut, hi ElMaestro, ❝ THX for your explanation (especially the lucid last sentence). THX from me too ![]() ❝ 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 ★★★ ![]() ![]() Vienna, Austria, 2015-08-17 17:02 (3507 d 21:57 ago) @ d_labes Posting: # 15284 Views: 5,486 |
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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. — Dif-tor heh smusma 🖖🏼 Довге життя Україна! ![]() Helmut Schütz ![]() The quality of responses received is directly proportional to the quality of the question asked. 🚮 Science Quotes |