Compliance ★ India, 2015-10-14 14:54 (3450 d 02:57 ago) Posting: # 15559 Views: 8,160 |
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Dear All, Does FDA raise any concern if we get around 20 to 25% positive pre-dose concentration in subsequent period of the study? Please note that the product is long acting depot injection and wash out duration fixed based on the data available on FDA site under SBOA for reference product. Please share your advice/ comment in this regard. Regards, Compliance |
Helmut ★★★ ![]() ![]() Vienna, Austria, 2015-10-14 16:44 (3450 d 01:07 ago) @ Compliance Posting: # 15561 Views: 6,997 |
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![]() ❝ Does FDA raise any concern … I don’t have a crystal ball. Substitute “does the FDA” by “will the FDA likely”. ❝ … if we get around 20 to 25% positive pre-dose concentration in subsequent period of the study? I don’t think so. See the current NDA-draft (Section Subjects with predose plasma drug concentrations): If the predose concentration is ≤ 5 percent of Cmax value in a subject with predose plasma concentration, you can include the subject’s data without any adjustments in all pharmacokinetic measurements and calculations. We recommend that if the predose value is greater than 5 percent of Cmax, you drop the subject from all BE study evaluations. If you exclude subjects you decrease the chance to demonstrate BE (= increase the producer’s risk). The patient’s risk (Type I Error) is of regulatory concern – not the Type II Error (β = 1 – π). If you are able to show BE despite the lower sample size, fine.The loss in power is not substantial in most cases:
❝ […] wash out duration fixed based on the data available on FDA site under SBOA for reference product. In the worst case the FDA might ask why you didn’t perform a pilot study. If the applicant chooses, a pilot study in a small number of subjects can be carried out before proceeding with a full BE study. This pilot study can be used to validate analytical methodology, assess variability, optimize sample collection time intervals, and provide other information. But that’s not mandatory. A depot injection, well… IMHO, the reference product’s data are sufficient to justify the chosen design.— 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, 2015-10-15 00:37 (3449 d 17:14 ago) @ Compliance Posting: # 15563 Views: 6,891 |
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Hi compliance, ❝ Does FDA raise any concern if we get around 20 to 25% positive pre-dose concentration in subsequent period of the study? Please note that the product is long acting depot injection and wash out duration fixed based on the data available on FDA site under SBOA for reference product. As I see it you would never plan for 20%-25% having predose concentrations. You would plan to avoid it. Therefore, in such a study one might argue that planning had gone not just wrong but badly wrong. This would perhaps not affect the conclusion of BE in the study in question, but one could argue that initiating studies where 20%-25% of subjects are futilely exposed to IMP is an ethical concern. Under some circumstances it could be an inspection trigger. Send some more info. How did your average apparent Kel look in comparison with SPC /prescr. info? Did you find some other useful explanations yourself? — Pass or fail! ElMaestro |
Compliance ★ India, 2015-10-15 09:36 (3449 d 08:15 ago) @ ElMaestro Posting: # 15564 Views: 6,788 |
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Dear Helmut & Elmaestro, Thank you very much for sharing your concern. Expiry of reference product is only one year and we are planning to conduct 3-WSABE study due to high variability. Due to this we could not keep long wash out period. however we are taking chance that if pre dose >5 % would be higher then it would not been considered for the BE. We performed one pilot study and my question comes from that study only. In which we got total 13 subject out of 48 with positive pre dose. Out of 13, 09 subject has shown > 5% pre dose concentration. Regards, Compliance |
Helmut ★★★ ![]() ![]() Vienna, Austria, 2015-10-15 15:45 (3449 d 02:06 ago) @ Compliance Posting: # 15565 Views: 6,978 |
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Hi Compliance, ❝ Expiry of reference product is only one year and we are planning to conduct 3-WSABE study due to high variability. Due to this we could not keep long wash out period. OK, since you are limited by the shelf life of the reference I assume that the FDA would still expect you to plan the washouts as long as possible. ❝ however we are taking chance that if pre dose >5 % would be higher then it would not been considered for the BE. Nitpicking: ≥5%, not >5%. State conditions for exclusion unambiguously in the protocol. You shouldn’t worry about loosing power due to excluded subjects. Example for GMR 0.9 (conservative, since highly variable!), CV 60%, target power 90%, minimum power 80%, partial replicate design, FDA’s RSABE:
gives Sample size plan scABE (FDA/RSABE) If you perform the study in 57 subjects, you may loose (dropouts) and/or exclude (predose ≥5% Cmax) 26 (45%!) and still achieve 80% power. ❝ We performed one pilot study […] In which we got total 13 subject out of 48 with positive pre dose. Out of 13, 09 subject has shown > 5% pre dose concentration. OK, that’s ~20%. Following ElMaestro’s question: Did you see any differences between T and R – especially in λz? For such a formulation λz represents absorption… Or the other way ’round: Was there a substantial difference in the PEs of AUCt and AUC∞? If yes, you should consider to sample longer. — 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 |