d_labes
★★★

Berlin, Germany,
2009-09-30 12:55
(5319 d 07:30 ago)

Posting: # 4273
Views: 4,012
 

 Regulatory french replicates [Regulatives / Guidelines]

Dear All,

dont know if this is the right category.

But here is my question, story:
We recently conducted a 2-sequence-4-period replicate study (sequences TRTR/RTRT) to show that the reference formulation is highly variable and therefore claim to use the broadened bioequivalence range of 75-133% for Cmax.
As you surely noticed this study was European. :yes:

The study was evaluated using the Proc MIXED code from Appendix E of the FDA guidance "Statistical approaches ..." 2001. Code for instance here.

So far so good. I thought.

Now we got a question from the French authority:
QUESTIONS

The company must supply the simple calculation of intra-individual variability (mean of individual experimental differences) based on experimental data, so that the results can be compared with model values obtained using the Drug2-replicate program.


Any body out there who knows to hell what they mean? Or has an idea?
Variability=mean? Simple calculation? Experimental differences? :confused:
Totally confused.

BTW: Drug2-replicate program is the name of a SAS project (couple of macros) implementing the Proc MIXED code as its heart.

Regards,

Detlew
yjlee168
★★★
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Kaohsiung, Taiwan,
2009-09-30 15:39
(5319 d 04:46 ago)

@ d_labes
Posting: # 4274
Views: 3,354
 

 Regulatory french replicates

Dear D. Labes,

Guess many other colleagues are looking for the answers of your QUESTION now. I don't know if I can really help here. But allow me to try first. :-)
To calculate intra-individual variabilities and means seems not a problem for the guy like you. Or see Hauschke D, et al., "Bioequivalence Studies in Drug Development - Methods and Applications", 2007, pp. 258-9.
Why did they ask these questions? I really don't know. ABE and intra-subject variability (Liu JP, 1991)? One thing for sure is that they must see something on the output from using Drug2-replicate program. That's why they may also want to know these output contents from your study. I guess that probably you have found the answer yourself now if you have run your data with drug2-replicate program. [BTW, where to get it? Is this drug2-replicate program (SAS macros) freely available?]

❝ The company must supply the simple calculation of intra-individual variability (mean of individual experimental differences) based on experimental data, so that the results can be compared with model values obtained using the Drug2-replicate program.


❝ Any body out there who knows to hell what they mean? Or has an idea? Variability=mean? Simple calculation? Experimental differences? :confused: Totally confused.


❝ BTW: Drug2-replicate program is the name of a SAS project (couple of macros) implementing the Proc MIXED code as its heart.


All the best,
-- Yung-jin Lee
bear v2.9.1:- created by Hsin-ya Lee & Yung-jin Lee
Kaohsiung, Taiwan https://www.pkpd168.com/bear
Download link (updated) -> here
d_labes
★★★

Berlin, Germany,
2009-09-30 18:48
(5319 d 01:37 ago)

@ yjlee168
Posting: # 4279
Views: 3,300
 

 Regulatory french replicates

Dear Yung-jin,

❝ Guess many other colleagues are looking for the answers of your QUESTION now. I don't know if I can really help here. But allow me to try first. :-)


Thanx.

❝ To calculate intra-individual variabilities and means seems not a problem for the guy like you.


Of course not :-P . One part of the output of the Proc MIXED code contains the intra-subject variabilities for Test and Reference and the between-subject variability also. They have therefore what they request.
But it seems they do not belief in the results of the REML estimates from that Proc MIXED
That's where my confusion comes from. And means make no sense within the category if intra-subject variance.

❝ Or see Hauschke D., et al., "Bioequivalence Studies in Drug Development - Methods and Applications", 2007, pp. 258-9.


Cannot find anything about intra-subject variabilities on that pages.

❝ [...] [BTW, where to get it? Is this drug2-replicate program (SAS macros) freely available?]



Sorry. But its the property of the company I am working in.

Regards,

Detlew
ElMaestro
★★★

Denmark,
2009-09-30 16:11
(5319 d 04:14 ago)

@ d_labes
Posting: # 4277
Views: 3,357
 

 Regulatory french replicates

Hi dlabes,

❝ Any body out there who knows to hell what they mean? Or has an idea? Variability=mean? Simple calculation? Experimental differences? :confused: Totally confused.


Separate tables with descriptive stats (mean, median, sd, min, max, sem) for:
T-T in TRTR and RTRT
R-R in TRTR and RTRT
...and then a table or the pooled stuff at the end.

EM.
d_labes
★★★

Berlin, Germany,
2009-10-01 10:45
(5318 d 09:40 ago)

@ ElMaestro
Posting: # 4280
Views: 3,413
 

 MoM or Dad

Old Sailor and Pirate!

❝ Separate tables with descriptive stats (mean, median, sd, min, max, sem) for:

❝ T-T in TRTR and RTRT

❝ R-R in TRTR and RTRT

❝ ...and then a table or the pooled stuff at the end.


Is it because an Old pirate always knows from where the wind blows?
Or had you also such a question in your career?

Thanks for acknowledging my own guess.
I must say my second thought.

First I guessed they would have a 'conventional' evaluation ignoring the replicate nature (same as for a 2x2 cross-over). But this seemed too silly.

Now I will go with intra-individual variability calculated from the contrasts T-T or R-R. This is sometimes called "Method of moments" (MoM) I think.
But looking on the formulas in Chapter 9.4 of Chow, Liu "Design and analysis of bioavailability and bioequivalence studies" I cannot see why they call this simple :no:.
All the stuff in calculation stratified over sequence groups to account for the different period effects in the contrasts ... My implementation in SAS is currently getting longer and longer compared to the approximate 6-8 lines with Proc MIXED.

And if our guess is what the assessor wants to see the question remains why.
The MoM estimation is only another estimation method with its pros and cons.
Just to cite Patterson and Jones1): "Variance estimates are of less concern in ABE testing, but in alternative criteria where estimates are important to interpretation (i.e., for IBE and PBE) method-of-moments estimates should be viewed cautiously. Method-of-moment estimation, as expected, yields unbiased estimates in complete data sets, but results in positively biased sigma2D in some sample with missing data. Bias in method-of-moment sigma2D (with certain patterns of missing data) and constrained REML procedures increases as drugs become more highly variable and decreases with increasing sample size..."
(sigma2D is the subject by treatment interaction term)

Is the Proc MIXED result with REML estimates to complicated to understand?
Or why do they not trust them?
Or is it because the French do not love Americans?
Of course I know that one cannot ask why an regulator has a question. :angry:
But maybe I overlooked something here.

BTW: Why did you suggest all the summary statistics above? The only relevant is the variance I think, because it is well known that T-T or R-R have the expectation 2*sigma2within for test or reference.

1) Patterson, Jones
"Replicated Designs and Average, Individual, and Population Bioequivalence"
GlaxoSmithKline BDS Technical Report 2002-05, 11 December 2002, page 55



Edit: Online resource added. [Helmut]

Regards,

Detlew
ElMaestro
★★★

Denmark,
2009-10-01 13:40
(5318 d 06:45 ago)

@ d_labes
Posting: # 4282
Views: 3,268
 

 I am guessing, too!

Dear dlabes,

❝ Is it because an Old pirate always knows from where the wind blows?

❝ Or had you also such a question in your career?


If you put an old sock into someones mouth, he or she won't say much. In this case I just try to imagine from the wording you gave above what type of sock would fit.

❝ Is the Proc MIXED result with REML estimates to complicated to understand?


Yes, honestly, the process goes via maximizing the likelihood of a totally osbcure multi-matrix expression. So if the process if complicated, why shoudn't the result be? Bear in mind, the assessor might not even be a statistician, but a lowly paid slave (biologist, pharmacist, etc) who is trying to impress his or her boss by asking questions that indicate a profound understanding of everything.

❝ Or why do they not trust them?

❝ Or is it because the French do not love Americans?


Airbus vs. Boeing. And they started to make their own wine over there, so less Bourgogne is being exported. As a counter-measure the French have stopped paying for their meals at McDonalds*.

❝ BTW: Why did you suggest all the summary statistics above? The only relevant is the variance I think, because it is well known that T-T or R-R have the expectation 2*sigma2within for test or reference.


You gave the wording from the assessor's question above. (S)he did not mention variance, but variability, so even though I agree that sigma or variance is most relevant here this might not itself cover variability. It is a matter of making the sock large enough.

EM.
d_labes
★★★

Berlin, Germany,
2009-10-01 14:43
(5318 d 05:42 ago)

@ ElMaestro
Posting: # 4283
Views: 3,265
 

 Old socks

Dear ElMaestro,

❝ If you put an old sock into someones mouth, he or she won't say much.


[image]

I will report if the sock fits if we get a response from the french authority.

Regards,

Detlew
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