Sutan Wu PhD FDACDER 5202014 1 Outlines Background of Dissolution Profile Comparisons C urrent Methods for Dissolution Profile Comparisons Current Statistical Concerns Simulation Cases ID: 269249
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Slide1
Current Statistical Issues in Dissolution Profile Comparisons
Sutan Wu, Ph.D.FDA/CDER5/20/2014
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Outlines:
Background of Dissolution Profile ComparisonsC
urrent Methods for Dissolution Profile Comparisons
Current Statistical ConcernsSimulation CasesDiscussions
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Disclaimer:The presented work and views in this talk represents the presenter’s personal work and views, and do not reflect any views or policy with CDER/FDA.Slide4
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Dissolution profile comparison: why so important?
Extensive applications throughout the product development process
Comparison between batches of pre-change and post-change under certain post-change conditions e.g.: add a lower strength, formulation change, manufacturing site
change
Generic Drug Evaluations
FDA Guidance:
Dissolution, SUPAC-SS
, SUPAC-IR, IVIV and etc.
Backgrounds:Slide5
5
Recorded
at multiple time
pointsAt least 12 tablets at each selected time point is recommendedProfile curves are drug-dependent
e.g
: Immediate release vs. extend
release
Response: cumulative percentage in dissolution
Dissolution DataSlide6
Model-Independent Approaches
Similarity factor
(FDA Dissolution Guidance):
Multivariate Confidence Region
Procedure ---
Mahalanobis
Distance:
,
Model-Dependent Approaches:
Select the most appropriate model such as
logit
,
Weibull
to fit the dissolution data
Compare the statistical distance among the model parameters
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Current Methods for Dissolution Profile ComparisonsSlide7
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Methods
Pros
Cons
Comments
Similarity factor
Simple to compute
Clear Cut-off Point: 50
Only the mean dissolution profile to
be considered;
At
least 3
same time point measurements for the test and
reference batch;Only one measurement should be considered after 85% dissolution of both products;%CV <=20% at the earlier time points and <=10% at other time points.Approximatelyover 95% applications Bootstrapping f2 is used for data with large variabilityMahalanobis
Distance
Both the mean profile and the batch
variability to be considered together
Simple stat formula
Same time point measurements for the test and
reference batches;Cut-off point not proposedA few applications Hard to have a common acceptable cut-off pointModel-dependent ApproachMeasurements at different time pointsModel selectionCut-off point not proposedSome internal lab studies
MethodsProsConsCommentsSimple to computeClear Cut-off Point: 50Only the mean dissolution profile to be considered;At least 3 same time point measurements for the test and reference batch;Only one measurement should be considered after 85% dissolution of both products;%CV <=20% at the earlier time points and <=10% at other time points.Approximatelyover 95% applications Bootstrapping f2 is used for data with large variabilityMahalanobis DistanceBoth the mean profile and the batch variability to be considered togetherSimple stat formula Same time point measurements for the test and reference batches;Cut-off point not proposedA few applications Hard to have a common acceptable cut-off pointModel-dependent ApproachMeasurements at different time pointsModel selectionCut-off point not proposedSome internal lab studiesSlide8
8
Some Review Lessions:
Large variability was observed in some applications and the conclusions based on similarity factor f2 were in doubt.
Bootstrapping f2 was applied to re-evaluate the applications. Different conclusions were observed.Slide9
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How to cooperate the variability consideration into dissolution profile comparison in a feasible and practical way?
Bootstrapping f2:
Lower bound of the non-parametric bootstrapping confidence interval (90%) for
f2
index
50 could be the cut-off point Subsequent Concerns: The validity of bootstrapping f2?
Mahalanobis
-Distance (M-Distance):
A classical multivariate analysis tool for describing the distance between two vectors and
widely used for outlier
detectionUpper Bound of the 90% 2-sided confidence interval (Tsong et. al. 1996)Subsequent Concerns: The validity of M-Distance? The cut-off point?Motivations: Slide10
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Objectives: Thoroughly examine the performance of bootstrapping f2 and f2 index:
can bootstrapping f2 save the situations that f2 is not applicable?
Gain empirical knowledge of the values of M-distance: does M-distance is a good substitute? What would be the “appropriate” cut-off point(s)?Slide11
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Scenarios 1: similarity factor f2 “safe” cases
For both batches 1) %CV at earlier time points (within 15
mins) <= 20% and %CV <= 10% at other time points; 2) Only one measurement after 85% dissolution Scenarios 2: large batch variability cases (f2 is not recommended generally)%CV > 20% (<= 15
mins
) or/and %CV > 10
% (> 15mins)
Different mean dissolution profile but same variability for both batches
Same mean dissolution profile but testing batch has large variabilityScenarios 3: multiple measurements
after 85%
dissolution
“Safe” Variability cases: Dissolution Guidance recommendations
Large Variability cases
Simulation Cases:Slide12
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Basic Simulation Structures:Dissolution Mean Profile from Weibull
Distribution:
Reference Batch: MDT= 25, B=1, Dmax=85
Testing Batch
:
Start
End
Step
MDT
13
37
2
B0.551.450.05Dmax73972Batch Variability (%CV) for 12 tablets: StartEndStep<=15 mins5%50%2%>15 mins5%30%2%
)],
5000 iterations for Bootstrapping f2
Time (
mins
): 5, 10, 15, 20, 30, 45, 60 Slide13
Scenarios 1 Cases:
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%CV at all time points = 5%
f2
43.60
Bootstrapping f2
43.30
M-Distance
31.07
%CV at all time points = 10%
f2
84.23
Bootstrapping f2
84.10
M-Distance
2.81
When similarity factor f2 is applicable per FDA guidance, bootstrapping f2 and f2 give the same similar/dissimilar conclusions;
In examined cases, the values of bootstrapping f2 is close to f2 values, though slightly smaller;Values of M-Distance could vary a lot, but within expectations. f2
51.04Bootstrapping f250.77M-Distance9.18%CV (<=15mins) = 15%, %CV (> 15mins) = 12%ReferenceTestingSlide14
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Demo of M-distance vs. Bootstrapping f2:
Values of M-Distance vary a lot:
for higher Bootstrapping f2, M-Distance can be lower than 5;for board line cases (around 50), M-Distance can vary from 7 to 20. Slide15
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Scenarios 2
Cases: Different Mean Dissolution Profile, but same variability at all the time points: some board line cases show up
Some discrepancies were observed between Bootstrapping f2 and f2 index
Bootstrapping f2 gives different conclusions for the same mean profile but different batch variability
Values of M-Distance vary
: stratified by batch variability?
Dmax
=89, MDT=19, B=0.75
%CV all time points 30%
f2
50.10
Bootstrapping f249.46M-Distance5.34
Dmax
=89, MDT=19, B=0.85
%CV all time points 30%
f2
51.3Bootstrapping f250.54M-Distance5.03
Dmax=89, MDT=19, B=0.75%CV all time points 10%f2 50.40Bootstrapping f250.10M-Distance9.31Slide16
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Same Mean Dissolution Profile but large variability for testing batch
Bootstrapping f2 is more sensitive to batch variability, but still gives the same conclusion with cut-off point as 50;
This may suggest to use a “higher” value as the cut-off point at large batch variability cases;
M-Distance varies: depends on the batch variability
In examined casesSlide17
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Scenarios 3: More than 1 measurement over 85%
In examined cases,
Bootstrapping f2 gives more appealing value but still same conclusion with cut-off point as 50;
This may suggest to use a different value as cut-off point
for bootstrapping f2.Slide18
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Findings:
When similarity factor f2
is applicable per FDA Dissolution guidance, bootstrapping f2 and f2 give the same similar/dissimilar conclusions;In the examined cases,Bootstrapping f2 is more sensitive to batch variability or multiple >85% measurements;
However, with 50 as the cut-off points, bootstrapping f2 still gives the same conclusion
as similarity factor f2;
Values of M-Distance varies a lot and appears that <=3 could be a similar case, and over 30 could be a
different case.Conclusions:
Based on current review experiences and examined cases, bootstrapping f2 is recommended when the similarity factor f2 is around 50 or large batch variability is observed;
At the large batch variability cases, new cut-off points may be proposed.
Testing batches would be penalized by larger batch variability.
M-Distance is another alternative approach for dissolution profile comparisons. Its values also depends on the batch variability.
T
he cut-off point is required for further deep examinations, particularly, M-Distance values at different batch variability and bootstrapping f2 around 50.Slide19
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Problems encountered with M-distance: Convergence issue with Inverse of
Proposal: To c
ompute the increment M-Distance
The proposed increment M-Distance can help us solve the convergence problem caused by highly correlated data (cumulative measurements);
The interpretation of increment M-Distance: the distance between the increment vectors from the testing and reference batches.Slide20
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References:FDA Guidance: Dissolution Testing of
Immediate Release
Solid Oral Dosage Forms, 1997FDA Guidance: SUPAC for Immediate Release Solid Oral Dosage Forms, 1995
FDA Guidance: Extended
Release Oral Dosage
Forms: Development, Evaluation
,
and Application of In Vitro/In Vivo Correlation, 1997In Vitro Dissolution Profile Comparison, Tsong et. al, 2003Assessment of Similarity Between Dissolution Profiles, Ma et. al, 2000
In Vitro Dissolution Profile Comparison – Statistics and Analysis of the Similarity Factor f2, V. Shah et. al, 1998
Statistical Assessment of Mean Differences Between Dissolution Data Sets, Tsong et al, 1996Slide21
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Acknowledgement:FDA Collaborators and Co-workers:
ONDQA: Dr. John Duan,
Dr. Tien-Mien ChenOGD: Dr. Pradeep M. SatheOB: Dr. Yi TsongSlide22
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Thank You!Slide23
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Back UpSlide24
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90% Confidence Region of M-Distance:
,where
By Langrage Multiplier Method