Transcript Project To Exceed (PTE) Guidance

Statistical Issues With Linear
Extrapolation of Stability Data
Jason Marlin, MS/T Statistics, Eli Lilly & Co.
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Define OOT & PTE
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OOT—Out of Trend: the FDA considers any atypical test result
or slope to be an “out of trend.”
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PTE—Project to Exceed (Lilly term): linear extrapolation of
stability data that indicates a lot may exceed the regulatory limit
prior to expiry
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FDA Resource for OOT PTE
From Q1E: The Evaluation of Stability Data (June 2004)
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The FDA expects industry to monitor stability batches and to react to
trends or changes.
Where appropriate, determine if batches may not stay within the
regulatory specifications during shelf-life.
Inform agency in advance if product will fail
Modeling an appropriate fit is clearly important to this work.
Additional Resources
Published reference papers:
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April 2003, Identification of Out of Trend Stability Results, by PhRMA
CMC Statistics Stability Expert Teams, published in Pharmaceutical Technology
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October 2005, Identification of Out-of-Trend Stability Results, Part II, by
PhRMA CMC Statistics Stability Expert Teams, published in Pharmaceutical
Technology
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These papers establish three types of OOT data:
 1) Analytical—a single result out of trend but within specification
 2) Process Control—a succession of data points with an atypical pattern
 3) Compliance—a single result or succession of results indicates the likelihood for an Out
Of Specification prior to Expiry
PTE Resource
From April 2003, Identification of Out of Trend Stability Results
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“The extrapolation of OOT should be limited and
scientifically justified, just as the use of extrapolation of
stability data is limited in regulatory guidance (ICH,
FDA).“
WIIFM
Every pharmaceutical company is required to evaluate stability
data for trends and respond accordingly.
Every product has different challenges—e.g. assay (RMSE of
common slopes), process mean, markets, possibly different
stability timepoints, possibly different sites of manufacture, etc.
Intent: provide some measure of accounting for these differences
in the process of evaluating stability data for projection to
exceed.
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What is not covered is a method for controlling the Type II error rate—namely,
failing to signal a batch that will exceed regulatory prior to expiry. (A rough
simulation has been performed but further refinement is needed).
WIIFM-continued
PTE’s are often evaluated by a stability coordinator (often nonstatistician)
A false signal=wasted resources (deviation, investigation, re-assay, etc.)
Generic computer algorithms don’t account for necessary variables (how
many batches are manufactured, assay, process mean, etc.)
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Thus, some “decision-science” is needed to allow the coordinator to determine
how many stability timepoints are required to obtain a reliable projection
Example: Actual Example ( w/coded data)
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7 stability batches, all with data through at least 50% of expiry
Example: Actual Product w/coded data continued
Expiry
A lot with 6 timepoints PTE. 6th timepoint at 18 months
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Sources of OOT
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Reasons for a false signal:
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Non-linear data
Limited data
Process mean deviation from label claim
Assay variability
simulation
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What data requirements are needed to limit the probability of a false
signal?
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Problem: for products with no practical change on stability and relatively
high assay variability, three or four points are not sufficient to prevent
false signals
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Simulation
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Properties with Single-sided and Dual-sided limits are evaluated.
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For single-sided limits, the mean bias and the assay standard deviation
are expressed as a portion of the regulatory limit
For dual-sided limits, the mean bias and the regulatory limit are
expressed in actual units as % of label claim but they can also be
expressed as k-sigma units of the assay standard deviation
For the sake of simplicity, both single-sided and dual-sided properties are
expressed in k-sigma units as “distance to nearest specification.” This eliminates
the need for presenting two sets of results.
Simulation-cont’d
Two-sided Limit
One-sided Limit
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Simulation—continued
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Population means and assay standard deviations (assumed known)
simulated relative to target.
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For single-sided and dual-sided limits,1500 simulations are performed
for 40 different combinations of true mean, regulatory limits and assay
standard deviation
Assumptions: 1) No Change on Stability 2) 36-month
expiry 3) Typical Stability timepoints (0,3,6,9,12,18,24,30) A
reduction in alpha (α)—all else held constant—could affect beta
(β).
**The assumption that there is not change on stability MUST be based
on the science of the molecule/packaging and supported by available
stability data
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Errors in PTE
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Type I—designating a batch as PTE when the true property is
not outside regulatory limits at expiry.
Type II—failing to detect a batch with a true property value
outside regulatory limits at or before expiry.
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Goal
 In general, identify the minimum n such that no PTE’s are
issued >95% of the time for properties which are
practically stable.
 Also evaluated n (minimum # of stability timepoints) for
90 and 99%.
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Allow manufacturing sites to select a minimum # of stability
time-points to achieve the desired alpha.
Allow manufacturing sites to see the impact of mean bias and
assay standard deviation on the likelihood of falsely PTE
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Target products are those with large assay error and with process
means close to the Regulatory limits (small R values)
 Brief JMP Simulation Overview
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R
Question: Is an R=4 the same for different combinations?
R1=4=100-90/2.5
R2=4=99-95/1
Simulation shows the results are effectively the same for a given n.
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Rn=4(0,3,6,9,12,18,24months)
Each point represents a
different combination of
assay, process mean and
regulatory.
Bivariate Fit of % Not PTE By R n=4
RMSE=2.79%
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Rn=5(0,3,6,9,12,18,24months)
Bivariate Fit of % Not PTE By R n=5
RMSE=2.16%
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Rn=6(0,3,6,9,12,18,24months)
Bivariate Fit of % Not PTE By R n=6
RMSE=0.99%
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Rn=7(0,3,6,9,12,18,24months)
Bivariate Fit of % Not PTE By R n=7
RMSE=0.31%
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R (4, 5, 6 & 7 stability timepoints)
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R Summary Tables
0,3,6,9,12,18,24 months
90% Table
R
≤2.4
2.5-3.2
3.3-7.4
>7.5
n
7
6
5
4
90% Table
R
≤1.9
2.0-2.4
2.5-3.3
>3.4
n
7
6
5
4
95% Table
95% Table
R
≤3.2
3.3-4.8
4.9-9.4
>9.5
0,3,6,12,18,24,30 months
n
7
6
5
4
R
≤2.4
2.5-3.2
3.30-4.8
>4.8
n
7
6
5
4
99% Table
99% Table
R
≤4.8
4.9-7.5
7.6-9.5
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n
7
6
5
R
≤3.3
3.4-7.4
7.5-9.4
>9.4
n
7
6
5
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Summary
• Simulation provides a method to protect against falsely PTE for
products which are stable
• Increasing the number of data-points required to perform a PTE
evaluation can—for instances where actual product stability
changes occur—result in an increased likelihood of failing to detect
a PTE for a product which will have a true property value outside
the regulatory specifications
• PTE evaluations need to account for assay variability, mean bias
and the scientific basis of product stability.
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Summary
•Next Steps—simulate with linear slope to determine at what
expense the reduction in false PTE’s (by increasing n) is achieved
Determine how the PTE changes as a result of true change on stability
Initial look (slopes of 0.05%/month and 0.10%/month ) for 36-month
dating and for a product with ±10% regulatory limits, as long as the mean
was within 2% of target, these slope changes would not result in a true
property value outside the regulatory limits.
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Talking Points
• Distance of projection to expiry is very important
• Alpha should be a ƒn of # of lots manufactured and historical
data
• In general, 4 stability timepoints is marginal for 95%
probability of not falsely PTE
• Beta dependent on assumption of stability
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Questions
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One-Sided Simulation
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For different true, but unknown property mean values and for different true
but unknown assay variabilitys, simulate the probability of PTE given the
seven assumed stability time-points for two different stability evaluations:
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1500 simulations are performed for 20 different combinations of true mean
and assay standard deviation
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0, 3, 6, 9, 12, 18 and 24 months (standard validation timepoints)
0, 3, 6, 12, 18, 24 and 30 months (alternative timepoint approach)
Assay stdev levels=10,20, 30, 40 and 50 % of regulatory
Mean Bias Levels=0, 5, 10, 20 and 25 % of regulatory
Regulatory Level is not a factor for the one-sided simulation as both variables are
expressed in terms of a given regulatory limit (this is verifed by simulation to
work for different regulatory limits)
Assumptions: 1) No Change on Stability 2) 36-month expiry 3) Typical
Stability timepoints 4) A reduction in alpha (α)—all else held constant—
could affect beta (β).
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Two-Sided Simulation
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For different true, but unknown property mean values (in % of label
claim but also easily expressed in k-sigma units from target) and for
different true but unknown assay variabilities, simulate the probability
of PTE given the seven assumed stability time-points for two different
stability evaluations:
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1500 simulations are performed for 40 different combinations of true
mean, regulatory limits and assay standard deviation
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0, 3, 6, 9, 12, 18 and 24 months (standard validation timepoints)
0, 3, 6, 12, 18, 24 and 30 months (alternative timepoint approach)
Assay stdev levels=0.50, 0.75, 1.00, 1.25 and 1.50 % of target
Mean Bias Levels=0.0, 0.5, 1.0, and 1.5 % from target
Regulatory Levels=±5% from target, ±10% from target
Assumptions: 1) No Change on Stability 2) 36-month expiry 3)
Typical Stability timepoints 4) A reduction in alpha (α)—all else held
constant—could affect beta (β).
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Summary Table for One-sided and Two-sided
One-sided V1
90% Table
R
n
≤1.9
7
2.0-2.4
6
2.5-3.3
5
>3.4
4
One-sided V2
90% Table
R
n
≤2.4
7
2.5-3.2
6
3.3-7.4
5
>7.5
4
Two-sided V1
90% Table
R
n
≤2.3
6
2.4-3.5
5
>6.7
4
Two-sided V2
90% Table
R
n
≤3.2
6
3.3-4.7
5
>4.7
4
95% Table
R
n
≤2.4
7
2.5-3.2
6
3.30-4.8
5
>4.8
4
95% Table
R
≤3.2
3.3-4.8
4.9-9.4
>9.5
95% Table
R
n
≤2.3
7
2.4-3.2
6
3.3-4.5
5
>4.5
4
95% Table
R
n
≤2.7
7
2.8-4.5
6
4.6-5.7
5
>5.7
4
99% Table
R
n
≤3.3
7
3.4-7.4
6
7.5-9.4
5
99% Table
R
≤4.8
4.9-7.5
7.6-9.5
>9.4
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4
n
7
6
5
4
n
7
6
5
99% Table
R
≤3.3
3.4-4.5
4.6-6.7
>6.7
n
7
6
5
99% Table
R
≤4.0
4.1-5.3
5.4-8.5
n
7
6
5
4
>8.6
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Summary graphs for R by simulation
0, 3, 6, 9, 12, 18, 24 months
0, 3, 6, 12, 18, 24, 30 months
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