CDER Research on Transdermal Generic Evaluations

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A new FDA post discusses research by CDER statisticians who developed innovative and more efficient ways to evaluate transdermal and topical delivery systems (collectively called TDS). Instead of evaluating similarity of adhesion between test and reference scores as the ratio of means (ROM) adhesion scores, CDER statisticians settled for a comparison based on the difference of mean (DOM) adhesion scores. “As opposed to the previous noninferiority threshold of a test/reference ratio of less than 1.25, CDER experts determined that the more appropriate noninferiority threshold would be based on the difference in the test product and reference product overall mean adhesion scores, with a noninferiority margin of 0.15 (i.e., 15%),” the post says.

 

“Computer simulations were conducted to compare the power of the two approaches (ROM vs. DOM) while varying critical parameters such as study size (number of subjects) and variability (e.g., across adhesion scores in a given subject) for a range of different test and reference product adhesion scores (i.e., for TDS spanning the range from well adhering to poorly adhering),” the agency says. “These simulations demonstrated that the low power of the traditional ROM approach was due to the (numerically) small values of the scores for well adhering brand name (reference) products. These investigations showed that the DOM approach would provide much higher power to correctly conclude that well-adhering test products exhibited noninferior adhesion compared to a well-adhering reference product, without increasing the probability of mistakenly concluding that a poorly adhering test product showed acceptable, noninferior adhesion (i.e., Type 1 error was controlled at the same level).”

 

The research resulted in a new draft guidance for industry that recommends using the more powerful DOM method rather than the previous ROM method for the statistical noninferiority analysis when comparing the adhesion performance of a would-be generic TDS to its corresponding reference product. To determine how well the DOM approach would work with real world data, CDER statisticians looked at 40 studies comparing the adhesion of test and reference TDS products that had been submitted to the FDA in applications for generic TDS products and applied the updated recommendations in the new draft guidance, the post says.

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