Sample Size Selection-USP - FDA - ASTM

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The key takeaways are that FDA, USP and ASTM each play a role in setting standards for product quality. FDA focuses on regulatory standards and product/process design and quality control. USP sets market and compendial standards. ASTM and other consensus standards organizations set industry standards and standard methods.

The two types of quality discussed are product design/specifications and ensuring low risk of failing to meet clinical attributes.

Regulators set and enforce regulatory standards. USP sets market standards and standard methods. ASTM and other consensus standards organizations set industry standards and standard methods.

Sample Size Selection

Role of Regulators, USP, and ASTM

Keith O. Webber, Ph.D.


Deputy Director
Office of Pharmaceutical Science
Acting Director
Office of Generic Drugs
CDER, FDA

Why Test?
Assessment of Quality
Verification of Quality
End-Product Testing
Rejection of out-of-spec lots

In-process Testing
In lieu of end-product testing
As part of in-process QC system
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Two Types of Quality


The suitability of either a drug substance
or drug product for its intended use.
ICH Q6A Specifications Guideline

The state of having an acceptably low risk


of failing to achieve the desired clinical
attributes.
J. Woodcock, M.D.
Amer. Pharm. Rev. (NovemberDecember 2004)
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Desired State
Product specifications based on
mechanistic understanding of how
formulation and process factors impact
product performance
Product quality and performance achieved
and assured by design of effective and
efficient manufacturing processes
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Two Types of Quality


Product design
Tablet Coating Design

http://www.medscape.org/viewarticle/540104_4

From: Pharmaceutical Formulation & Quality


TABLET COATINGS: Tune into Terahertz
L Ho, KC Gordon, T Rades, & P Taday

Specifications define the design.


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Batch/Lot Quality
Within-Lot Distribution

Lower Spec Limit

Upper Spec Limit

Attribute
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Batch/Lot Quality
Within-Lot Distribution

Lower Spec Limit

Upper Spec Limit

Attribute
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Numbers of tablets out-of-spec


Spec range = 75-125%
batch size = 1,000,000 tablets

Sigma

Mean
95%
100%

105%

6%
7%
7.8%

430
2150
5232

430
2150
5232

30
360
1350

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Dr. Janet W oodcock, April 9, 2002

Sample Size and Confidence


Calculating Sample Size (ASTM: E122 - 09)
Demonstrating Confidence in Complying with
an Acceptance Procedure (ASTM: E270910)
Confidence in Attribute Sampling (ASTM
E2334-09
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FDA , USP, ASTM


Each is involved in setting standards
associated with product quality.

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Regulators Role
Reviewer, Inspector, Compliance Officer
Set and enforce regulatory standards for:
Product quality (lot release & shelf life)
Quality control
Manufacturing control

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Reviewers Role
Ensure that product design is consistent
with products performance requirements
Ensure that process design is capable of
producing product that meets
specifications
Assess the process controls and the level
of confidence that units in a batch will
meet specifications
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Inspectors Role
Assess the ability of the manufacturer to
appropriately manufacture the product in
accordance with cGMPs and the
parameters in the marketing application.
Maintaining control
Routine sampling

Adequately responding to and investigating


deviations
Enhanced sampling adequate for intended
purpose?
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Compliance Officers Role


Work with the Reviewer to ensure that the
sampling plans to be approved are compliant
with cGMPs
Work closely and coordinate with ORA
Headquarters and Field Units on the review of
inspectional observations (483) and
Establishment Inspection Report (EIR) to
determine what (if any) regulatory action is
necessary to achieve compliance with cGMPs.
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Regulation on
Selection of Units
21 CFR 211.165(d)
adequate to assure that batches of drug
products meet each appropriate specification
and appropriate statistical quality control
criteria as a condition for their approval and
release

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USPs Role
Standards Mandated by Law
USP/NF referenced in 21 U.S.C. 351

Market Standards

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Adulteration & the USP


A drug may be considered adulterated :
If it purports to be or is represented as a drug the name of
which is recognized in an official compendium, and its
strength differs from, or its quality or purity falls below, the
standard set forth in such compendium. Such determination
as to strength, quality, or purity shall be made in accordance
with the tests or methods of assay set forth in such
compendium,
FDCA 501(b)
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USP General Notices


34th Revision
At times, compendial standards take on the character of
statistical procedures, with multiple units involved
The similarity to statistical procedures may seem to
suggest an intent to make inference to some larger
group of units, but in all cases, statements about
whether the compendial standard is met apply only to
the units tested
Repeats, replicates, statistical rejection of outliers, or
extrapolations of results to larger populations, as well as
necessity and appropriate frequency of batch testing, are
neither specified nor proscribed by the compendia.
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USP General Notices


34th Revision
The manufacturers specifications, and good
manufacturing practices generally (including,
e.g., Quality by Design initiatives) are developed
and followed to ensure that the article will
comply with compendial standards until its
expiration date
Frequency of testing and sampling are left to
the preferences or direction of those performing
compliance testing, and other users of USP-NF,
including manufacturers, buyers, or regulatory
authorities.
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Consensus Standards Orgs.


(e.g., ASTM)
Congress: National Technology Transfer
and Advancement Act (NTTAA); 1995
Office of Management and Budget (OMB):
Circular A-119; 1998 (original in 1993)
http://standards.gov/standards_gov/index.
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cfm

Consensus Standards Orgs.


(e.g., ASTM)
OMB Circular A-119
this Circular directs agencies to use
voluntary consensus standards in lieu of
government-unique standards except where
inconsistent with law or otherwise impractical.

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Use voluntary consensus


standards
To determine whether established
regulatory limits or targets have been met
Test methods
Sampling procedures
Protocols
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ASTM Standards for


Sampling / Statistics
E105 - 10:

Probability Sampling Of Materials

E122 - 09:

Calculating Sample Size to Estimate, With Specified


Precision, the Average for a Characteristic of a Lot or
Process

E141 - 10:

Acceptance of Evidence Based on the Results of


Probability Sampling

E178 - 08:

Dealing With Outlying Observations

E2709 - 10: Demonstrating Confidence in Complying with Acceptance


Procedures
E2587 - 10 : Statistical Process Control
E2334 09: Confidence in Attribute Sampling
E2281 10: Process Capability
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CSOs and FDAs authority


This policy does not preempt or restrict
agencies authorities and responsibilities
to make regulatory decisions authorized
by statute.
These include
Determining the level of acceptable risk
Setting the level of protection
Balancing risk, cost and availability of
technology in establishing regulatory
standards.

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FDA , USP, ASTM


Each is involved in setting standards for
product quality.
FDA Regulatory standards
Product design & quality control

USP Market stds. & standard methods


CSOs (e.g., ASTM) Industry standards
Standard Methods
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FDA, USP, ASTM


Regulatory Standards

FDA

USP
Market Standards
& Standard Methods

CSOs*
Industry
Standards
*e.g., ASTM

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Acknowledgements

Alex Viehmann
Jon Clark
Ali Afnan
Steven Lynn
Helen Winkle

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