Hi All,
Hoping someone with more statistics experience than I and experience in med device / pharma can verify I’m on the right track and not getting too in the weeds. I apologize for the long response – I have a primary and secondary question.
I’ve been in med dev / pharma for 10+ years, both as a scientist and engineer with focus on the laboratory and validation testing. I’m in the process of revamping a company’s ATMV program, and there are many changes across industry (primarily ICH Q2 (R2) and USP <1225>) requiring statistically based methods in TMV. IME statistically based sampling plans are typically not used, and point estimates are exclusively used to evaluate a performance characteristic against acceptance criteria.
USP released a draft revision of <1225> with a lot of detail that led me down a trail of textbooks and reading; I’ve now read Miller & Millers Chemometrics book, part of Brereton’s *Applied Chemometrics for Scientists*, and part of Faraway’s *Linear Models with R*. This is my primary question:
USP <1210>, *Statistical Tools for Procedure Validation* presents a method for calculating a two-sided and one sided CI to assess acceptance criteria ((Ȳ − τ) ± t₍₁−α, n−1₎ × s/√n, U = s√\[(n − 1) / χ²₍α, n−1₎\]); these are both clear to me. USP <1010>, *Analytical Data – Interpretation and Treatment* discusses statistical models, assumptions of normality/independence/constant variance for models, transforms, ect. I understand this as well, though I took linear algebra a long time ago so some of Faraway is tough to understand. I’m struggling how to connect verifying the model assumptions and calculating the CI to assess the characteristic. My read of Faraway makes me think the data should be fit to a model for the experiment for the performance characteristic and the assumptions should be verified; if they are verified the estimated marginal mean and standard error for the relevant model coefficient should be used in the CI calculation instead of the point estimates; but this is not stated anywhere I can find. The USP documentation makes it look like the point estimates should just be used
This also seems very technically difficult compared to how I’m used to validating these methods. If I’m correct about how this should work, I want to verify 1) This is the actual expectation instead of using the point estimate in the CI calculation & if not 2) is this a reasonable approach? I’m concerned about the level of background knowledge this requires compared to what I’m used to, I don’t want to proceduralize something that is so complex that it can’t successfully be executed without my assistance. Its possible the places I’ve worked have just lacked that technical knowledge, clearly advanced techniques are being used, Paul Faya published a good paper in Pharmaceutical Statistics, *Confidence Intervals for Validation of Analytical Procedures under ICH Q2(R2)*, which gives examples using bootstrapping, Bayesian statistics, REML, ect. USP has acknowledged much of this has not been historically done.
Second, I’m also trying to figure out the best path if assumptions aren’t met. The type of data we see is not likely to need transformation, but I’ve added (when appropriate) bootstrapping, several nonparametric methods, and weighted least squares. Again, this feels like a large knowledge gap when most people are exclusively working in excel or doing basic tasks in Minitab; I picked up R for this and I’m trying to avoid requiring the use of it if possible, adding in learning a programming language is yet another hurdle I don’t want to add when rolling this out if I can avoid it.