An Issue in Multi-Regional Clinical Trial Design: Sample Size of Japanese patients 2011 APEC MRCT TOKYO Workshop November 2nd, 2011 Kihito Takahashi, MD, PhD GSK-Japan, JAPhMed, JCPM Disclaimer and Acknowledgement The views and opinions expressed in the following presentation are those of the individual presenter and should not be attributed to any organization with which the presenter is employed or affiliated. This slides were created with the strong support from the following individuals: – Dr. Masao Yarita (GSK) – Dr. Yoshio Tsukada (GSK) – Dr. Tomoya Masaki (GSK) 2 Background of the Issue Currently, sample size determination of Japanese patients in MRCT is one of the most controversial issues among pharmaceutical companies. – Before Japan’s participation in MRCT, determination in regional sample size was not a major issue Recent References regarding this issue: – 13 Sep 2010, APEC Multi-Regional Clinical Trials Seoul Workshop Multi-Regional Clinical Trials in Global Drug Development: Experience in Japan. Yuki Ando. PMDA – 19 Nov 2010, The Biometric Society Seminar Issues in synchronized global development and multi-regional studies from regulator’s viewpoint. Yuki Ando. PMDA – 30 Sep 2011, The Tenth Kurume Biostatistics Forum Statistical aspects in drug review. Yuki Ando. PMDA 3 Description in ICH guidelines ICH-E5 Q&A11 (5-Oct-2006 ) – discussion of a multi-regional clinical trial. Q11: … It may be desirable in certain situations to achieve the goal of bridging by conducting a multi-regional trial under a common protocol that includes sufficient numbers of patients from each of multiple regions to reach a conclusion about the effect of the drug in all regions. Please provide points to consider in designing, analyzing and evaluating such a multi-regional trial. A11: ………. For a multi-regional trial to serve as a bridging study for a particular region, it would need to have persuasive results in that region, because it is these regional results that can convince the regulators in that region that the drug is effective, and can “bridge” the results of trials in other regions in the registration application.. 4 Description in Japanese Guidelines Basic Principles on Global Clinical Trials – (28-Sep-2007) 6. When conducting an exploratory trial like a dose-finding study or a confirmatory trial as a global clinical trial, how is it appropriate to determine a sample size and a proportion of Japanese subjects? – In a global trial, sample size can be calculated assuming results from the entire study population across regions. In this case, a sufficient statistical power to detect statistically significant difference should not necessarily be secured within the Japanese subpopulation. 5 Sample Size Calculation Method 1 DALL DJapan Dother 0 ↑criteria DJapan > All regions 1 DAll 2 Japan Differences between placebo and treatment Method 2 DJapan > 0, DChina > 0, DKorea > 0 DJapan DKorea All regions Japa n DChina 0 ↑criteria Korea China Differences between placebo and treatment 6 Sample Size Determination: Reference in the guideline Example: In case of clinical trial with the following characters: – the size of a few hundred patients – two-arm – placebo-controlled parallel group design – similar efficacy across regions For a scientifically appropriate evaluation based on the existing study results, – (1) by the method 1, if attempting to minimize the Japanese sample size while to an adequate extent preventing increase of the total sample size, Japanese subjects are needed to account for about 20 %; – (2) by the method 2, when conducting a trial in three regions, with the power of the trial as 90 % for the total sample size, Japanese subjects are needed to account for about 15 % or more. 2007, Guideline 7 Positive Impact of Guideline on MRCT The number of MRCTs steeply increased after the publication of the guideline 60 Time course on % of MRCT in Japan Ratio (%) 50 40 30 55.2 20 28.6 10 7.1 5.6 4.9 5.6 2003 2004 2005 2006 0 2007 2008 EFPIA-J 2010 8 Dependency on the Guideline : Survey Results from 11 Companies Base Comply (both DE and SS) Not Foreign based 5(3) 2 Domestic 2(0) 2 Result from internal interview survey (SS=sample size, DE=data extrapolation) Summary: – Companies tend to follow the guideline regarding the feasibility assessment of data extrapolation – Companies do not necessarily follow regarding sample size calculation: Simulation and/or confidence limit Consultation with PMDA Practicality 9 Proportion of Japanese Patients by Therapeutic Area Ando, 2010 10 An Example in a pharmaceutical company Japanese sample size in MRCT : – Not correlated with the whole sample size of the study – Proportion of Japanese patients decreases as the whole size increases 1 Japanese proportion vs. total sample size in MRCT 0.9 0.8 N Japan (proportion) 0.7 0.6 0.5 0.4 0.3 0.2 0.1 0 0 5000 10000 15000 N total 11 Consultation with PMDA : Major Route for Japanese Sample Size Determination 2006, ICH-E5Q&A11, Planning – Minor differences in design (e.g., age inclusion criteria, concomitant medication, etc.) may be acceptable and prior discussion with regulatory agencies is encouraged. 2007, Guideline – since FY2006, the Pharmaceuticals and Medical Devices Agency (PMDA) has given priority status to sponsors’ requests for clinical trial consultation on global clinical trials. It is important that sponsors and PMDA sufficiently discuss the clinical study design and data handling, etc. for individual development programs through the clinical trial consultations, assuming conduct of a global clinical trial. – For individual cases, issues identified in this notification, such as development strategies and trial designs, should be considered in advance, and the clinical trial consultations with PMDA should be utilized as soon as possible. – If results from a Japanese subgroup are markedly different from those in the entire study population, the reasons for it should be examined and in this case, because an additional clinical trial may be needed where necessary, it is recommended to utilize the clinical trial consultation with PMDA. – Specific sample size setting for individual cases can be discussed with PMDA on the clinical trial consultation. 12 Trend in Number of Consultation on MRCT Moriyama, 2011 13 Possible Direction for Japanese Sample Size in MRCT Large sample size where ethnic difference exists Smaller sample size where ethnic difference does not exist More experiences are needed to confirm this direction 14 Summary Determination of Japanese sample size remains as a controversial issue. MRCT Guideline provides a guidance for the Japanese sample size determination and contributed to increase MRCTs. Approach for sample size determination varies among companies. In reality, sample size seems to be determined through PMDA consultation based on simulation, statistical approach and practicality etc. Further research and accumulation of MRCT cases will hopefully provide more scientific solution for the regional sample size determination. 15 References 1. 2. 3. 4. 5. 6. 7. ANDO Yuki. Multi-Regional Clinical Trials in Global Drug Development: Experience in Japan. 2010 Multi-Regional Clinical Trials Seoul Workshop 13-Sep2010 slide (http://www.pmda.go.jp/english/presentations/index.html) ICH. E5 (Ethnic Factors) Implementation Working Group Questions & Answers (R1). 2-Jun-2006 MHLW. Basic principles on Global Clinical Trials. 28-Sep-2007 OOSAWA Shino. A study on statistical consideration for Japanese sample size in global clinical trial. 14-Feb-2009. Slide for master thesis defense (Japanese) ISHIBASHI Keita. Current situation and issue about global clinical trials. Office of Pharmaceutical Industry Research News No.26. 2008 KATOH. Chairperson press conference. 4-Mar-2010 slides (Japanese) (http://efpia.jp/link/100303Press%20conference_J_fin.pdf) MORIYAMA Yusuke. Clinical Trial Notifications and Scientific Consultation System in Japan. The Second China-Japan Symposium on Drug Development focusing on IND, Pre-Consultation, GMP and DMF system 12-Apr-2011 slide (http://www.pmda.go.jp/english/past/2011beijing_sympo.html) 16
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