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Shirpur Education Society’s
R. C. Patel Institute of Pharmaceutical Education and Research, Shirpur
Presentation on
E4 – Dose Response Information to support
Drug Registration
Presented by -
Bhavesh Patil ,
First Year M. Pharmacy (Regulatory Affairs)
Guide –
Dr. P. P. Nerkar.
(Dept. of Regulatory Affairs)
R. C. Patel Institute of Pharmaceutical Education and Research, Shirpur
1
Content
Introduction
1
Purpose of Dose-Response Information
2
Use of Dose-Response Information in Choosing Doses
3
Uses of Concentration-Response Data
4
Problems with Titration Designs
5
Interactions Between Dose-Response and Time
6
Obtaining Dose-response Information
7
Specific Trial Designs
8
2
Introduction –
Efficacy Guidelines :
The work carried out under the efficacy heading is all about design,
conduct, safety and reporting of the clinical trials. It also cover some
other aspects like novel type of medicine derived from biotechnological
process and the use of pharmacogenomics to produce better targeted
medicines.
E4 – Dose response Information to support Drug Registration
This guideline was developed within the Expert Working Group
(Efficacy) of ICH for the Registration of Pharmaceuticals for Human
Use and has been subject to consultation by the regulatory parties, in
accordance with the ICH process.
This ICH harmonized guideline was finalized under step 4 in March
1994.
This guideline was published in the Federal Register on November 9,
1994 (59 FR 55972) and is applicable to both drug and biological
products.
E4 – Dose response
Information to
support Drug
Registration
3
This document gives
recommendations on the design
and conduct of studies to access
the relationship among dose,
drug – concentration and clinical
response given by drug.
This information can give the
appropriate starting dose, to
adjust to the dosage need of
particular patient need.
Scope of E4 guideline
Objectives of E4 guideline
Knowledge of the relationship among
dose, drug-concentration in blood and
clinical response is imp for safety of
patient
It gives the common database
globally to all regulatory
agencies to provide an
economical approach.
4
To identify an
appropriate starting
dose
To adjust dosage according to the
needs of a particular patient, and a
dose beyond which unacceptable side
effects are observed.
To prepare dosage and
administration instructions in
product labeling.
Historically, drugs have often
been initially marketed at
excessive doses (sometimes with
adverse consequences
This situation has been improved by
attempts to find the smallest dose with a
detectable useful effect or a maximum
tolerated dose
Purpose of Dose-Response
Information
5
Use of Dose-Response Information in Choosing Doses
A high starting dose, might be a poor choice for a drug
with a small demonstrated separation between its useful
and undesirable dose ranges
Choice of starting dose may be affected by intersubject
variability in pharmacodynamic response to a given
blood concentration level, or by pharmacokinetic
differences, such as nonlinear kinetics or
pharmacokinetic drug-drug interactions.
In dose-response information, it is important to identify, factors that lead to
differences in pharmacokinetics of drugs among individuals, including
demographic factors, other diseases,diet, concurrent therapies, or individual
characteristics (e.g., weight, body habitus, other drugs, metabolic
differences).
In these cases, a lower starting dose would protect patients
who obtain higher blood concentrations.
6
Uses of Concentration-Response Data
A drug can be safely and effectively given only with blood concentration monitoring,
the value of concentration-response information is mandatory.
An established concentration-response relationship is often not needed, but useful in
below cases. (1) For ascertaining the magnitude of the clinical consequences, such as
those due to drug-disease (e.g., renal failure) or drug-drug interactions; or (2) for
assessing the effects of the altered pharmacokinetics of new dosage forms or new
dosage regimens.
Concentration-response information can also allow selection of doses (based on the
range of concentrations they will achieve) most likely to lead to a satisfactory response.
If the relationships between concentration and observed effects (e.g., an undesirable or
desirable) are defined, the drug can be titrated according to patient response without
further blood level monitoring.
7
Problems with Titration Designs
A study design
widely used to
demonstrate
effectiveness
utilizes dose
titration to
some
effectiveness
or safety
endpoint.
Such titration
designs,
without careful
analysis, are
usually not
informative
about dose-
response
relationships.
In some cases, notably where an
early results are essential, the
titration-to-highest-tolerable-
dose approach is acceptable,
because it often requires a
minimum number of patients.
For example, the first marketing
of zidovudine (AZT) for
treatment of people with
acquired immune deficiency
syndrome (AlDS) was based on
studies at a high dose; later
studies showed that lower doses
were as effective and far better
tolerated.
8
• The choice of the size of an individual dose is dependent
with the frequency of dosing.
• In general, when the dose interval is long compared to the
half-life of the drug, attention should be directed to the
pharmacodynamic basis for the chosen dosing interval.
• Dose-response studies should take time into account in a
variety of other ways.
• Like the study period at a given dose should be long enough
for the full effect to be realized, whether delay is the result
of pharmacokinetic or pharmacodynamic factors.
• The dose-response may also be different for morning versus
evening dosing.
• Similarly, the dose-response relationship during early dosing
may not be the same as in the subsequent maintenance
dosing period.
Interactions
between
Dose -
Response
and Time
9
II. OBTAINING DOSE-RESPONSE INFORMATION
A. Dose-Response Assessment Should Be an Integral Part of Drug
Development
If dose-response information is built into the development process it can be
accomplished with no loss of time and minimal extra effort compared to
development plans that ignore dose-response.
B. Studies in Life-Threatening Diseases
• Parallel dose-response study designs with placebo, or placebo-controlled
titration study designs (very effective designs, typically used in studies of
angina, depression, hypertension, etc.) would not be acceptable in the study of
some conditions, such as life-threatening infections or potentially curable
tumors, sometimes relatively high doses of drugs are usually chosen to achieve
the greatest possible beneficial effect rapidly.
• In life threatening diseases drug developer should choose the best dose, dose-
interval, better dose escalation steps and highest tolerated dose.
10
C. Regulatory Considerations When Dose-Response Data Are Imperfect
• Even well-laid plans are not invariably successful.
• well-designed dose-response study may have utilized doses that were too high, or
too close together, so that all appear equivalent.
• In that case, there is the possibility that the lowest dose studied is still greater than
needed to exert the drug's maximum effect.
• An acceptable balance of observed undesired effects and beneficial effects can be
marketed at one of the doses studied.
• This decision would be easiest, if the drug had special value, if in case it have partly
defined dose range, the dose finding can be done in post-marketing phase.
11
D. Examining the Entire Database for Dose-Response Information
• In addition to seeking dose-response information from studies specifically designed to
provide it, the entire database should be examined intensively for possible dose-
response effects.
• The limitations imposed by certain study design features should, of course, be
appreciated. For example, many studies titrate the dose upward for safety reasons.
• As most side effects of drugs occur early and may disappear with continued treatment,
this can result in a spuriously higher rate of undesirable effects at the lower doses.
• If pharmacokinetic screening (obtaining a small number of steady-state blood
concentration measurements) is carried out, or if other approaches to obtaining drug
concentrations during trials are used, a relation of effects (desirable or undesirable) to
blood concentrations may be detected.
• The relationship may by itself be a convincing description of concentration-response or
may suggest further study.
12
III. STUDY DESIGNS FOR ASSESSING DOSE RESPONSE
1. General
• The choice of study design in dose-response trials will depend on the phase of
development, the therapeutic indication under investigation, and the severity of the
disease in the patient population of interest.
• In general, useful dose-response information is best obtained from trials specifically
designed to compare several doses.
• A comparison of results from two or more controlled trials with single fixed doses
might sometimes be informative.
• It is also possible in some cases to derive, retrospectively, blood concentration-
response relationships from the variable concentrations attained in a fixed-dose trial.
• Conducting dose-response studies at an early stage of clinical development may
reduce the number of failed Phase 3 trials, speeding the drug development process and
conserving development resources.
13
• Pharmacokinetic information can be used to choose doses that ensure adequate spread of
attained concentration-response values and eliminate overlap between attained
concentrations in dose-response trials.
• For drugs with high pharmacokinetic variability, a greater spread of doses could be
chosen. Alternatively, the dosing groups could be sorted by adjusting for
pharmacokinetic covariates or a concentration-controlled study could be carried out.
• When the study endpoint is delayed, titration and simultaneous assessment of response is
usually not possible, and the parallel dose-response study is usually needed.
• Trials intended to evaluate dose- or concentration-response should be well-controlled,
using randomization and blinding to assure comparability of treatment groups and to
minimize bias, and should be of adequate size.
14
B. Specific Trial Designs
A number of specific study designs can be used to assess dose-response. The same
approaches can also be used to measure concentration-response relationships.
The following approaches have been shown to be useful ways of deriving valid dose-
response information.
1. Parallel Dose-Response
i. Randomization to several fixed-dose groups (the randomized parallel dose-
response study) is simple in concept and is a design that has had extensive
use and considerable success.
ii. The fixed dose is the maintenance dose; patients may be placed immediately
on that dose or titrated gradually (in a scheduled "forced" titration) to it if that
seems safer.
iii. In principle, statistically significant trend (upward slope) across doses can be
established using all the data.
iv. The parallel dose-response study gives group mean (population-average)
dose-response, not the distribution or shape of individual dose-response
curves.
15
v. The factorial trial is a special case of the parallel dose-response study to be
considered when combination therapy is being evaluated.
vi. It is particularly useful when both agents are intended to affect the same
response variable (a diuretic and another anti-hypertensive), or when one drug
is intended to mitigate the side effects of the other.
vii. These studies can show effectiveness of each component of the combination
and, in addition, provide dosing information for the drugs used alone and
together.
2. Cross-over Dose-Response
i. A randomized multiple cross-over study of different doses can be successful if
drug effect develops rapidly and patients return to baseline conditions quickly
after cessation of therapy.
ii. Problems of all cross-over studies are ,it can have analytic problems if there are
many treatment withdrawals; it can be quite long in duration for an individual
patient; and there is often uncertainty about carry-over effects.
16
iii. The advantages of the design are that each individual receives several different
doses so that the distribution of individual dose-response curves may be
estimated.
3. Forced Titration
i. A forced titration study where all patients move through series of rising
doses, is similar in concept to a randomized multiple cross-over dose-
response study, except that assignment to dose levels is ordered, not random.
ii. A critical disadvantage is that, by itself, this study design cannot distinguish
response to increased dose from response to increased time on drug therapy
or a cumulative drug dosage effect.
iii. This design can give a reasonable first approximation of both population-
average dose response and the distribution of individual dose-response
relationships if the cumulative (time-dependent) drug effect is minimal and
the number of treatment withdrawals is not excessive
17
4. Optional Titration (Placebo-Controlled Titration to Endpoint)
i. In this design, patients are titrated until they reach a well-characterized
favorable or unfavorable response, defined by dosing rules expressed in the
protocol.
ii. This approach is most applicable to conditions where the response is
reasonably prompt and is not an irreversible event, such as stroke or death.
iii. It is important, in this design, to maintain a concurrent placebo group to
correct for spontaneous changes
iv. Like other designs that use several doses in the same patient, this design may
use fewer patients than a parallel fixed-dose study of similar statistical power
and can provide both population average and individual dose-response
information.
v. Like the forced titration design, it can be used to study a wide dose range and,
with a concurrent placebo group, can provide clear evidence of effectiveness.
18
IV. GUIDANCE AND ADVICE
1. Dose response data are desirable for almost all new chemical entities entering the
market. These data should be derived from study designs that are sound and
scientifically based; a variety of different designs can give valid information.
2. The information obtained through targeted studies and analyses of the entire
database should be used by the sponsor to:
• Identify a reasonable starting dose, with specific adjustments for patient size,
gender, age, concomitant illness, and concomitant therapy.
• Identify reasonable, response-guided titration steps, and the interval at which
they should be takenThese steps would be based either on the shape of the
typical individual's dose-effect curves and the time needed to detect a change
in these effects.
• Identify a dose, or a response (desirable or undesirable), beyond which
titration should not ordinarily be attempted.
19
3. Dose-response data for both beneficial and undesirable effects may provide
information that allows approval of a range of dose.
4. It is prudent to carry out or concentration-response studies early in development in
order to avoid failed Phase 3 studies.
5. Regulatory agencies and drug developers should be open to new approaches and to
the concept of reasoned and well-documented exploratory data analysis of existing or
future databases in search of dose-response data.
6. Adjustment of drug exposure levels might be made on the basis of reliable
information on drug-taking compliance. In all of these cases, one should always be
conscious of confounding, i.e., the presence of a factor that alters both the refigured
dose and response or that alters both blood level and response, compliance and
response, etc
20
7. Approval decisions are considered with degree of effectiveness shown,
imperfections in the database may be acceptable with the expectation that
further studies will be carried out after approval.
21
V. REFERENCES
1. Federal Register. Vol. 59, No. 216, Wednesday, November 9, 1994, pages 55972-55976
2. https://www.ich.org/page/efficacy-guidelines
22
THANK
YOU !
23

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E4 Presentation.pptx

  • 1. Shirpur Education Society’s R. C. Patel Institute of Pharmaceutical Education and Research, Shirpur Presentation on E4 – Dose Response Information to support Drug Registration Presented by - Bhavesh Patil , First Year M. Pharmacy (Regulatory Affairs) Guide – Dr. P. P. Nerkar. (Dept. of Regulatory Affairs) R. C. Patel Institute of Pharmaceutical Education and Research, Shirpur 1
  • 2. Content Introduction 1 Purpose of Dose-Response Information 2 Use of Dose-Response Information in Choosing Doses 3 Uses of Concentration-Response Data 4 Problems with Titration Designs 5 Interactions Between Dose-Response and Time 6 Obtaining Dose-response Information 7 Specific Trial Designs 8 2
  • 3. Introduction – Efficacy Guidelines : The work carried out under the efficacy heading is all about design, conduct, safety and reporting of the clinical trials. It also cover some other aspects like novel type of medicine derived from biotechnological process and the use of pharmacogenomics to produce better targeted medicines. E4 – Dose response Information to support Drug Registration This guideline was developed within the Expert Working Group (Efficacy) of ICH for the Registration of Pharmaceuticals for Human Use and has been subject to consultation by the regulatory parties, in accordance with the ICH process. This ICH harmonized guideline was finalized under step 4 in March 1994. This guideline was published in the Federal Register on November 9, 1994 (59 FR 55972) and is applicable to both drug and biological products. E4 – Dose response Information to support Drug Registration 3
  • 4. This document gives recommendations on the design and conduct of studies to access the relationship among dose, drug – concentration and clinical response given by drug. This information can give the appropriate starting dose, to adjust to the dosage need of particular patient need. Scope of E4 guideline Objectives of E4 guideline Knowledge of the relationship among dose, drug-concentration in blood and clinical response is imp for safety of patient It gives the common database globally to all regulatory agencies to provide an economical approach. 4
  • 5. To identify an appropriate starting dose To adjust dosage according to the needs of a particular patient, and a dose beyond which unacceptable side effects are observed. To prepare dosage and administration instructions in product labeling. Historically, drugs have often been initially marketed at excessive doses (sometimes with adverse consequences This situation has been improved by attempts to find the smallest dose with a detectable useful effect or a maximum tolerated dose Purpose of Dose-Response Information 5
  • 6. Use of Dose-Response Information in Choosing Doses A high starting dose, might be a poor choice for a drug with a small demonstrated separation between its useful and undesirable dose ranges Choice of starting dose may be affected by intersubject variability in pharmacodynamic response to a given blood concentration level, or by pharmacokinetic differences, such as nonlinear kinetics or pharmacokinetic drug-drug interactions. In dose-response information, it is important to identify, factors that lead to differences in pharmacokinetics of drugs among individuals, including demographic factors, other diseases,diet, concurrent therapies, or individual characteristics (e.g., weight, body habitus, other drugs, metabolic differences). In these cases, a lower starting dose would protect patients who obtain higher blood concentrations. 6
  • 7. Uses of Concentration-Response Data A drug can be safely and effectively given only with blood concentration monitoring, the value of concentration-response information is mandatory. An established concentration-response relationship is often not needed, but useful in below cases. (1) For ascertaining the magnitude of the clinical consequences, such as those due to drug-disease (e.g., renal failure) or drug-drug interactions; or (2) for assessing the effects of the altered pharmacokinetics of new dosage forms or new dosage regimens. Concentration-response information can also allow selection of doses (based on the range of concentrations they will achieve) most likely to lead to a satisfactory response. If the relationships between concentration and observed effects (e.g., an undesirable or desirable) are defined, the drug can be titrated according to patient response without further blood level monitoring. 7
  • 8. Problems with Titration Designs A study design widely used to demonstrate effectiveness utilizes dose titration to some effectiveness or safety endpoint. Such titration designs, without careful analysis, are usually not informative about dose- response relationships. In some cases, notably where an early results are essential, the titration-to-highest-tolerable- dose approach is acceptable, because it often requires a minimum number of patients. For example, the first marketing of zidovudine (AZT) for treatment of people with acquired immune deficiency syndrome (AlDS) was based on studies at a high dose; later studies showed that lower doses were as effective and far better tolerated. 8
  • 9. • The choice of the size of an individual dose is dependent with the frequency of dosing. • In general, when the dose interval is long compared to the half-life of the drug, attention should be directed to the pharmacodynamic basis for the chosen dosing interval. • Dose-response studies should take time into account in a variety of other ways. • Like the study period at a given dose should be long enough for the full effect to be realized, whether delay is the result of pharmacokinetic or pharmacodynamic factors. • The dose-response may also be different for morning versus evening dosing. • Similarly, the dose-response relationship during early dosing may not be the same as in the subsequent maintenance dosing period. Interactions between Dose - Response and Time 9
  • 10. II. OBTAINING DOSE-RESPONSE INFORMATION A. Dose-Response Assessment Should Be an Integral Part of Drug Development If dose-response information is built into the development process it can be accomplished with no loss of time and minimal extra effort compared to development plans that ignore dose-response. B. Studies in Life-Threatening Diseases • Parallel dose-response study designs with placebo, or placebo-controlled titration study designs (very effective designs, typically used in studies of angina, depression, hypertension, etc.) would not be acceptable in the study of some conditions, such as life-threatening infections or potentially curable tumors, sometimes relatively high doses of drugs are usually chosen to achieve the greatest possible beneficial effect rapidly. • In life threatening diseases drug developer should choose the best dose, dose- interval, better dose escalation steps and highest tolerated dose. 10
  • 11. C. Regulatory Considerations When Dose-Response Data Are Imperfect • Even well-laid plans are not invariably successful. • well-designed dose-response study may have utilized doses that were too high, or too close together, so that all appear equivalent. • In that case, there is the possibility that the lowest dose studied is still greater than needed to exert the drug's maximum effect. • An acceptable balance of observed undesired effects and beneficial effects can be marketed at one of the doses studied. • This decision would be easiest, if the drug had special value, if in case it have partly defined dose range, the dose finding can be done in post-marketing phase. 11
  • 12. D. Examining the Entire Database for Dose-Response Information • In addition to seeking dose-response information from studies specifically designed to provide it, the entire database should be examined intensively for possible dose- response effects. • The limitations imposed by certain study design features should, of course, be appreciated. For example, many studies titrate the dose upward for safety reasons. • As most side effects of drugs occur early and may disappear with continued treatment, this can result in a spuriously higher rate of undesirable effects at the lower doses. • If pharmacokinetic screening (obtaining a small number of steady-state blood concentration measurements) is carried out, or if other approaches to obtaining drug concentrations during trials are used, a relation of effects (desirable or undesirable) to blood concentrations may be detected. • The relationship may by itself be a convincing description of concentration-response or may suggest further study. 12
  • 13. III. STUDY DESIGNS FOR ASSESSING DOSE RESPONSE 1. General • The choice of study design in dose-response trials will depend on the phase of development, the therapeutic indication under investigation, and the severity of the disease in the patient population of interest. • In general, useful dose-response information is best obtained from trials specifically designed to compare several doses. • A comparison of results from two or more controlled trials with single fixed doses might sometimes be informative. • It is also possible in some cases to derive, retrospectively, blood concentration- response relationships from the variable concentrations attained in a fixed-dose trial. • Conducting dose-response studies at an early stage of clinical development may reduce the number of failed Phase 3 trials, speeding the drug development process and conserving development resources. 13
  • 14. • Pharmacokinetic information can be used to choose doses that ensure adequate spread of attained concentration-response values and eliminate overlap between attained concentrations in dose-response trials. • For drugs with high pharmacokinetic variability, a greater spread of doses could be chosen. Alternatively, the dosing groups could be sorted by adjusting for pharmacokinetic covariates or a concentration-controlled study could be carried out. • When the study endpoint is delayed, titration and simultaneous assessment of response is usually not possible, and the parallel dose-response study is usually needed. • Trials intended to evaluate dose- or concentration-response should be well-controlled, using randomization and blinding to assure comparability of treatment groups and to minimize bias, and should be of adequate size. 14
  • 15. B. Specific Trial Designs A number of specific study designs can be used to assess dose-response. The same approaches can also be used to measure concentration-response relationships. The following approaches have been shown to be useful ways of deriving valid dose- response information. 1. Parallel Dose-Response i. Randomization to several fixed-dose groups (the randomized parallel dose- response study) is simple in concept and is a design that has had extensive use and considerable success. ii. The fixed dose is the maintenance dose; patients may be placed immediately on that dose or titrated gradually (in a scheduled "forced" titration) to it if that seems safer. iii. In principle, statistically significant trend (upward slope) across doses can be established using all the data. iv. The parallel dose-response study gives group mean (population-average) dose-response, not the distribution or shape of individual dose-response curves. 15
  • 16. v. The factorial trial is a special case of the parallel dose-response study to be considered when combination therapy is being evaluated. vi. It is particularly useful when both agents are intended to affect the same response variable (a diuretic and another anti-hypertensive), or when one drug is intended to mitigate the side effects of the other. vii. These studies can show effectiveness of each component of the combination and, in addition, provide dosing information for the drugs used alone and together. 2. Cross-over Dose-Response i. A randomized multiple cross-over study of different doses can be successful if drug effect develops rapidly and patients return to baseline conditions quickly after cessation of therapy. ii. Problems of all cross-over studies are ,it can have analytic problems if there are many treatment withdrawals; it can be quite long in duration for an individual patient; and there is often uncertainty about carry-over effects. 16
  • 17. iii. The advantages of the design are that each individual receives several different doses so that the distribution of individual dose-response curves may be estimated. 3. Forced Titration i. A forced titration study where all patients move through series of rising doses, is similar in concept to a randomized multiple cross-over dose- response study, except that assignment to dose levels is ordered, not random. ii. A critical disadvantage is that, by itself, this study design cannot distinguish response to increased dose from response to increased time on drug therapy or a cumulative drug dosage effect. iii. This design can give a reasonable first approximation of both population- average dose response and the distribution of individual dose-response relationships if the cumulative (time-dependent) drug effect is minimal and the number of treatment withdrawals is not excessive 17
  • 18. 4. Optional Titration (Placebo-Controlled Titration to Endpoint) i. In this design, patients are titrated until they reach a well-characterized favorable or unfavorable response, defined by dosing rules expressed in the protocol. ii. This approach is most applicable to conditions where the response is reasonably prompt and is not an irreversible event, such as stroke or death. iii. It is important, in this design, to maintain a concurrent placebo group to correct for spontaneous changes iv. Like other designs that use several doses in the same patient, this design may use fewer patients than a parallel fixed-dose study of similar statistical power and can provide both population average and individual dose-response information. v. Like the forced titration design, it can be used to study a wide dose range and, with a concurrent placebo group, can provide clear evidence of effectiveness. 18
  • 19. IV. GUIDANCE AND ADVICE 1. Dose response data are desirable for almost all new chemical entities entering the market. These data should be derived from study designs that are sound and scientifically based; a variety of different designs can give valid information. 2. The information obtained through targeted studies and analyses of the entire database should be used by the sponsor to: • Identify a reasonable starting dose, with specific adjustments for patient size, gender, age, concomitant illness, and concomitant therapy. • Identify reasonable, response-guided titration steps, and the interval at which they should be takenThese steps would be based either on the shape of the typical individual's dose-effect curves and the time needed to detect a change in these effects. • Identify a dose, or a response (desirable or undesirable), beyond which titration should not ordinarily be attempted. 19
  • 20. 3. Dose-response data for both beneficial and undesirable effects may provide information that allows approval of a range of dose. 4. It is prudent to carry out or concentration-response studies early in development in order to avoid failed Phase 3 studies. 5. Regulatory agencies and drug developers should be open to new approaches and to the concept of reasoned and well-documented exploratory data analysis of existing or future databases in search of dose-response data. 6. Adjustment of drug exposure levels might be made on the basis of reliable information on drug-taking compliance. In all of these cases, one should always be conscious of confounding, i.e., the presence of a factor that alters both the refigured dose and response or that alters both blood level and response, compliance and response, etc 20
  • 21. 7. Approval decisions are considered with degree of effectiveness shown, imperfections in the database may be acceptable with the expectation that further studies will be carried out after approval. 21
  • 22. V. REFERENCES 1. Federal Register. Vol. 59, No. 216, Wednesday, November 9, 1994, pages 55972-55976 2. https://www.ich.org/page/efficacy-guidelines 22