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Preparing an eSubmission based on multiple trials, some of which are ongoing
– challenges for statistical programming
Åsa Carlsheimer, Statistical Programming Director
PhUSE October 9-11, 2011
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Outline
1. Introduction 2. Data standards 3. Data repository 4. Output programs 5. Planning and communication 6. Key message
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Introduction
Drug FER123 was approved by FDA and EMEA in 2009
Different dose and longer treatment duration now investigated
1 pivotal phase III trial
17 completed phase II-IIIb trials
8 ongoing phase IIIb trials
Scope of new eSubmission
Combined safety & efficacy analysis for FER123
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Data standards
l Implementation – Early 2009 based on draft CDISC ADaM 2.1
l Maintenance – All new trials across all projects and therapeutic areas
l Benefits – One common standard – Customization, recognition, facilitating communication
with other functions – Easy to integrate in a repository – Submission ready
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. . . . .
Study 1
Study 10
Study 2
Study Analysis Database
Compound Analysis Database (CAD)
*.SAS
Study 11
Study 12
Study 17
CAD
Studies included in the previous
submission
Migration process
CAD
Migration to ADaM
*.SAS Validation of repository
Integrate repository
*.SAS
Submission repository
MedDRA dictionary
Harmonize MedDRA codes
Study 18
Study 14
Study 25
Cut-off
*.SAS
Repository Database
*.SAS
Create combined treatment codes
Data repository
. . . .
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Repository learnings
Ø Discuss expectations on level of data cleaning for cut-off
Ø Include time for coding of ongoing trials after cut-off in timelines
Ø Agree on version of MedDRA dictionary for pivotal trial and Integrated Summary of Safety (ISS)
Ø Document outcome of repository validation together with actions and responsible programmer
Ø Easy to underestimate the resources & time needed for cleaning up the ongoing trials
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ISS/ISE Statistical Analysis Plan (SAP)
Output specification
*.SAS
Grouping macros
*.SAS Standard programs
*.SAS
ISS/ISE unique programs
*.TAB *.CGM
ISS/ISE output
Subgroups (age, weight, race, geographic region, disease severity)
Pooled trials (phase 2/3, phase IIIb), dose/regimens, controlled/uncontrolled
Output program set-up
(>1100 TLFs)
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Output program learnings
Ø Include an option to present data by multiple trials when developing standard programs (for ISS/ISE)
Ø >1100 TLFs need to split in to several documents (consider numbering)
Ø Test transfer to eCTD tool (pdf-size, templates, bookmarks, hyperlinks)
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Planning and communication
Submission team 13 statistical programmers (including biostatisticians and off-shore)
Weekly internal programming/biostat meetings (status, issues, validation strategies, assign tasks to person)
One representative in the regulatory led cross-functional team
Structured programming approach using planning tools
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Delivery times after database lock
ü Pivotal phase III trial (500 TLF) within 1 week
ü ISE (200 TLF) within 2 weeks
ü ISS (900 TLF) within 3 weeks
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Key message To prepare for a submission based on multiple trials, some of which are ongoing is a complex and challenging task!
Utilizing the following will facilitate the work and ensure timely deliveries:
• Implemented ADaM standards
• Maintaining data repository
• Clear programming and validation strategy
• Good communication & planning
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Data format considerations
Read eCTD to FDA “Study Data Specifications 1.5”
Define file (metadata and logic) generated from ADaM specifications in Word
Format SAS transport files *.xpt maximum 400 MB
Ferring eCTD system limitation of 100 MB
ADLB > 830 MB = ADLB1, ADLB2,----,ADLB10
Split by subject, site, X number of observations?