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Statistical Considerations in Setting Product Specifications a

a

a

Xiaoyu Dong , Yi Tsong & Meiyu Shen a

Division of Biometrics VI, Office of Biostatistics, Office of Translational Sciences, Center for Drug Evaluation and Research, US Food and Drug Administration Accepted author version posted online: 30 Oct 2014.

Click for updates To cite this article: Xiaoyu Dong, Yi Tsong & Meiyu Shen (2014): Statistical Considerations in Setting Product Specifications, Journal of Biopharmaceutical Statistics, DOI: 10.1080/10543406.2014.972511 To link to this article: http://dx.doi.org/10.1080/10543406.2014.972511

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Statistical Considerations in Setting Product Specifications Xiaoyu Dong, Yi Tsong, Meiyu Shen

Division of Biometrics VI, Office of Biostatistics, Office of Translational Sciences,

Food and Drug Administration, 10903 New Hampshire Ave, Silver Spring, MD 20993;

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Center for Drug Evaluation and Research,

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Email: [email protected]

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This article reflects the views of the author and should not be constructed to represent Food and Drug Administration’s views or policies.

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ABSTRACT

According to ICH Q6A (1999), a specification is defined as a list of tests, references to analytical

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Xiaoyu Dong, PhD,

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Correspondence should be addressed to:

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Division of Biometrics VI, Office of Biostatistics, Office of Translational Sciences, Center for Drug Evaluation and Research, US Food and Drug Administration

procedures, and appropriate acceptance criteria, which are numerical limits, ranges, or other criteria for the tests described. For drug products, specifications usually consist of test methods and acceptance criteria for Assay, Impurities, pH, Dissolution, Moisture, and Microbial Limits, etc., depending on the dosage forms. They are usually proposed by the manufacturers, and

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subject to the regulatory approval for use. When the acceptance criteria in product specifications cannot be pre-defined based on prior knowledge, the conventional approach is to use data from a limited number of clinical batches during the clinical development phases. Often in time, such

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acceptance criteria is set as an interval bounded by the sample mean plus and minus two to four

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standard deviations. This interval may be revised with the accumulated data collected from

released batches after drug approval. In this paper, we describe and discuss statistical issues of

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including reference interval, (Min, Max) method, tolerance interval, and confidence limit of

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percentiles. We also compare their performance in terms of interval width and the intended coverage. Based on our study results and review experiences, we make some recommendations on how to select appropriate statistical methods in setting product specifications to better ensure the product quality.

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Key Words: Specification; Quality Control; Tolerance Interval; Confidence limit; Percentile.

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1.INTRODUCTION

Specifications are critical quality standards and requirements for drug substances and

drug products. According to ICH Q6A, a specification is defined as a list of tests, references to

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commonly used approaches in setting or revising specifications (usually tighten the limits),

analytical procedures, and appropriate acceptance criteria, which are numerical limits, ranges, or other criteria for the tests described. For drug products, specifications usually consist of test methods and acceptance criteria for Assay, Impurities, pH, Dissolution, Water Content, and Microbial Limits, et. al. depending on the dosage form. The testing results of these quality

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attributes from the sample will be compared to the acceptance criteria. If all the results are within the acceptance criteria, then the product batch can be released. Otherwise, thorough investigation may be needed to identify the root cause of out-of-specification (OOS) observations. Thus,

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specifications are key elements to ensure the product quality as well as the consistency of the

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manufacturing process.

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subject to regulatory approval for use during the new drug application process. When setting specifications, there are many important points to be considered, such as dosage form, clinical

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efficacy and safety, process controls, batch analyses, analytical procedures. Many literatures provide excellent introduction and overview of this area, including EBE Concept Paper (2013), EMA (2011), DiFeo (2003), Kumar and Palmieri (2009). Specifically, for some quality attributes, their specifications can be pre-specified by prior knowledge or clinical justification.

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For a few other quality attributes, specifications are given by USP general chapters. For example,

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the specification for content uniformity is provided USP; and the specification for dissolution is provided by USP. When no prior information is available, statistical analysis plays an important

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role in setting specifications. In this case, specification is often set as an interval bounded by the sample mean plus and minus two to four standard deviations. Sometimes, minimum (Min) and maximum from the sample are also used to establish specifications. As mentioned earlier, the

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In general, specifications are proposed by manufacturers at the Phase III of development, and

original specification is usually determined using a limited number of clinical batches in Phase

III. Thus, the data may not be fully representative of the product and usually results in unpractical intervals. For this reason, after drug approval, original specifications may be revised by statistical analysis of the accumulated data collected from released batches or stability studies.

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This post-marketing change is also subject to the approval from regulatory agencies. Tolerance interval method is a commonly used method in revision of specifications. In short, a tolerance interval is an interval cover at least p% of the population with a given confidence level. This

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concept was introduced in earlier work in Wilks (1941), Wilks (1942), and Wald (1943) for

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normal distributions. However, tolerance interval approaches in general lead to over-wide intervals. Thus, in this paper, we also consider an alternative method, confidence limits of

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specifications. For example, Wessels, et. al. (1997) presents a confidence limit based statistical

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approach to utilize stability data and a given shelf life in setting specifications. Yang (2013) presents a multivariate statistical model to establish specifications for correlated quality attributes.

In order to identify proper statistical methods to set meaningful and reasonable specifications,

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this paper provides in depth discuss on statistical properties of above commonly used methods,

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including Mean +/- k∙SD, (Min, Max), Tolerance Interval, and confidence limits of percentile. Then, these methods are compared with each other in terms of interval width and coverage for

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large sample sizes through theoretical and simulation studies. We also address the issues of consumer’s risk and manufacturer’s risk. Conclusions are presented in the last section.

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percentiles, in order to avoid the over-wide problem. Other methods are also proposed in setting

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2.

STATISTICAL

METHODS

FOR

SETTING

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SPECIFICATION

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For a given quality attribute, assume the testing results from batches, X1, X2, …, Xn, are random samples from a normal distribution with mean µ and variance σ2. If the desired specification can

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0< p 50. These observations show that confidence limits of percentiles is a more stringent method than the tolerance interval method. It can reduce the risk of passing low quality product and thus better assure the product

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quality.

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SAMPLES

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To set specifications which are close to the intended interval, all methods discussed in this paper are problematic when sample size is small. As presented earlier, for small samples, reference interval and (Min, Max) cannot provide assurance on the coverage due to the nature of these two intervals. Tolerance interval gives a too-wide interval with inflated consumer’s risk. Conversely,

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the confidence limits of percentiles provide a narrower interval with well controlled consumer’s risk. These findings are consistent with the fundamental principles of statistics as well as the

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nature of each method.

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Can large sample size solve all these problems? To answer this question, we compare the performance of above methods when the sample size n is no less than 30. Considering (Min, Max) is not suitable to set specifications for small and large samples, we will not include this

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3. COMPARISON OF METHODS ON LARGE

method in our following discussion in this section. With n = 30, 50, 100, and 500 and the

intended coverage of 95%, Figure 7 shows the box plots of coverage from 105 Monte Carlo

simulations from the standard normal distribution using Reference Interval (RI), (97.5%, 95%) one-sided Tolerance Interval (TI) and 90% Confident Limits of Percentiles (CL of Perc.). From

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Figure 7, we have following findings. First, a coverage distribution obtained from the reference interval method is almost symmetric about the target value of 95% when n = 500 with much reduced variability. Second, in general, the coverage from the tolerance interval method is the

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highest among the all methods and larger than the target value most of time. Third, the coverage

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from the confidence limits of percentiles is the lowest in general and is lower than 95% mostly.

Although for n = 500, all methods produces similar results which are all close to 95%, the above

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We also plot the percentiles of the interval limits in Figure 8 using the three methods. As can be

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seen, the interval obtained from tolerance interval method is the widest, while that from the confidence limits of percentiles is the tightest. As expected, interval limits from all three methods are similar and also are very close to the targeted interval of (-1.96, 1.96) when n = 500.

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Moreover, variability of the interval limits are similar.

To further evaluate the performance of each method, we study two types of misclassification

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probabilities. The first one is the inflation of consumer’s risk which is computed as the

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probability of been classified as normal data when it is actually an OOS data. The other one is the inflation of manufacturer’s risk defined as the probability of been classified as OOS data when it is actually a normal data. Please note, these two types of inflation do not include the

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patterns are still presented.

parts caused by sampling plans. By the above definitions, these two probabilities can be formulated as (6) and (7), respectively.

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Pinflate.C= I (θˆlow < θ1 ) Pr(θˆlow < X < θ1 | θˆlow ) + I (θˆup > θ 2 ) Pr(θ 2 < X < θˆup | θˆup )

(6)

Pinflate.M= I (θˆlow > θ1 ) Pr(θ1 < X < θˆlow | θˆlow ) + I (θˆup < θ 2 ) Pr(θˆup < X < θ 2 | θˆup )

(7)

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Applying (6) and (7), Figures 9 and 10 provide the box plots of inflation rate of consumer’s risk

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and manufacturer’s risk for n = 30, 50, 100, and 500 using the same simulation scenarios as in

Figures 7 and 8. More specifically, the inflation of consumer’s risk is computed via the following

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Step 1: Generate X ~ N (0,1/ n) , and S 2 ~ χ n2−1 / (n − 1) independely;

Step 2: Compute the specification interval ( θˆlow , θˆup ) based on a given method;

1 Step 3: Let the underlying true specification interval be (θ1 , θ 2 ) , if θˆlow < θ1 , then I (θˆlow < θ1 ) =

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and compute the proportion of misclassification due to the underestimate of the lower specification limit as (1 − P) / 2 − Φ (θˆlow ) . Here, we use P as the targeted central coverage.

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Similarly computation is applied to obtain the value of I (θˆup > θ 2 ) Pr(θ 2 < X < θˆup | θˆup ) . Step 4: Obtain Pinflate.C from the results in (2); Step 5: Repeat Steps 1 to 4 for a large number of times, say 105 times, to obtain the boxplot.

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simulation scheme. Here, we use P as the targeted central coverage.

A similar simulation scheme can be used to compute the inflation of manufacturer’s risk defined in (7).

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4. SAMPLE SIZE CALCULATION In this section, we propose a sample size calculation method in the context of setting

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specifications. Particularly, if the intended central coverage is 100p%, say 95%, then the sample size can be obtained so that the probability of the estimated coverage within an acceptable range

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as confidence level.

PX , S  p − δ ≤ PX ( X − K .S < X < X + K .S | X , S ) ≤ p + δ  ≥ γ

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(8)

, where the factor K depends on the statistical interval applied. For reference interval, K = Z(1+p)/2; for tolerance interval K= k= tn −1,γ ( Z (1+ p )/2 n ) / n ; and for confidence limits of percentiles

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K =CZ (1+ p )/ 2 − Z1−α 1/ n + Z (12 + p )/ 2 (C 2 − 1) . Similar idea of such sample size calculation has been

discussed in earlier work of Faulkenberry and Weeks (1968), Faulkenberry and Daly (1970),

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Guenther (1972) and Krishnamoorthy and Mathew (2009). Extending the derivation in

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Krishnamoorthy and Mathew (2009), it can be shown that equation (8) is equivalent to   χ1,2 p −δ ( X n2 ) χ1,2 p +δ ( X n2 )   2 < < EX n  P  U   ≥ γ n  kn2 kn2    

(9)

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of (p – δ, p + δ) is at least γ, where δ is a small number between 0 and 1 and γ can be interpreted

Where Xn ~ N(0, 1/n), U n2 ~ χ n2−1 / (n − 1) , χ df2 is the chi-square distribution with degrees of freedom of df, and χ df2 , p (θ ) is the 100p% percentile of χ df2 and non-centrality parameter of θ. Then the sample size n can be determined as the smallest number satisfying the inequality (9).

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5. SUMMARY The purpose of this paper is to identify proper statistical methods for setting a specification

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interval which is close to the intended interval with target coverage. This is an important part in the product control strategy to assure the product quality and manufacturing process consistency.

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impact on product quality at release and in-process control are considered in this paper. One is the coverage; the other is the width of the interval. In this paper, we discussed three common

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approaches, including reference interval, (Min, Max), and tolerance interval. We also propose an alternative method using confidence limits of percentiles. From our in-depth study and review experiences, we do not recommend using (Min, Max) to set specification. We also do not encourage change specifications using small samples. With relative large sample sizes, although

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all three other methods would generate similar results, tolerance interval mostly likely gives an interval wider than the intended and a most inflated consumer’s risk; while confidence limits of

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percentiles would have an interval slightly tighter than the intended and the least inflated

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consumer’s risk. Most importantly, all specifications need to be scientifically meaningful. REFERENCES

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To evaluate the suitability of common statistical methods, two critical aspects with a direct

(1)

S. Chakraborti and J. Li (2007): Confidence Interval Estimation of a Normal Percentile,

The American Statistician, 61:4, 331-336.

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(2)

Thomas, J. DiFeo. (2003). Drug product development: a technical review of chemistry,

manufacturing, and controls information for the support of pharmaceutical compound licensing activities. Drug Development and Industrial Pharmacy. 29: 939-958.

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ICH Guideline Q6A, “Specifications: test procedures and acceptance criteria for new drug

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(3)

substances and new drug procedures” chemical substances”. 1999

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EBE Concept Paper (2013), “Considerations in Setting Specifications”, European

Biopharmaceutical Enterprises.

EMA (2011), “Report on the expert workshop on setting specifications for biotech

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(5)

products”. European Medicines Agency, London, 9 September 2011. (6)

Guenther, W.C. (1972). Tolerance intervals for univariate distributions. Naval Research

(7)

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Logistic Quarterly, 19, 309-333.

Faulkenberry, G.D. and Daly, J.C. (1970). Sample size for tolerance limits on a normal

Faulkenberry, G.D. and Weeks, D. L. (1968). Sample size determination for tolerance

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(8)

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distribution. Technometrics, 12, 813-821.

limits. Technometrics, 43, 147-155.

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(4)

(9) Krishnamoorthy, K. and Mathew, T. (2009). Statistical tolerance regions – Theory, Applications and computations. Wiley series in probability and statistics. (10) Kumar, R. and Palmieri Jr, M. J. (2009). Points to consider when establishing drug product specifications for parenteral microspheres. The AAPS Journal. 12: 27-32.

17

(11)

Shen, M., Dong, X., Lee, Y. and Tsong, Y. (2014). Statistical evaluation of several

methods for cut point determination of immunogenicity screening assay. (Under peer review) (12)

Wald, A. (1943). An extension of Wilks’s method for setting tolerance limits. Annals of

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(13)

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Mathematical Statistics, 13, 45-55.

Wessels, P., Holz, M., Erni, F., Krummen, K., and Ogorka, J. (1997). Statistical

Wilks, S. S. (1941). Determination of sample sizes for setting tolerance-limit factors for

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(14)

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Development and Industrial Pharmacy. 23: 427-439.

normal distribution. Annals of Mathematical Statistics, 12, 91 – 96. (15)

Wilks, S. S. (1942). Statistical prediction with special reference to the problem of

(16)

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tolerance limits. Annals of Mathematical Statistics, 13, 400 – 409.

Yang, H. (2013). Setting specifications of correlated quality attributes through

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543.

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multivariate statistical modelling. Journal of Pharmaceutical Science and Technology. 67: 533-

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evaluation of stability data of pharmaceutical products for specification setting. Drug

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68%

87%

95%

99%

>99%

Z(1+p)/2

1

1.5

2

2.5

3

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p

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Table 1 – Percentiles for Commonly Used Coverage of the Standard Normal Distribution

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p% = 95%,

p% = 99%,

p% = 99.7%,

Z(1+p)/2 = 1.64

Z(1+p)/2 = 1.96

Z(1+p)/2 = 2.58

Z(1+p)/2 = 3.00

n = 10

0.5

0.55

0.68

n = 20

0.35

0.39

n = 30

0.28

n = 50

0.22

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0.47

0.53

0.38

0.43

0.24

0.3

0.33

0.21

0.23

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0.76

0.31

0.17

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n = 100

t

p% = 90%,

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Table 2 – Standard Deviation of X ± Z (1+ p )/2 × S for Various Values of Sample Size n and Intended Coverage of p

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Percentiles

n = 10

n = 20

n = 30

n = 50

n = 100

0%

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48.1

53.1

68.2

75.5

t

25%

79.3

83.8

85.4

86.7

87.8

89.3

50%

86.9

88.4

89

75%

92.4

100%

99.9

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89.6

89.9

91.5

91.2

90.4

99.5

99.2

98.2

97.5

92.6

n = 20

n = 30

n = 50

n = 100

n = 1000

27.2

46.9

64.7

75.2

84.3

92.6

25%

86.9

90.6

91.8

92.8

93.6

94.6

50%

92.9

94

94.3

94.6

94.8

95

n = 10

pt 0%

ce Zp = 1.96

85.9

91.9

Percentiles

p = 0.95,

n = 1000

92.1

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Zp = 1.64

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p = 0.9,

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Table 3 – Percentiles of Coverage of X ± Z p × S with Intended Coverage of 100p% based on 105 Monte Carlo Simulations from N(0,1)

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96.6

96.4

96.3

96.1

95.9

95.3

100%

100

99.9

99.8

99.5

99

96.8

Percentiles

n = 10

n = 20

n = 30

n = 50

n = 100

n = 1000

0%

36.1

65.5

77.5

86.5

93.7

98.1

25%

95.4

97.3

97.8

50%

98.3

75%

99.5

100

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98.9

98.8

98.9

99

99

99.4

99.4

99.3

99.3

99.1

100

100

99.9

99.5

100

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100%

98.5

98.7

ed

Zp = 2.58

98.2

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p = 0.99,

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75%

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n = 10

n = 30

n = 50

n = 50

n = 500 n = 1000

90%

1.64

2.90

2.21

2.06

1.92

1.76

95%

1.96

3.40

2.61

2.43

2.28

2.09

99%

2.58

4.39

3.38

3.16

99.7%

3.00

5.01

us 2.97

M an 3.62

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pt

ed

3.87

23

1.72

t

Z(p+1)/2

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100p%

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Table 4 – One-sided (β, 95%) Tolerance Factors k for a given intended central coverage of 100p%and sample size n with β = (1+p)/2

3.40

2.05

2.74

2.69

3.15

3.10

Table 5 – Percentiles of Coverage of the One-sided (97.5%, 95%) Tolerance Interval from 105 Monte Carlo Simulations with a Intended Coverage of p = 95% n = 10

n = 30

n = 50

n = 100

n = 500

n = 1000

k = 3.40

k =2.61

k =2.43

k =2.28

k =2.09

k = 2.05

0%

51.4

77.2

83.9

88.4

93.0

93.7

5%

95

95.4

95.5

10%

97.3

25%

99.2

t

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us 95.2

95.2

96

95.5

95.4

97.9

97.4

96.8

95.9

95.7

98.9

98.3

97.6

96.3

96

100

99.4

98.9

98.2

96.7

96.3

95%

100

99.8

99.5

98.9

97.2

96.7

50%

ed

96.3

pt

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95.4

96.6

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75%

99.8

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Percentile

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Figure 1 – Plots of (Min, Max) of 10 Monte Carlo Simulations from 5 Random Samples from the Standard Normal Distribution

25

I

-2.8

2.07

H

-2.18

2.01

G

-2.38

2.22

F

-2.22

2.65

E

-2.04

1.79

D

-1.6

2.77

C

-2.3

B

-1.95

A

-2.19

2.46

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2.34 1.55

-2

0

2

(Min, Max)

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pt

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-4

t

2.33

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-1.85

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J

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Samples

Figure 2 – Plots of (Min, Max) of 10 Monte Carlo Simulations from 50 Random Samples from the Standard Normal Distribution

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Figure 3 – Plots of (Min, Max) of 10 Monte Carlo Simulations from 100 Random Samples from the Standard Normal Distribution

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Figure 4 – Box Plot of the Lower and Upper Bounds of Specification using (97.5%, 95%) Onesided Tolerance Interval from 105 Monte Carlo Simulations on the Standard Normal Distribution with a Targeted Interval of (-1.96, 1.96)

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Figure 5 – Box Plot of Coverage using 90% Confidence Limits of Percentiles

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from 105 Monte Carlo Simulations on the Standard Normal Distribution with a Targeted Coverage of p = 95%

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Figure 6 – Box Plot of the Lower and Upper Bounds of Specification Interval using 90% Confidence Limits of Percentile from 105 Monte Carlo Simulations on Standard Normal Distribution with a Targeted Interval of (-1.96, 1.96)

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Figure 7 – Box Plot of the Lower and Upper Bounds of Specification Interval from 105 Monte Carlo Simulations on the Standard Normal Distribution with a Targeted Coverage of 95% using Reference Interval (RI), (97.5%, 95%) One-sided Tolerance Interval (TI) and 90% Confidence Limits of Percentiles (CL of Perc.)

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Figure 8 – Box Plot of the Lower and Upper Bounds of Specification from 105 Monte Carlo Simulations on Standard Normal Distribution with a Targeted Interval of (-1.96, 1.96) using Reference Interval (RI), (97.5%, 95%) One-sided Tolerance Interval (TI) and 90% Confidence Limits of Percentiles (CL of Perc.)

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Figure 9 – Box Plots of the Inflation Rate of Consumer’s Risk from 105 Monte Carlo Simulations Generated on Standard Normal Distribution with a Targeted Interval of (-1.96, 1.96) using Reference Interval (RI), (97.5%, 95%) One-sided Tolerance Interval (TI) and Confidence Limits of Percentiles (CL of Perc.)

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Figure 10 – Box Plot of the Inflation Rate of Manufacturer’s Risk from 105 Monte Carlo Simulations on Standard Normal Distribution with a Targeted Interval of (-1.96, 1.96) using Reference Interval (RI), (97.5%, 95%) One-sided Tolerance Interval (TI) and Confidence Limits of Percentiles (CL of Perc.)

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Statistical considerations in setting product specifications.

According to ICH Q6A (1999), a specification is defined as a list of tests, references to analytical procedures, and appropriate acceptance criteria, ...
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