---
title: "Introduction to bootf2"
author: "Zhengguo XU"
date: "`r format(Sys.Date())`"
output: 
  rmarkdown::html_vignette:
    keep_md: true
    toc: false
    toc_depth: 3
    fig_width: 7
    fig_height: 4.5
  highlight: "tango"
bibliography: ref.bib
notes-after-punctuation: false
link-citations: yes
csl: ref.csl
vignette: >
  %\VignetteIndexEntry{Introduction to bootf2}
  %\VignetteEngine{knitr::rmarkdown}
  %\VignetteEncoding{UTF-8}
---

```{r setup0, include=FALSE}
knitr::opts_chunk$set(
  collapse = TRUE,
  comment = "#"
)
```

```{r setup, echo=FALSE}
library(bootf2)
```

```{r longlink, echo=FALSE}
ema1 <- "https://www.ema.europa.eu/en/documents/scientific-guideline/"
ema2 <- "guideline-investigation-bioequivalence-rev1_en.pdf#page=21"
ema3 <- paste0(ema1, ema2)
fda  <- "https://www.fda.gov/media/70936/download#page=12"
fda2 <- "https://www.gmp-compliance.org/files/guidemgr/UCM070246.pdf#page=12"
fdamr <- "https://www.fda.gov/media/70956/download#page=37"
canada1 <- "https://www.canada.ca/en/health-canada/services/drugs-health"
canada2 <- "-products/drug-products/applications-submissions/guidance"
canada3 <- "-documents/post-notice-compliance-changes/quality-document/"
canada4 <- paste0(canada1, canada2, canada3, "guidance.html#a5")
ca1 <- "https://www.canada.ca/en/health-canada/services/drugs-health-"
ca2 <- "products/drug-products/applications-submissions/guidance-documents/"
ca3 <- "canadian-reference-product-guidance.html#app2"
ca4 <- paste0(ca1, ca2, ca3)
who1 <- "https://apps.who.int/iris/bitstream/handle/10665/258720/"
who2 <- "9789241210034-eng.pdf?sequence=1&isAllowed=y#page=244"
who3 <- paste0(who1, who2)
#anvisa1 <- "https://bvsms.saude.gov.br/bvs/saudelegis/anvisa/2010/"
anvisa1a <- "https://web.archive.org/web/20190806045126/http://bvsms.saude."
anvisa1b <- "gov.br/bvs/saudelegis/anvisa/2010/res0031_11_08_2010.html"
anvisa2  <- paste0(anvisa1a, anvisa1b)
```

## Introduction

Because of the prominent roles dissolution profiles played in the pharmaceutical
industry, it is important to have a reliable method to compare dissolution 
profiles. Over the years, many model-dependent and -independent methods were
developed; but owing to its simplicity, similarity factor $f_2$ is the most
widely used one, and it is recommended in many regulatory guidelines
[@EMA-2010-INV.BE; @USFDA-1997-08-DISSO.IR.SOLID.ORAL; @HealthCanada-2017;
@WHO-2017; @MHLW2012; @ANVISA2010; @CDENMPA-2016].

However, to apply the $f_2$ method, several conditions have to be fulfilled due
to certain drawbacks associated with it. When $f_2$ method is not applicable for
the failure of fulfilling regulatory conditions, other methods should be used. 

The package `bootf2` was developed to compare the dissolution profiles using
confidence interval of $f_2$ by bootstrap method as recommended recently by 
several regulatory agencies [@EMA-2018-09-QA.MSD.DISSO; @Davit-2013-03-BA;
@Lum-2019-05-WS; @Mandula-2019-05-WS].

There are 4 main functions in the package:

1. `sim.dp()` to simulate dissolution profile using mathematical models or
    multivariate normal distribution.
1. `calcf2()` to calculate similarity factor $f_2$ according to different
    regulatory rules.
1. `sim.dp.byf2()` to find a dissolution profile that, when compared to a given
    reference profile, has $f_2$ value equal to the predefined target $f_2$.
1. `bootf2()` to estimate the confidence intervals of $f_2$s using bootstrap 
    method.  

The details of functions are explained in their respective manual and vignettes.
Some common topics are discussed in this document. 


## Regulatory rules for $f_2$

To apply the traditional $f_2$ method, several conditions have to be fulfilled.
Unfortunately, different regulatory agencies described those conditions 
differently. Some of the conditions are same across different guidelines, such
as 1.) *same dissolution condition* and *same time points* for both test and
reference, 2.) use *12 units*, and 3.) use *at least 3 time points* for the
calculation of $f_2$, while others are either slightly different, or are 
actually the same but different interpretation exist due to the ambiguous
wording in the guideline.

The last two scenarios are detailed below with direct quotes from guidelines 
(with hyper links) as they affect the implementation of the functions 
`calcf2()`.

4. *20%/10% CV Rule*

    - *EMA* [@EMA-2010-INV.BE]: 
    
    > ["The relative standard deviation or coefficient of variation
      of any product should be less than 20% for the first point and
      less than 10% from second to last time point."](`r ema3`)
      
      If the the time points in the dissolution is 5 min, 10 min, 
      15 min, ..., strict interpretation is that the 20% CV is for the
      first time point 5 min only. From time point 10 min onward, 
      the CV% criteria is 10%. From an unofficial communication with an
      EU regulator, the practical use is 20% CV for all time points till 
      10 min, 10% for the rest points. It seems that, due to high 
      variability asociated to the early point, many companies deleted 
      5 min time points from their dissolution profile, even though 
      this point should be presented according to their method.
      Obviously this is a kind of bad practice, so the relaxed criterion
      of 20% CV up to 10 min can be considered as encouragement for 
      the company not to delete any data points.
      
    - *US FDA* [@USFDA-1997-08-DISSO.IR.SOLID.ORAL]: 
    
    > ["To allow use of mean data, the percent coefficient of variation
      at the earlier time points (e.g., 15 minutes) should not be more
      than 20%, and at other time points should not be more than 
      10%."](`r fda`)
      
      While the guidance indicating 15 min as an example for cutting
      points of earlier points (20% CV), FDA seems take more liberal
      approach. In an unofficial communication, an example of dissolution 
      profiles having 5, 10, 20, 30 min, ..., time points was given where
      the first 2 *or 3 points* (that's 20 min!) having CV% within 10% 
      and 20%. In such cases, FDA will review thew data for test and
      reference, but it is likely that the traditional $f_2$ method could
      still be used.
      
    - *Health Canada*: 
      
      The older guidance [@HealthCanada-2017] states that:
    
    > ["To use mean data, the % coefficient of variation at the first 
      time point should not be more than 20% and at other time points 
      should not be more than 10%."](`r ca4`)
      
      So that would be the same as the EMA's guideline when interpreted 
      strictly. However, the newer guidance [@HealthCanada-2019-07-Quality]
      has the following statement:
      
    > ["To use mean data, the % coefficient of variation at the earlier
      point should be not more than 20% and at other time points should 
      be not more than 10%."](`r canada4`)
      
      So it is not clear right now which time points could be considered 
      as *earlier points*. In the function `calcf2()`, the same rule as 
      EMA's was implemented. 
      
    - *WHO* [@WHO-2017]:
    
    > ["To use mean data the percentage coefficient of variation at
      time-points up to 10 minutes should be not more than 20% and at
      other time-points should be not more than 10%;"](`r who3`)
      
      This is the same as the "*new*" interpretation of the EMA's guideline.
      
    - *Brazil* [@ANVISA2010]:
    
    > ["para permitir o uso de médias, os coeficientes de variação para
      os primeiros pontos de coleta não podem exceder 20%. Para os demais
      pontos considera-se o máximo de 10%. São considerados como primeiros
      pontos de coleta o correspondente a 40% do total de pontos coletados.
      Por exemplo, para um perfil de dissolução com cinco tempos de coleta,
      consideram-se primeiros pontos os dois primeiros tempos de 
      coleta."](`r anvisa2`)
      (Translation: to allow the use of averages, the coefficients of 
      variation for the first collection points cannot exceed 20%. 
      For the other points, a maximum of 10% is considered. The first
      collection points correspond to 40% of the total collected points.
      For example, for a dissolution profile with five collection times,
      the first two collection times are considered first points.)
      
The next condition caused different interpretations among many. 

5. *More than 85% dissolution time points*

    - *EMA* [@EMA-2010-INV.BE]: 
    
    > ["Not more than one mean value of > 85% dissolved for any of the
      formulations."](`r ema3`)
      
    - *US FDA* [@USFDA-1997-08-DISSO.IR.SOLID.ORAL]: 
    
    > ["Only one measurement should be considered after 85% dissolution
      of both the products."](`r fda`)
      
      There is no ambiguity associated with EMA's rule. But because of
      the phrase "*both the products*" in FDA's guidance, many 
      interpreted that all time points should be included until both 
      test and reference dissolved more than 85%. For example, 
      with the following dissolution profiles, many would interpret 
      that while time points 5, 10, 15, and 20 min should be included 
      according to EMA's rule, *all time points* should be included 
      according to FDA's rule because both test and reference dissolve 
      more than 85% only at 60 min, not at earlier points. 
      
      
      ```{r fda85rule01, echo=FALSE}
       fda85 <- data.frame(Time = c(5, 10, 15, 20, 30, 45, 60),
                    Test = c(7, 15, 50, 69, 82, 84, 86),
                    Ref = c(10, 20, 55, 86, 90, 95, 97))
       knitr::kable(fda85, booktabs = TRUE)
      ```

      However, this is a misinterpretation. Because if this is true, 
      then there will be 4 time points included in the reference profile
      where dissolution is more than 85%, which is in direct
      contradiction to the same sentence that "*Only one measurement 
      should be considered after ...*". 
      
      In an unofficial communication using this example, an FDA staff
      confirmed that only the first 4 time points would be used. In
      other words, the same as EMA's rule.
      
    - *Health Canada* [@HealthCanada-2019-07-Quality]: 
      
    > ["Because f2 values are sensitive to the number of dissolution time
      points, only one measurement should be considered after 85% 
      dissolution of the product."](`r canada4`)
      
      
    - *WHO* [@WHO-2017]:
    
    > ["a maximum of one time point should be considered after 85%
      dissolution of the reference (comparator) product has been 
      reached;"](`r who3`)
      
      If reference dissolves faster than test does, WHO's rule would 
      be the same as the EMA/FDA rule; if not, then there might be
      several time points with more than 85% dissolved for test product. 
      This would be different from EMA/FDA approach, but at least the 
      guideline is very clear and leaves no room for ambiguity.
      
    - *Brazil* [@ANVISA2010]:
    
    > ["para fins de cálculo F2, incluir apenas um ponto da curva 
      após ambos os medicamentos atingirem a média de 85% de 
      dissolução;"](`r anvisa2`)
      (Translation: for F2 calculation purposes, include only one 
      point on the curve after both drugs average 85% dissolution;)

    The phrasing is very similar to FDA's so it could also open to be 
    misinterpreted. However, with the same logic as discussed above, 
    ANVISA's rule should also be the same as EMA's.
    
    To summarize, EMA, US FDA, Canada, and Brazil should have the same 
    rule in this regard; only WHO has slightly different rule. 

There is another regulatory scenario regarding the use of $f_2$, or rather,
the *not use* of it.

6. *When $f_2$ is unnecessary* 

    For immediate-release formulation, sometimes it is *unnecessary 
    to calculate $f_2$* and the profiles can still be declared similar
    if the products dissolve quick enough, typically more than 85% at
    15 min. 

    - *EMA* [@EMA-2010-INV.BE]: 
    
    > ["For immediate release formulations, ..., Where more than 85% of 
      the drug is dissolved within 15 minutes, dissolution profiles may
      be accepted as similar without further mathematical
      evaluation. "](`r ema3`)
      
    - *US FDA* [@USFDA-2017-12-WAIVER.BABE.IR.BCS]: 
    
    > ["In addition, when both test and reference products dissolve 
      85 percent or more of the label amount of the drug in 15 minutes
      using all three dissolution media recommended above, the profile
      comparison with an f2 test is unnecessary."](`r fda2`)
      
      
    - *Health Canada* [@HealthCanada-2019-07-Quality]: 
      
    > ["If the individual data for both the test and reference 
      products show more than 85% dissolution within 15 minutes, 
      the profiles are considered similar (no calculations are 
      necessary)."](`r canada4`)
      
      Canadian rule is stricter than EMA's and FDA's since the latter 
      two use mean value while the former use individual data.
      
      
    - *WHO* [@WHO-2017]:
    
    > ["If both the test and reference (comparator) products show 
      more than 85% dissolution in 15 minutes the profiles are
      considered similar (no calculations required)."](`r who3`)
      
      
    - *Brazil* [@ANVISA2010]:
    
    > ["Quando a substância ativa apresentar alta solubilidade e a 
      formulação for de liberação imediata, apresentando dissolução 
      muito rápida para ambos os medicamentos, o fator F2 perde o seu
      poder discriminativo e, portanto, não é necessário calculá- lo.
      Nesses casos deve-se comprovar a dissolução muito rápida dos
      produtos, por meio do gráfico da curva, realizando coletas em,
      por exemplo: 5, 10, 15, 20 e 30 minutos. O coeficiente de variação
      no ponto de 15 minutos que não pode exceder 10%."](`r anvisa2`)
      (Translation: When the active substance presents high solubility
      and the formulation is immediate release, presenting very fast
      dissolution for both drugs, the F2 factor loses its discriminative 
      power and, therefore, it is not necessary to calculate it. 
      In these cases, the very fast dissolution of the products must be 
      proved by means of the dissolution curve, carrying out collections
      in, for example: 5, 10, 15, 20 and 30 minutes. The coefficient of 
      variation at the 15-minute point that cannot exceed 10%.)

Another point worth mentioning, even though it is not related to the 
calculation of $f_2$, is a scenario described in US FDA's SUPAC-MR
guidance [@USFDA-1997-09-SUPAC.MR.CMC.DISSO.BE]:

> ["Also, the average difference at any dissolution sampling time point
  should not be greater than 15% between the changed drug product and 
  the biobatch or marketed batch (unchanged drug product) dissolution
  profiles."](`r fdamr`)

This rule has not been implemented in the function `calcf2()`. 


## References

.
