Where did the 80-125% bioequivalence criteria come from?

Most people involved in clinical pharmacokinetics are familiar with the 80-125% criterion. This criterion is used to compare two treatments with the purpose of evaluating if the treatments are bioequivalent. But, where did this come from? Why 80-125%? Why not 90-110%? or why not 80-120%?

Before we explain where 80-125% came from, let me explain the specifics of the criterion. When testing two treatments (e.g. 2 formulations, male vs. female, impaired vs non-impaired, etc.) often we would like to know if there is a difference in systemic exposure between the two treatments. The currently accepted test is often called “bioequivalence”.

The bioequivalence test states that we can conclude that two treatments are not different from one another if the 90% confidence interval of the ratio of a log-transformed exposure measure (AUC and/or Cmax) falls completely within the range 80-125%. It is important to note that we only conclude that the two treatments are “not different” from one another. We do not conclude that they are the “same”. However, if the 90% confidence interval falls outside the 80-125% range, we conclude that the two treatments are different from one another.

The basis for the 80-125% range is arbitrary … sort of. The FDA (and other regulatory bodies) “decided” that differences in systemic drug exposure up to 20% are not clinically significant. Now, that may lead you to believe that the appropriate range should be 80-120% (100% ± 20%) … but that isn’t the range. This is because the pharmacokinetic parameters for exposure (AUC and/or Cmax) are log-normally distributed. This means that if you transform these exposure parameters by taking the logarithm, you will get a normal distribution. Normal distributions are generally required for specific statistical tests. Thus, the symmetrical ± 20% has to be in the log-transformed space so that the statistical test of bioequivalence will be valid. The following table illustrates the different ratios, and the log-transformed difference.

Test Reference Ratio Percentage ln(ratio)
0.8 1.0 0.8 80% -0.223
0.9 1.0 0.9 90% -0.105
1.0 1.0 1.0 100% 0
1.1 1.0 1.1 110% 0.095
1.2 1.0 1.2 120% 0.182
1.25 1.0 1.25 125% 0.223

Starting at the lower limit (80%), we calculate the natural log of the ratio as -0.223. We can also see that the natural log of the ratio of 100% is 0. Therefore, a symmetrical distribution around 100% on the natural log transformed ratio would be ± 0.223. As shown in the table above, this corresponds to 125% at the upper limit. That’s how we get 80-125% as the target range that represents ± 20% systemic exposure.

This same principle can be used for other ranges that are commonly used for comparisons between 2 treatments where a wider range is acceptable.

Clinical Range ± ln(ratio) Acceptable Range
± 20% ± 0.223 80 – 125%
± 30% ± 0.357 70 – 143%
± 50% ± 0.693 50 – 200%

When conducting a study to compare two treatments, make sure you pick the correct range for the statistical test. All of these ranges are commonly accepted by regulatory agencies. In addition, if you need a custom range (e.g.  ± 25%), you can calculate it by determining the ln(ratio) of the lower limit, then creating the symmetrical ln(ratio) for the upper limit and back-calculating the untransformed upper limit.

Generics and bioequivalence

As the debate about health care in the United States continues forward, the term “generic drugs” has become rather commonplace. What are generic drugs? Are they safe to use? Why do we have them? and what is bioequivalence? All of these are common questions that I hope to answer with my post today.

What are generic drugs?

Generic drugs are “store-brand” drugs that are exact copies of the “name-brand” drug. If you have been shopping at the grocery store recently you might see the following two items in the breakfast isle:

Cereals

Toasted Oats (left) and Cheerios (right)

Cheerios (pictured on the right) is a name brand cereal made by General Mills. Toasted Oats, on the other hand, is a store-brand or “generic” cereal that is intended to have the look and feel of Cheerios. Although these cereals may be similar, they likely are not exactly the same. In fact, most people can tell a difference between the name-brand Cheerios and any store-brand cereal. There are differences because there is no requirement for the Toasted Oats to be identical to the Cheerios. Anyone can make a cereal that looks like Cheerios and sell it. This is why food companies guard their food recipes so closely. If someone gets their recipe it will be very easy to copy the food and potentially take market share away from the brand-name food.

In 1984, the “Hatch-Waxman Act” [Public Law 98-417] was signed into law in the United States. This law allowed the Food and Drug Administration (FDA) to regulate the marketing of “generic” drugs that are identical in composition and clinical efficacy as the “brand-name” drug. Thus, similar to the cereal example, a company can create a copy of the brand-name drug and sell it in the open market. But this copy must meet stringent criteria established by the FDA to ensure that the generic drug has the same clinical efficacy as the brand-name drug.

Are they safe to use?

As mentioned above, generic drugs are required to be identical to their brand-name counterparts in composition and clinical efficacy. Thus generic drugs are just as safe as their brand-name counterparts. In fact, the manufacturing controls required for generic drugs are identical to those required for brand-name drugs.

Why do we have generic drugs?

Generic drugs are designed to offer competition in the pharmaceutical market in the United States. After the patent protection period ends on a name-brand drug, other companies can make generic copies of those drugs. Often these “generic drug companies” are able to sell the generic drug at a significantly discounted price compared to the name-brand drug. This is possible because generic drug companies have much lower research and development costs. Often generic drugs acquire >90% of the market within 2-3 years after introduction.

What is bioequivalence?

The FDA decided that a comparison of drug levels in the systemic circulation would be the best way to show that a generic drug is identical to a brand-name drug. The type of analysis to show this is called bioequivalence. See my previous post for a definition of equivalence trials. In a bioequivalence trial, systemic drug levels are measured following administration of both the brand-name and generic drugs. If those systemic drug levels are similar (±20%) then the generic drug is considered bioequivalent to the brand-name drug. More specifically, the 90% confidence intervals for of the ratio of generic drug to name-brand drug must lie between 80-125% (which is ±20% on the logarithmic scale).

If you would like additional reading, the FDA website has quite a bit of excellent information on generic drugs.