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To all:
Last year at this time, there was an exciting exchange at PHARMPK on this topic. So much so that the
Bioanalytical Focus Group of AAPS decided to incorporate a roundtable on "The Case For and Against
the Release of Bioanalytical Data Below the LLOQ" at the AAPS Annual Meeting on October 28. Details
can be found at https://annual.aapsmeeting.org/event/member/181195.
So, if you are going to the AAPS meeting, try to attend the roundtable. Even if you can't, I would
appreciate hearing any comments or potential issues you think would be pertinent to this issue.
Christopher J. Kemper, Ph.D.
Pharma Navigators, LLC
cell: 609-213-3038
fax: 609-844-0312
PK/PD/Bioanalytical Consulting
Alliance Management/Business Analysis
http://www.pharmanavigatorsllc.com/
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How about this. The bioanalytical lab releases concentrations from and including the LLOQ to and
including the ULOQ. Response below the LLOQ are reported asanother or the same table as the concentration, the Ba lab alos lists responses for all samples.
The PK/PD people can take the response and do their own calculations.
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Chris:
Is it not a case of splitting the hair? These topics are good enough for academic discussion but in
a regulated field like ours anything below LLOQ is "non reportable" Fundemental principle in any
analysis LLOQ meant to say below whatever the value below LLOQ is that it can not be measured with
scientific and statistical confidence. If folks are so obsessed with what is below LLOQ they better
refine the analytical method and validate to a much more sensitive limits. By challenging LLOQ I
wonder how much mileage in accuracy these folks get in overall pharmacokinetics?
Prasad NV Tata, Ph.D., FCP
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Hey Prasad:
I couldn't have said it any better. But this has become a divisive issue unlike anything since ISR.
Take care,
Chris
Christopher J. Kemper, Ph.D.
Pharma Navigators, LLC
[Interestingly in an academic setting the same lab is commonly doing the 'chemical' analysis AND the
'pharmacokinetic analysis' so this question isn't always one side versus the other.
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Chris:
the problem about these values below LLOQ is “Don't let the noise of others' opinions drown out your
own inner voice."
Regards,
Prasad NV Tata, Ph.D., FCP
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In a regulated lab the analysts cannot project beyond assay limits. Therefore the LLOQ restraint
and not reporting out any concentration below that. We could report instrument responses for all
samples including those below the LLOQ and let the PK people play. As long as the bioanalytical
report does not report concentrations below LLOQ they are clear. The PK folks will need to explain
the manipulation so they do beyond that.
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