ABSTRACT
Production lots and tests with a specification range of two standard deviations will produce random rejections five percent of the time, as a result of extreme statistical variation. Techniques based on sound statistical reasoning were developed to deal with out-of-specification (OOS) test results. The temptation to bend the rules and lower the reject rate led to abuses, however. The most common of these was to test a sample repeatedly until a passing result was produced. In 1993, Barr Laboratories lost a lawsuit on this and related points and the judge's decision led to new interpretations of FDA rules, including the requirement that an investigation be initiated before a replicate sample can be tested. These rules and others incorporated into FDA guidance documents reflect a misunderstanding of important statistical principles.
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2018-05-02