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USFDA Basic Statistics and Data Presentation (v02) PDF

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FOOD AND DRUG ADMINISTRATION Document Number:

Revision #: 02
OFFICE OF REGULATORY AFFAIRS III-04
Revision Date:
ORA Laboratory Manual Volume III Section 4 08/13/2019

Title:
Page 1 of 28
Basic Statistics and Data Presentation

Sections in This Document

1. Introduction ................................................................................................................................. 2
2. General Considerations.............................................................................................................. 2
2.1. Accuracy, Precision, and Uncertainty ............................................................................. 3
2.2. Error and Deviation; Mean and Standard Deviation ....................................................... 3
2.3. Random and Determinate Error ...................................................................................... 6
2.4. The Normal Distribution ................................................................................................... 6
2.5. Confidence Intervals ........................................................................................................ 8
2.6. Populations and Samples: Student’s t Distribution ......................................................... 9
2.7. References....................................................................................................................... 9
3. Data Handling and Presentation .............................................................................................. 10
3.1. Rounding of Reported Data........................................................................................... 10
3.2. Significant Figures ......................................................................................................... 10
3.2.1. Definitions and Rules for Significant Figures .................................................. 11
3.2.2. Significant Figures in Calculated Results ....................................................... 11
4. Linear Curve Fitting .................................................................................................................. 12
5. Development and Validation of Spreadsheets for Calculation of Data ................................... 14
5.1.1. Introduction...................................................................................................... 15
5.1.2. Development of Spreadsheets........................................................................ 15
5.1.3. Validation of Spreadsheets ............................................................................. 15
6. Control Charts .......................................................................................................................... 16
6.1. Definitions ...................................................................................................................... 16
6.2. Discussion...................................................................................................................... 16
6.3. Quality Control Sample Example .................................................................................. 17
6.4. References..................................................................................................................... 17
7. Statistics Applied to Drug Analysis .......................................................................................... 17
7.1. Introduction .................................................................................................................... 17
7.2. USP Guidance on Significant Figures and Rounding ................................................... 17
7.3. Additional Guidance in the USP .................................................................................... 19
7.4. References..................................................................................................................... 20
8. Statistics Applied to Radioactivity ............................................................................................ 20
8.1. Introduction .................................................................................................................... 20
8.2. Sample Counting ........................................................................................................... 20

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8.3. Standard Deviation and Confidence Levels .................................................................. 21


8.4. Counting Rate and Activity ............................................................................................ 23
9. Statistics Applied to Biological Assays..................................................................................... 23
10. Statistics Applied to Microbiological Analysis .......................................................................... 24
10.1. Introduction .................................................................................................................... 24
10.2. Geometric Mean ............................................................................................................ 24
10.3. Most Probable Number.................................................................................................. 26
10.4. References..................................................................................................................... 26
11. Statistics Applied to pH in Canned Foods ............................................................................... 26
12. Rounding Guidelines Applied to Engineering Analyses .......................................................... 27
13. Document History ..................................................................................................................... 28
14. Change History ......................................................................................................................... 28
15. Attachments.............................................................................................................................. 28

1. Introduction
Statistics may be used in the ORS laboratory to describe and summarize the
results of sample analysis in a concise and mathematically meaningful way.
Statistics may also be used to predict properties (ingredients, acidity, quantity,
dissolution, height, weight, etc.) of a contaminant or of a regulated product
based on measurements made on a subset, or sample, of the contaminant or
product. All statistical concepts are ultimately based on mathematically
derived laws of probability. Understanding statistical concepts will allow the
ORS analyst to better convey analytical results with the maximum accuracy
and precision.
Proper application of statistics gives analysts the ability to report accurate
results, while allowing for the fact that there is inherent error (both random and
determinate) in virtually every laboratory measurement made.
This section is meant to be a general guide for situations commonly
encountered in the ORS laboratory. The section also gives guidance on
various aspects of data presentation and verification.
2. General Considerations
Statistical procedures used to describe measurements of samples in the ORS
laboratory allow regulatory decisions to be made in as unbiased manner as
possible. The following are numerically descriptive measures commonly used
in ORS laboratories.

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2.1. Accuracy, Precision, and Uncertainty


A. The accuracy of a measurement describes the difference between the
measured value and the true value. Accuracy is said to be high or low
depending on whether the measured value is near to, or distant from,
the true value.
B. Precision is concerned with the differences in results for a set of
measurements, regardless of the accuracy. Applied to an analytical
method as used in an ORS laboratory, a highly precise method is one in
which repeated application of the method on a sample will give results
which agree closely with one another.
C. Precision is related to uncertainty: a series of measurements with high
precision will have low uncertainty and vice versa.
D. Terms such as accuracy, precision, and uncertainty are not
mathematically defined quantities but are useful concepts in
understanding the statistical treatment of data. Exact mathematical
expressions of accuracy and precision (error and deviation), will be
defined in the next section.
E. As an example of these terms, consider shooting arrows at a target,
where the “bull’s eye” is considered the true value. An archer with high
precision (low uncertainty) but low accuracy will produce a tightly
clustered pattern outside the bull’s eye; if low precision (high
uncertainty) and low accuracy, the pattern will be random rather than
clustered, with the bull’s eye being hit only by chance. The best
situation is high accuracy and high precision: in this case a tight cluster
is found in the bull’s eye area. This example illustrates another
important concept: accuracy and precision depend on the bow, the
arrow, and the archer. Applied to a laboratory procedure, this means
that the reliability of results depends on both the apparatus/instruments
used and the analyst. It is extremely important to have a well-trained
analyst who understands the method, applies it with care (for example
by careful weighing and dilution), and uses a calibrated instrument
(demonstrated to be operating reliably). Without all of these
components in place, it is difficult to obtain the reliable results needed
for regulatory analysis.
2.2. Error and Deviation; Mean and Standard Deviation
A. The concepts of accuracy and precision can be put on a mathematical
basis by defining equivalent terms: error and deviation. This will allow
the understanding of somewhat more complicated statistical
formulations used commonly in the ORS laboratory.

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Basic Statistics and Data Presentation

B. If a set of N replicate measurements x1, x2, x3, xn, were made


(examples: weighing a vial N times, determining HPLC peak area of N
injections from a single solution, measuring the height of a can N times,
…), then:
Ei = xi – μ

where Ei = error associated with measurement i,


xi = result of measurement i, and
μ = true value of measurement.
C. The definition of error often has little immediate practical application,
since in many cases μ, the true value, may not be known. However, the
process of calibration against a known value (such as a chemical or
physical standard) will help to minimize error by giving us a known value
with which to compare an unknown.
D. The deviation, a measure of precision, is calculated without reference to
the true value, but instead is related to the mean of a set of
measurements. The mean is defined by:
Ν
xi
X =∑
i =1 Ν

where
X = mean of set of N measurements,
xi = ith measurement, and
N = Number of Measurements.
Note: this is the arithmetic mean of a set of observations. There are
other types of mean which can be calculated, such as the geometric
mean (see the section on “Application of Statistics to Microbiology”
below), which may be more accurate in special situations.
E. Then, the deviation, di, for each measurement is defined by:
di = x i - X

F. Using the example of the archer shooting arrows at a target, the


deviation for each arrow’s position is the distance from the arrow’s
position to the calculated mean of all of the arrow’s positions.

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Basic Statistics and Data Presentation

G. Finally, the expression of deviation most useful in many ORS laboratory


applications is s, the standard deviation:

∑d
2

∑ (x − X)
n 2
i
i =1 i
s= i =1
=
N −1 N −1

where s = standard deviation, and other terms are as previously


defined.
H. The standard deviation is then a measure of precision of a set of
measurements but has no relationship to the accuracy. The standard
deviation may also be expressed in relative terms, as the relative
standard deviation, or RSD:
(100)(s)
RSD (%) =
X

I. Whereas the standard deviation has the same units as the


measurement, the RSD is dimensionless, and expressed as a
percentage of the mean.
Standard deviation as defined above is the correct choice when we
have a sample drawn from a larger population. This is almost always
the case in the ORS laboratory: the sample which has been collected is
assumed to be “representative” of the larger population (for example, a
batch of tablets, lot of canned goods, field of wheat) from which it has
been taken. As it is taken through analytical steps in the laboratory (by
subsampling, compositing, diluting, etc.) the representative
characteristic of the sample is maintained.
If the entire population is known for measurement, the standard
deviation s is redefined as σ, the population standard deviation. The
formula for σ differs from that of s in that (N-1) in the denominator is
replaced by N. The testing of an entire population would be a rare
circumstance in the ORS laboratory, but may be useful in a research
project.
J. Statistical parameters such as mean and standard deviation are easily
calculated today using calculators and spreadsheet formulas. Although
this is convenient, the analyst should not forget how these parameters
are derived.

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2.3. Random and Determinate Error


A. Recall the definition of error in Section 2.2 above. Errors in
measurement are often divided into two classes: determinate error and
non-determinate error. The latter is also termed random error. Both
types of error can arise from either the analyst or the instruments and
apparatus used, and both need to be minimized to obtain the best
measurement, that with the smallest error.
B. Determinate error is error that remains fixed throughout a set of
replicate measurements. Determinate error can often be corrected if it is
recognized. Examples include correcting titration results against a
blank, improving a chromatographic procedure so that a co-eluting peak
is separated from the peak of interest, or calibrating a balance against a
NIST-traceable standard. In fact, the purpose of most instrument
calibrations is to reduce or eliminate determinate error. Using the
example of the archer shooting arrows at a target, calibration of the
sights of the bow would decrease the error, leading to hitting the bull’s
eye.
C. Random error is error that varies from one measurement to another in
an unpredictable way in a set of measurements. Examples might
include variations in diluting to the mark during volumetric procedures,
fluctuations in an LC detector baseline over time, or placing an object to
be weighed at different positions on the balance pan. Random errors
are often a matter of analytical technique, and the experienced analyst,
who takes care in critical analytical operations, will usually obtain more
accurate results.

2.4. The Normal Distribution


A. In the introduction to this chapter, it was briefly mentioned that statistics
is derived from the mathematical theory of probability. This relationship
can be seen when we consider probability distribution functions, of
which the normal distribution function is an important example. The
normal distribution curve (or function) is of great value in aiding
understanding of measurement statistics, and to interpret results of
measurements. Although a detailed explanation is outside the scope of
this chapter, a brief explanation will be beneficial.
B. The normal distribution curve describes how the results of a set of
measurements are distributed as to frequency; assuming only random
errors are made. It describes the probability of obtaining a
measurement within a specified range of values. It is assumed here that

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the values measured (i.e. variables) may vary continuously rather than
take on discrete values (the Poisson distribution, applicable to
radioactive decay is an example of a discrete probability distribution
function; see discussion under “Statistics Applied to Radioactivity”).
C. The normal distribution should be at least somewhat familiar to most
analysts as the “bell curve” or Gaussian curve. The curve can be
defined with just two statistical parameters that have been discussed:
the true value of the measured quantity, μ, and the true standard
deviation, σ. It is of the form:
−1 / 2{( x − µ ) / σ }2
Y= e
Where Y= frequency of occurrence of a measurement (a value between
0 and 1),
x = the magnitude of the measurement,
μ = the true value of the measurement,
σ = true standard deviation of the population, and
e = base of natural logarithms (2.718…)
D. An example of two normal curves with the same true value, μ, but two
different values of σ is shown below (this was calculated using an
Excel® spreadsheet, using the formula above and an array of x values):

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Normal Distribution

1.2

0.8
standard
Normalized frequency

deviation = 0.1

0.6

standard
deviation =0.05

0.4

0.2

0
1 5 9 13 17 21 25 29 33 37 41 45 49 53 57 61 65 69 73 77 81 85 89 93 97 101
measurement (mean = 0.5)

E. Some properties of the normal distribution curve that are evident by


inspection of the graph and mathematical function above go far in
explaining the properties of measurements in the laboratory:
1. In the absence of determinate errors, the measurement with the
most probable value will be the true value, μ.
2. Errors (i.e. x-μ), as defined previously, are distributed symmetrically
on either side of the true value, μ; errors greater than the mean are
equally as likely as errors below the mean.
3. Large errors are less likely to occur than small errors.
4. The curve never reaches the y-axis but approaches it asymptotically:
there is a finite probability of a measurement having any value.
5. The probability of a measurement being the true value increases as
the standard deviation decreases.
2.5. Confidence Intervals
A. The confidence interval of a measurement or set of measurements is
the range of values that the measurement may take with a stated level
of uncertainty. Although confidence intervals may be defined for any

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probability distribution function, the normal distribution function


illustrates the concept well.
B. Approximately 68% of the area under the normal distribution curve is
included within ±1 standard deviation of the mean. This implies that, for
a series of replicate measurements, 68% will fall within ±1 standard
deviation of the true mean. Likewise, 95% of the area under the normal
distribution curve is found within about ± 2σ (to be precise, 1.96 σ), and
approximately 99.7% of the area of the curve is included within a range
of the mean ±3σ. A 95% confidence interval for a series of
measurements, therefore, is that which includes the mean ± 2σ. An
example of the application of confidence limits is in the preparation of
control charts, discussed in Section 6 below.
2.6. Populations and Samples: Student’s t Distribution
A. In the above discussion, we are using the true standard deviation, σ (i.e.
the population standard deviation). In most real-life situations, we do not
know the true value of σ. In the ORS laboratory, we are generally
working with a small sample which is assumed to be representative of
the population of interest (for example, a batch of tablets, a tanker of
milk). In this case, we can only calculate the sample standard deviation,
s, from a series of measurements. In this case, s is an estimate of σ,
and confidence limits need to be expanded by a factor, t, to account for
this additional uncertainty. The distribution of t is called the Student’s t
Distribution.
B. Further discussion is beyond the scope of this chapter, but tables of t
values, which depend on both the confidence limit desired and the
number of measurements made, are widely published.
2.7. References
The following are general references on statistics and treatment of data that
may be useful for the ORS Laboratory:
A. Dowdy, S., Wearden, S. (1991). Statistics for research (2nd ed.). New
York: John Wiley & Sons.
B. Garfield, F.M. (1991). Quality assurance principles for analytical
laboratories. Gaithersburg, MD: Association of Official Analytical
Chemists.
C. Taylor, J. K. (1985). Handbook for SRM users (NBS Special Publication
260-100). Gaithersburg, MD: National Institute for Standards and
Technology.

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3. Data Handling and Presentation


In the most general sense, analytical work results in the generation of
numerical data. Operations such as weighing, diluting, etc. are common to
almost every analytical procedure, and the results of these operations,
together with instrumental outputs, are combined mathematically to obtain a
result or series of results. How these results are reported is important in
determining their significance. As a regulatory agency, it is important that we
report analytical results in a clear, unbiased manner that is truly reflective of
the operations that go into the result. Data should be reported with the proper
number of significant digits and rounded correctly. Procedures for
accomplishing this are given below:
3.1. Rounding of Reported Data
A. When a number is obtained by calculations, its accuracy depends on
the accuracy of the number used in the calculation. To limit numerical
errors, an extra significant figure is retained during calculations, and the
final answer rounded to the proper number of significant figures (see
next section for discussion of significant figures).
B. The following rules should be used:
1. If the extra digit is less than 5, drop the digit.
2. If the extra digit is greater than 5, drop it and increase the previous
digit by one.
3. If the extra digit is five, then increase the previous digit by one if it is
odd; otherwise do not change the previous digit.
C. Examples are given in the following table:
Reported
Calculated Significant Number with one
rounded
Number digits to report extra digit retained
number
79. 35432 4 79.354 79.35
99.98798 5 99.9879 99.988
32.9653 4 32.965 32.96
32.9957 4 32.995 33.00
0.0396 1 0.039 0.04
105.67 3 105.6 106
29 2 29 29

3.2. Significant Figures


Significant figures (or significant digits) are used to express, in an approximate
way, the precision or uncertainty associated with a reported numerical result.

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In a sense, this is the most general way to express “how well” a number is
known. The correct use of significant figures is important in today’s world,
where spreadsheets, handheld calculators, and instrumental digital readouts
are capable of generating numbers to almost any degree of apparent
precision, which may be much different than the actual precision associated
with a measurement. A few simple rules will allow us to express results with
the correct number of significant figures or digits. The aim of these rules is to
ensure that the final result should never contain any more significant figures
than the least precise data used to calculate it. This makes intuitive as well as
scientific sense: a result is only as good as the data that is used to calculate it
(or more popularly, “garbage in, garbage out”).
3.2.1. Definitions and Rules for Significant Figures
A. All non-zero digits are significant.
B. The most significant digit in a reported result is the left-most non-zero
digit: 359.741 (3 is the most significant digit).
C. If there is a decimal point, the least significant digit in a reported result is
the right-most digit (whether zero or not): 359.741 (1 is the least
significant digit). If there is no decimal point present, the right-most non-
zero digit is the least significant digit.
D. The number of digits between and including the most and least
significant digit is the number of significant digits in the result: 359.741
(there are six significant digits).
E. The following table gives examples of these definitions:
Sig.
Number
Digits
A 1.2345 g 5
B 12.3456 g 6
C 012.3 mg 3
D 12.3 mg 3
E 12.30 mg 4
F 12.030 mg 5
G 99.97 % 4
H 100.02 % 5

3.2.2. Significant Figures in Calculated Results


Most analytical results in ORS laboratories are obtained by arithmetic
combinations of numbers: addition, subtraction, multiplication, and division.
The proper number of digits used to express the result can be easily obtained
in all cases by remembering the principle stated above: numerical results are

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reported with a precision near that of the least precise numerical measurement
used to generate the number. Some guidelines and examples follow.
3.2.2.1. Addition and Subtraction
The general guideline when adding and subtracting numbers is that the
answer should have decimal places equal to that of the component with the
least number of decimal places:
21.1
2.037
6.13
________
29.267 = 29.3, since component 21.1 has the least number of decimal places
3.2.2.2. Multiplication and Division
The general guideline is that the answer has the same number of significant
figures as the number with the fewest significant figures:
56 X 0.003462 X 43.72
1.684
A calculator yields an answer of 4.975740998 = 5.0, since one of the
measurements has only two significant figures.
4. Linear Curve Fitting
This section deals with fitting of experimental data to a mathematical function.
This situation is encountered in a variety of situations in the ORS laboratory,
particularly with calibration curves. In most situations, the relationship between
the variables is linear, and therefore a linear function is needed:

y = f(x) = mx + b

Where x = independent variable,


y= dependent variable,
m = calculated slope of line, and
b= calculated y-intercept of line.

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The independent variable, x, is assumed to be known exactly, with no error


(such as concentration, distance, time, etc.). The dependent variable, y,
(instrument response for example) then depends on (is a function of) the value
of x. Each value of the independent variable is assumed to follow a normal
distribution and to have the same variance (i.e. square of the standard
deviation). The method of linear regression (also known as linear least
squares) is used to fit experimental data to a linear function (note: in certain
cases, a non-linear relationship may be reduced to a linear equation by a
transformation of variables; if so, the linear regression method is still
applicable).
The aim of linear regression is to find the line which minimizes the sum of the
squares of the deviations of individual points from that line. Once that is
accomplished, the slope (m) and the intercept (b) of the ‘least squares’ line is
determined. It should be intuitively clear that minimizing deviations of data
points from the fitted line gives the best fit of data. Given a set of data points
(xi,yi), the equations used to determine the least squares parameters are:
SLOPE
 n  n 
n∑i =1 xi y i −  ∑ xi  ∑ y i 
n

m=  i =1  i =1 
2
n
 n 
n∑ xi −  ∑ xi 
2

i =1  i =1 
 n n

 ∑ y i − m∑ xi 
b =  i =1 i =1  = Y − mX (intercept)
n
An additional parameter, which is an indicator of the “goodness of fit” of the
line to the data points, is the coefficient of determination. This coefficient
denotes the strength of the linear association between x and y. The coefficient,
r2, uses information on means and deviations of each data set to express
variation numerically. If the two data sets correspond perfectly or exhibits no
variation, a coefficient of 1 will be calculated. A coefficient of 0 indicates there
is no relationship or no explanation of variation between the two data sets.
Typically, for analytical work performed in the ORS laboratory, the coefficient
should be very close to 1 (for example 0.999). The formula for the coefficient of
determination is:

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2
 n 
 ∑ ( xi − x )( y i − y ) 
r 2 =  i =1 
 n(s x )(s y ) 
 
 

where terms have been defined previously.


The following figure illustrates several points relating to linear least squares
curve fitting. Data was entered into an Excel® spreadsheet and the linear
least squares regression line calculated and plotted from the data. The vertical
lines indicate the distances (residuals) that are minimized in order to achieve
the best fit.

5. Development and Validation of Spreadsheets for Calculation of Data


When using spreadsheets or programmable calculators for reduction of data
generated by sample analyses, there should be assurance that the results are
valid and usable for regulatory use. The following section provides guidance
for assuring that spreadsheets will meet these criteria.

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5.1. Introduction
Although the formulas given above for calculation of statistical parameters may
seem complicated, matters are simplified by the ready availability of
spreadsheets and calculators which provide these values transparently. This
makes calculation of statistical parameters much more straightforward than in
the past, when direct application of these formulas was used. It is still useful to
have some familiarity with these formulas to understand how statistical
parameters are derived. In addition, there may be a need to verify the results
of statistical data generated by a spreadsheet or calculator; data can be
plugged directly into the formulas above to verify these results.
5.2. Development of Spreadsheets
Excel® and other spreadsheets incorporate all of the statistical parameters
discussed, as well as many others. Although individual spreadsheet functions
can be considered as reliable, it is important to make sure that data is
presented to the spreadsheet with the proper syntax. Also, when spreadsheets
are used for multiple numerical calculations in the form of in-house developed
templates, it is important to protect the spreadsheet from inadvertent changes,
to verify the reliability of the spreadsheet by comparison with known results
from known data, and to ensure that the spreadsheet can handle unforeseen
data input needs. Spreadsheets developed in the ORS laboratory should be
looked upon as in-house developed software that should be qualified before
use, just as instruments are qualified before use.
5.3. Validation of Spreadsheets
General guidance for design and validation of in-house spreadsheets and
other numerical calculation programs includes the following considerations:
A. Lock all cells of a spreadsheet, except those needed by the user to
input data.
B. Make spreadsheets read-only, with password protection, so that only
authorized users can alter the spreadsheet.
C. Design the spreadsheet so that data outside acceptable conditions is
rejected (for example, reject non-numerical inputs).
D. Manually verify spreadsheet calculations by entering data at extreme
values, as well as at expected values, to assess the ruggedness of the
spreadsheet.
E. Test the spreadsheet by entering nonsensical data (for example
alphabetical inputs, <CTRL> sequences, etc.).

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F. Keep a permanent record of all cell formulas when the spreadsheet has
been developed. Document all changes made to the spreadsheet and
control using a system of version numbers with documentation.
G. Periodically re-validate spreadsheets. This should include verification of
cell formulas and a manual reverification of spreadsheet calculations.
6. Control Charts
A control chart is a graph of test results with limits established in which the test
results are expected to fall when the instrument or analytical procedure is in a
state of “statistical control.” A procedure is under statistical control when
results consistently fall within established control limits. There are a variety of
uses of control charts other than identifying results that are out of control. A
chart will disclose trends and cycles which will allow real time analysis of data
and information for deciding corrective action prior to say an entire analytical
system goes out of control. The use of control charts is strongly encouraged in
regulatory science.
6.1. Definitions
A. Central line: mean value of earlier determinations, usually a minimum
of twenty results
B. Inner control limit: the mean value ± 2 standard deviations
C. Outer control limit: the mean value ± 3 standard deviation
6.2. Discussion
A. Control charts are frequently used for quality control purposes in the
laboratory. Control charts serve as a tool that determines if results
performed on a routine basis (e.g. quality control samples) are
acceptable for the intended purposes of the data.
B. The mean control chart consists of a horizontal central line and two
pairs of horizontal control limits lines. The central line defines the mean
value, the inner control limit (mean ± 2 standard deviations), and outer
control limit (mean ± 3 standard deviations). Results are plotted on the
y-axis against the x-axis variable (e.g. date, batch number).
C. Results fall within the inner control limits 95% of the time. Results
falling outside the inner control limit serve as a warning that the results
may be biased. Results falling outside the outer control limit indicate
the results are biased and corrective action should be taken.

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6.3. Quality Control Sample Example


A. The control chart for a laboratory instrument often plots the results of
the calibration result (y-axis) against the date (x-axis).
B. Mean control chart:
1. Calculate the mean calibration value
2. Calculate ±2 standard deviation, ± 3 standard deviation values
3. Draw horizontal lines above and below the mean value at ±2
deviations and the mean value ± 3 standard deviations
4. Plot calibration results against the date or batch number
5. Define corrective actions if the calibration results fall outside the
inner and outer control limits.
6.4. References
A. Pecsok, Shields, Cairns. (1986). Modern methods of analysis (2nd
Ed.). New York: John Wiley and Sons.
B. Steinmeyer, K. P. (1994). Mathematics review for health physics
technicians. Hebron, CT: Radiation Safety Associates Publications.
(Also 2nd Ed. in 1998.)
7. Statistics Applied to Drug Analysis
Chemists in ORS laboratories may have to analyze a wide range of human
and animal drugs in a number of different dosage forms, and using differing
analytical methods. Statistical evaluation of the analytical results is important
for making regulatory decisions.
7.1. Introduction
Drug analysis, as well as most analysis performed in the ORS laboratory,
relies on the statistical concepts defined above. In addition, there are
references in the United States Pharmacopeia (USP) and other official
references with which the drug analyst should be familiar.
7.2. USP Guidance on Significant Figures and Rounding
Under GENERAL NOTICES, the USP has several references, either direct or
implied, to statistics, reporting of results and maintaining precision during an
analysis. The drug analyst should be thoroughly familiar with the “Significant
Figures and Tolerances” section of the USP. Highlights of this section are
summarized as follows:

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A. Numerical limits specified in a monograph include the extremes of the


values and all values in between, but no values outside these limits.
This statement should be applied after proper rounding of numerical
results. If, for example, a properly rounded result is found to lie exactly
at the extreme of a limit (e.g. limits 98.0-102.0% of declared; found
102.03%, rounded to 102.0%) then the monograph limits are met. If the
result lies outside the numerical limits (e.g. 98.0-102.0% of declared;
found 102.05%, rounded to 102.1%), then the monograph limits are not
met.
B. Numerical result should be reported to the same number of decimal
places as the limit expression stated in the monograph. For example, if
limits are stated as 90.0-110.0% of declared, report results to 1 decimal
place (e.g. 98.3%, 101.8%), after applying USP rounding rules.
C. The USP has slightly different rounding rules than those commonly
encountered, as discussed earlier in Section 3.1. The difference is when
a value ends in 5. USP rounding conventions are as follows:
1. Retain only one extra digit to the right of the rightmost digit of the
monograph limit expression
2. If the extra digit is less than 5, drop the digit.
3. If the extra digit is greater than 5, drop it and increase the previous
digit by one
4. If the extra digit is exactly five, then drop it and (always) increase the
previous digit by one.
D. An explicit statement is made for titrimetric procedures: essentially all
factors, such as weights of analyte, should be measured with precision
commensurate with the equivalence statement given in the monograph.
Examples in the significant figures section above illustrate the
importance of this for all analytical work.
E. There is a table given in SIGNIFICANT FIGURES AND TOLERANCES
that gives examples of USP conventions for rounding, reporting, and
comparison of results with compendial limits. This should be reviewed
and thoroughly understood by all ORS drug analysts. A few additional
examples are given in the following table:

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Compendial Unrounded Rounded Conforms?


Requirement Result Result (Y/N)
Assay not less than 95.0 94.95% 95.0% Y
And not more than 105.0% 94.94% 94.9% N
of Declared 105.65% 105.7% N
0.24% 0.2% Y
Limit Test LTE 0.2%
0.25% 0.3% N

7.3. Additional Guidance in the USP


A. Under GENERAL NOTICES, TESTS AND ASSAYS, is additional
guidance. An important section is “Test Results, Statistics, and
Standards,” which is of particular regulatory significance. Important
points to understand include:
1. USP compendial instructions or guidelines are not to be applied
“statistically,” meaning the conformance or non-conformance of a
product is determined by a single test which may be applied to any
portion of a sample, at any time throughout its stated shelf life. The
monograph limits are chosen so that inherent uncertainty in the
method is taken into account, and system suitability tests verify that
the analytical system is reliable; therefore “any specimen tested as
directed in the monograph complies” (FDA’s practice, nonetheless,
is to perform a check analysis to confirm non-compliance with a
monograph limits).
2. To emphasize the “singlet determination” viewpoint of the USP, the
following statement is made: “Repeats, replicates, statistical
rejection of outliers, or extrapolations of results to larger populations
are neither specified nor proscribed by the compendia.”
B. Finally, under GENERAL NOTICES, TESTS AND ASSAYS, the
“Procedures” section includes some guidance that should be
understood by the ORS Laboratory drug analyst:
1. Weights and volumes of test substances and reference standards
may be adjusted proportionately, provided that such adjustments do
not adversely affect the accuracy of the procedure.
2. Similarly, when a method calls for a standardized solution of a
known concentration, a solution of a different concentration,
molarity, or normality may be used, provided allowance is made for
the differing concentration, and the error of measurement is not
thereby increased.
3. Monographs often use expressions such as “25.0 mL” for volumetric
measurements. This is not to be taken literally. In practice, volumes

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used quantitatively (i.e. the measurement will be used in a


quantitative calculation) should be measured to the higher precision
specified in “Volumetric Apparatus <31>” of the USP. This generally
means that class A flasks, burets, and pipets are to be used, and
with proper analytical technique employed. Similarly, for weights:
“25.0 mg” means that the weighing should be performed with a high-
precision balance, meeting standards set forth in “Weights and
Balances <41>.”
7.4. References
(Current Ed.). U. S. Pharmacopeia and national formulary. Rockville, MD:
United States Pharmacopeial Convention, Inc.
8. Statistics Applied to Radioactivity
ORS laboratories may be involved in the identification and quantitative
measurement of radionuclides in foods, drugs, and the environment.
Instrumentation varies from simple counters to solid state detectors that
measure both discrete energy levels and the quantity of radiation in these
samples. The correct application of statistical principles is important for arriving
at the correct analytical result that will support regulatory decisions.
8.1. Introduction
Statistics is directly and intimately involved in measurements of radioactivity.
Whereas most measurements made in the ORS laboratory are based on
variables which vary continuously, radioactivity measurements are based on
the counting of discrete, random events. In this case, the normal distribution
probability function is replaced by the Poisson distribution, and the associated
statistical parameters (mean, standard deviation) are therefore expressed
differently.
8.2. Sample Counting
A. Radioactive decay is a random process that is described quantitatively
in statistical terms. Therefore, repeatedly counting radioactive
transformations in a sample under identical conditions will not
necessarily result in identical values. The result of counting sample
radiations is
number of sample counts = N s
B. The standard deviation of the sample counts, based on Poisson
statistics, is

standard deviation of sample counts = s s = N s

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C. Noise originating in the background, also a random process,


simultaneously generates counts that are indistinguishable from those
originating in the sample, and therefore the total or gross counts
observed from counting a sample include background counts,
gross sample counts = N g = N s + N b

Where Ns = sample counts and


Nb = background counts
D. It follows that the counts due to sample radioactivity are obtained by
subtracting the background noise count from the sample gross counts
N s = N g − Nb .

E. The counting rate due to sample radioactivity is


Ns
Rs =
ts
where ts = sample counting interval
F. The sample counting rate can also be expressed as
Ng Nb
Rs = R g − Rb = −
tg tb
Where:
R g = gross sample counting rate
,
Rb = background counting rate ,

t g = gross sample counting interval


, and
t b = background counting interval .

8.3. Standard Deviation and Confidence Levels


A. The standard deviation is a measure of the dispersion of values of a
random variable about the mean value. For a large number of
measurements, 68 percent would be expected to lie within plus and
minus one standard deviation of the mean of the measurements; 96
percent would occur within plus or minus two standard deviations.

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B. The standard deviation of the sample counting rate, s Rs is given by:


Rg Rb
s R = s R2 + s R2 = +
s g b
tg tb

Where:
s R = standard deviation of the gross sample counting rate
g
, and
s R = standard deviation of the background counting rate
b .
C. The sample rate plus or minus one standard deviation is reported as
Rg Rb
R s ± s Rs = R s ± +
tg tb

D. If a measured value is reported within the limits of one standard


deviation, there is a 68 percent certainty, or 68 percent confidence level,
that the true value of the measured quantity is between the given limits.
In other words, there is a 68 percent certainty that the real value lies
within the limits. If the value is reported at the 96 percent confidence
level, the true value is within plus or minus two standard deviations of
the reported value. Several confidence levels are tabulated below:
Number of
Confidence Standard
Level (%) Deviations
(σs)
90 1.645
95 1.960
96 2.0
99 2.58

Example. A sample counted for 100 seconds yields 2300 gross counts. The
background measured under identical conditions yields 100 counts in 10
seconds. Calculate the sample counting rate (counts per second) and the
standard deviation of the sample counting rate. Report the results at the 96%
confidence level.
2300 counts 100 counts
Rs = - = 23 cps - 10 cps = 13 cps
100 s 10 s

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23 13
sR = + = 1.2 cps
s
100 10
Rs = 13 cps ± 2.4 cps

8.4. Counting Rate and Activity


A. The sample counting rate is proportional to sample activity, and may be
converted to radioactivity units using correction factors. These may
include detector efficiency in units of counts per disintegration, chemical
recovery fraction, fractional radiation yield, and others. The sample
activity may be obtained from the counting rate as follows:
Rg Rb
Rs ± +
R s ± s Rs tg tb
sample activity = =
ε × r ×Y ε × r ×Y
Where:
ε = detector efficiency
r = chemical recovery
Y = radiation yield
B. Example. A Sr-89 sample, counted using a detector having a 50% beta-
particle detection efficiency for Sr 89 (0.5 counts per Sr-89
disintegration which emits one beta particle per disintegration), yields
500 gross counts in 10 seconds. The background count was 100 counts
in 60 seconds. The chemical recovery of strontium was 86%. Report
the approximate activity in the sample at the 68% confidence level.

500 counts 100 counts 50 1.7


R s ± s Rs = − ± + cps = 48.3 ± 2.2cps
10 s 60 s 10 60
48.3 ± 2.2
Sample activity = Bq = 112.4 ± 5.2 Bq
0.5 × 0.86
where 1 Bq (Becquerel) = 1 disintegration/s.
9. Statistics Applied to Biological Assays
A. Biological assays are those carried out by dosing a biological test
system (such as a rat or mouse) with the substance to be determined
and measuring a response. An example is the USP monograph for

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Menotropins. This biological extract contains Luteinizing Hormone (LH)


and Follicle Stimulating Hormone (FSH), which have effects on the
reproductive organs. The assay consists of dosing male (LH) and
female (FSH) rats with menotropins and observing the effects (weight)
on the seminal vesicles and ovaries respectively after a multiple day
incubation time.
B. Although this type of assay will rarely be encountered in the ORS
laboratory, biological assays are instructive in the statistical complexity
encountered when dealing with highly variable systems such as live
animals. The interpretation of results is complicated by the fact that the
total variance of a measurement includes a large variance due to the
biological component. The analyst may also encounter these assays
when on team inspections.
C. The subject of biological assays is addressed in General Chapter <111>
of the USP, “Design and Analysis of Biological Assays,” where an
extensive statistical treatment is developed, based on the Analysis of
Variance (ANOVA). This is also one of the rare instances in the USP
where rejection of “outlier data” is allowed, under strict statistical
justification. The interested reader is referred to <111> for further
information.
10. Statistics Applied to Microbiological Analysis
Several analyses used by ORS microbiologists call for the enumeration of
microorganisms by statistical means. Two commonly used procedures for
estimating the number of microorganisms in a product are the plate count and
the Most Probable Number (MPN) tube methods. To avoid fictitious impression
of precision and accuracy, only 2 significant figures are reported. Many
regulatory decisions pertaining to microbial contamination or time-temperature
abuse of food will be based upon the level of organism present.
10.1. Introduction
Many microbiological analyses involve the counting of discrete events, for
example plate and tube counts for microbial growth and isolated colonies. As
in the case for radioactivity, the situation is one of random, discrete, and
relatively improbable events (such as growth of a colony forming unit on an
agar plate), and Poisson statistics apply.
10.2. Geometric Mean
A. In microbiological assays, because of the techniques used and the fact
that biological systems are being measured, a variety of unique
statistical situations arise. When determining, for example, the number

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of colony-forming units on a plate from a large number of replicate


inoculations, the data often does not correspond to the expected normal
distribution. That is, if the frequency of a given number of colonies is
plotted against the observed number of colonies, a non-symmetrical
frequency distribution is observed (note that the normal distribution
curve is completely symmetrical, centered about the arithmetic mean).
Instead the distribution is skewed or tailed at the higher end. This is
attributed to the fact that bacterial counts tend to favor lower counts and
disfavor extremely high counts. In this situation, the arithmetic mean is
not the best statistical indicator; instead the geometric mean is most
often used:
1/ n
 n 
x g =  / xi 
 i =1 

where xi are the individual counts, and ∏ indicates that the product of

the observations is determined rather than the sum.

B. For example, the arithmetic mean of the individual observations 1, 2


and 3 is:
(1 + 2 + 3)
3 =2
C. whereas the geometric mean of the same observations is:
(1x 2 x3)1 / 3 = 1.8
D. Question: Why would one expect lower plate counts to be more
probable than higher counts, thus causing a skewed probability
distribution? Answer: As the number of counts on a plate rises, in other
words the density of colonies rises, an overcrowding error occurs from
individual colonies inhibiting the formation of other colonies nearby.
Another factor appears to be a “counting fatigue” error at high numbers,
where the analyst may not count accurately because of the large
numbers involved.
E. An alternative way to calculate the geometric mean, which can be easily
derived from the product expression above, is to add the logarithms of
individual counts rather than form the product of the counts themselves.
The geometric mean is then defined as:

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 n 
 ∑ log xi 
x g = anti log i =1 
 n 
 
 
This formula is much easier for calculation purposes, particularly when
a large number of observations are involved.
10.3. Most Probable Number
Another statistical concept unique to microbiological observations is that of
Most Probable Number (MPN). The Most Probable Number is a statistically
derived estimate of the presence of microorganisms based on the presence or
absence of growth in serially diluted samples. After an initial dilution, serial
dilutions of the sample are made (for example, 1:10, 1:100, and 1:1000) with a
number of replicate tubes (for example, 3 or 5) at each dilution. After
incubation, the presence or absence of growth in each tube is tabulated. The
resulting code (number of positive tubes) is compared with published tables to
give the most probable number of microorganisms per unit of original,
undiluted sample. Most probable number tables are published for various
numbers of tubes at a number of dilutions. The statistical derivation is beyond
the scope of this discussion, but is based on Poisson counting statistics.
Tables are published in the Bacteriological Analytical Manual (BAM), the
AOAC Official Methods of Analysis, and General Chapter <61> of the USP.
10.4. References
A. (Current Ed.). “Microbiological Examination of Nonsterile Products
<61>,” U. S. Pharmacopeia and national formulary. Rockville, MD:
United States Pharmacopeial Convention, Inc.
B. Tomlinson, L. (Ed.). (1998). Bacteriological analytical manual (8th ed.,
Rev. A, in hardcopy) Washington DC: R. I. Merker, Ph.D., Office of
Special Research Skills, Center for Food Safety and Applied Nutrition,
U.S. Food & Drug Administration and The current version of the
Bacteriological Analytical Manual (BAM) found online.
11. Statistics Applied to pH in Canned Foods
A. pH is a logarithmic measure for the acidity of an aqueous solution.
Since pH represents the negative logarithm of a number, it is not
mathematically correct to calculate simple averages or other summary
statistics. Instead, the values should be converted to hydrogen ion
concentrations, averaged, and re-converted to pH values.
B. The following guidance is provided:

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1. Convert each pH value to hydrogen-ion activity (H+), using the


equation:
Activity = 10-pH
In Excel, the formula is: =10^(-pH number)
2. Calculate the mean of the activity values by adding the values and
dividing the sum by the total number of values. Calculate the
standard deviation also from the activity values.
3. Convert the calculated mean activity back to pH units, using the
equation:
pH = (-)(log10)(mean H+ activity). Also convert the standard
deviation to pH units.
In Excel, the formula is: = -LOG10(number)
C. When the pH values correspond closely, there is not a significant
difference between the mathematical mean and the logarithmic mean.
As the pH values spread further apart from each other, the difference
between the two means become more significant.
12. Rounding Guidelines Applied to Engineering Analyses
A. Most engineering analyses test devices for performance. Performance
testing involves determining conformance of test data with product
specifications.
B. Engineering analyses rely on the statistical concepts defined above.
Standards also provide guidance for using significant figures when
determining conformance to specifications.
C. When reporting direct measurements from an instrument, record all
digits that are known exactly plus one digit that can be estimated (e.g.
between ruler lines). The number of significant digits read from a digital
display should be between 0.05 (expanded uncertainty) and 0.5
(expanded uncertainty) of the instrument.
D. Calculate results using the observed values as reported and round only
the final result. Follow the rounding procedures in Section 3.1. In
addition, when the digit beyond the last place to be retained is 5 and
non-zero digits are beyond this 5, increase the retained digit by 1.
E. Compare the rounded value to the specified limit to determine
conformance.

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F. Refer to ASTM E29 Using Significant Digits in Test Data to Determine


Conformance with Specifications.

13. Document History


Revision Status* Approving Official Name
Date Author Name and Title
# (D, I, R) and Title

1.4 R 01/30/2013 LMEB LMEB

02 R 08/13/2019 LMEB LMEB


* - D: Draft, I: Initial, R: Revision

14. Change History


Revision
Change
#
Contents – Document History added.
Section 4.3 – title corrected to Data Handling and Presentation.
1.2
Section 4.3.1. – number of significant digits to report changed to 1 for 0.0396.
Section 4.10.4 – removed date from BAM reference.
1.3 Section 4.4, fourth paragraph – corrected to coefficient of determination and revised.
Header – Division of Field Science changed to Office of Regulatory Science
1.4
4.11 – Section added
Updated formatting and hyperlinks; Added new section “Rounding Guidelines Applied
02
to Engineering Analyses”

15. Attachments
None

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