← Về thư mục
Drug interactions (ICH M12) and QT assessment (ICH E14/S7B)
ICH M12 status
The first globally harmonised guidance on pharmacokinetic drug interactions mediated by metabolic
enzymes and transporters. Step 4 in 2024, then:
| Region |
Adoption |
| FDA |
Adopted 2 August 2024, with an accompanying M12 Drug Interaction Studies: Questions & Answers |
| EMA / EU |
Effective 30 November 2024 |
| NMPA (China) |
Implemented 29 October 2024 |
It replaces the previous FDA in vitro and clinical DDI guidances and EMA's DDI guideline as the
operative framework.
The stepwise, risk-based approach
- In vitro characterisation — is the drug a substrate, inhibitor or inducer of the major
enzymes and transporters?
- Basic models with conservative cut-offs — do the in vitro data rule the interaction out?
- Mechanistic static or PBPK modelling — refine a positive basic-model signal.
- Clinical study — where modelling cannot rule it out or the interaction is decision-relevant.
- Labelling — dose adjustment, contraindication, or monitoring.
The basic models are deliberately conservative: they are built to over-predict, so a negative
result is meaningful and a positive one is a trigger for further work, never an estimate of
clinical magnitude.
Basic model cut-offs
| Mechanism |
Model |
Cut-off |
| Reversible inhibition, hepatic |
R1 = 1 + Imax,u / Ki |
R1 ≥ 1.02 |
| Reversible inhibition, intestinal (CYP3A4) |
R1,gut = 1 + Igut / Ki, Igut = dose / 250 mL |
R1,gut ≥ 11 |
| Time-dependent inhibition |
R2 = (kobs + kdeg) / kdeg, kobs = kinact·I / (KI + I) at 50 × Imax,u |
R2 ≥ 1.25 |
| Induction (basic) |
R3 = 1 / (1 + d·Emax·I / (EC50 + I)) at 10 × Imax,u |
R3 ≤ 0.80 |
| Hepatic uptake transporters (OATP1B1/1B3) |
1 + fu·Iin,max / Ki,u |
≥ 1.1 |
| Intestinal transporters (P-gp, BCRP) |
Igut / IC50 |
≥ 10 |
| Renal transporters (OAT, OCT, MATE) |
Imax,u / Ki |
≥ 0.1 |
The hepatic inlet concentration for uptake transporters is
Iu,inlet,max = fu * (Imax + Fa*Fg*ka*Dose / (Qh * RB))
which is higher than systemic Imax and is what the liver actually sees during absorption.
An alternative induction assessment is the correlation / relative induction score approach,
calibrated against known inducers, which is less conservative than the basic R3 model.
Mechanistic static model
AUCR = 1 / (Ag·Bg·Cg·(1 - Fg) + Fg) × 1 / (Ah·Bh·Ch·fm + (1 - fm))
with, at each site,
A = 1 / (1 + I/Ki) reversible inhibition
B = kdeg / (kdeg + kinact·I/(KI + I)) time-dependent inhibition
C = 1 + d·Emax·I/(EC50 + I) induction
fm and Fg dominate the result. The ceiling on any inhibition of a single pathway is
1/(1 - fm): with fm = 0.9 no inhibitor can raise AUC more than 10-fold, and with fm = 0.7, no
more than 3.3-fold. These two fractions are usually the least well established inputs, and a
sensitivity analysis across their plausible range is more informative than the point prediction.
ddi_static.py --msm prints the ceiling alongside the prediction.
Perpetrator classification
| Class |
AUC ratio |
| Strong inhibitor |
≥ 5 |
| Moderate inhibitor |
≥ 2 and < 5 |
| Weak inhibitor |
≥ 1.25 and < 2 |
| No relevant effect |
> 0.8 and < 1.25 |
| Weak inducer |
> 0.5 and ≤ 0.8 |
| Moderate inducer |
> 0.2 and ≤ 0.5 |
| Strong inducer |
≤ 0.2 |
Clinical study design points
- Use index perpetrators (itraconazole or clarithromycin for strong CYP3A4 inhibition,
rifampicin for strong induction, and the corresponding index substrates) so the result is
interpretable against the classification bands.
- Worst-case first: a study with a strong index perpetrator that shows no interaction removes the
need for weaker ones.
- Induction requires multiple-dose administration of the perpetrator; a single dose can even
show inhibition from the same compound.
- Timing matters for time-dependent inhibition and for induction, both of which take days to
develop and days to reverse.
- A cocktail study can assess several pathways at once, provided the probes are validated as
non-interacting.
QT assessment: ICH E14 and S7B
The framework
- The threshold of regulatory concern is a QTc effect above 10 ms, assessed as the upper bound
of the two-sided 90% confidence interval for placebo-corrected change-from-baseline QTc (ΔΔQTc)
at the clinically relevant high exposure.
- A prospective concentration-QTc analysis on Phase I data can substitute for a dedicated
thorough QT study, and this is now the routine path.
- The 2022 E14/S7B Q&As introduced the "double negative" integrated nonclinical risk
assessment — a negative hERG assay plus a negative in vivo QTc study — as supplementary evidence.
This allows a submission to cover high clinical exposure without attaining a high multiple of
clinically relevant exposure, and its uptake in FDA reviews rose sharply after 2022.
Getting a C-QTc analysis right
- Correction method: QTcF (Fridericia) is the standard. QTcB (Bazett) over-corrects at high
heart rates and should not be primary. Where heart rate changes materially with treatment, a
study-specific or individual correction is preferable.
- Model: linear mixed effects on time-matched ΔQTc against plasma concentration, with a random
intercept and slope per subject and a treatment-specific intercept. Assess the intercept — a
non-zero one suggests the baseline or the placebo correction is wrong.
- Linearity: the extrapolation to supratherapeutic exposure depends on it. Check for curvature,
and check that the highest observed concentrations actually cover the exposure of interest.
- Hysteresis: if the QTc effect lags concentration, a direct model is misspecified and an effect
compartment is needed. Plot ΔQTc against concentration coloured by time to see it.
- Sample size is driven by the number of subjects and the spread of concentrations achieved;
a study where everyone has similar exposure estimates the slope poorly regardless of N.
exposure_response.py --cqtc implements the ordinary linear version for screening and flags
extrapolation beyond the observed concentration range. It is not a substitute for the mixed model
in a submission.