Commentary Success rates in the United States drug development system Lorraine Sheck, Ph.D., Christopher Cox, Ph.D., Henry T. Davis, Ph.D., A. Gene Trimble, William M. Wardell, M.D., Ph.D., and Ronald Hansen, Ph.D. Boston, Mass., and Rochester, N . Y . Center for the Study of Drug Development, Tufts University, Boston, and the University of Rochester, Rochester Drug development in the United States has been characterized by: (1) high attrition and correspondingly low success rates of drug candidates passing through the development sys(2) a steady decline in new chemical entities (NCEs) entering clinical r e ~ e a r c h , ~ - ~ and (3) increasingly lengthy and more costly periods required for clinical and regulatory review.3 These characteristics have raised the concern that the n u m b e r ~ fNCEs reaching the market in the future might remain low or decline even further unless compensatory ins creases in NCE success rates Although detailed information on the numbers of NCEs involved in preclinical testing is difficult to obtain, success rates for the complete process of drug development from synthesis of a drug to market approval have been estimated at less than 0.1 %.', The filing requirement of the 1962 investigational new drug (IND) regulations has provided more reliable data on NCEs for the period from IND filing to new drug application (NDA) approval, so that success rates for NCEs in U. S. clinical development and regulatory review have been calculated with a greater degree of certainty. From these data, success rates for drugs that have reached the point of U. S. clinical study have been calculated at about 9% to 12%.33 43 These success rates represent composite rates for all NCEs receiving INDs between 1963 and the early 1970s and hence do not reveal any change in success rate specific to cohorts of NCEs of the same IND age. We examined rates in the United States at which self-originated NCEs with IND filings reach NDA approval by means of an improved methodology for the determination of regulatory success rates. Success is defined as approval by the Food and Drug Administration; success rate is defined as the cumulative percentage of NCEs that pass through IND filing to submission and approval of the NDA (expressed as a function of time from IND filing). Changes in success rates for NCEs with roughly the same IND age are determined by stratifying NCEs into 3-yr cohorts based on year of IND filing. Success rates for the earlier IND cohorts can be determined with reasonable certainty from observed data, since few INDs remain active in these cohorts. However, for more recent IND cohorts with greater numbers of active INDs, a mathematic model is employed to estimate future success rates of NCEs currently in drug development. The proportions of U. S. NCE-INDs first studied abroad are also examined to evaluate the influence of foreign testing on the success rate achieved by IND cohorts. Methods Reprint requests to: Louis Lasagna, M.D., Center for the Study of Drug Development, Tufts University, 136 Harrison Ave., Boston, MA 02111. Criteria for inclusion of NCEs were as already described8: NCEs were defined as new Volume 36 Number 5 molecular compounds not previously tested in man and excluded new salts or esters of existing drugs; surgical and diagnostic materials; certain externally used compounds such as disinfectants, antiperspirants, and sunscreens; nutritional compounds such as natural forms of vitamins and sweetening agents; and certain biologic compounds such as vaccines, antigens, antisera, immunoglobulins, or purified extracts of existing drugs. Data for this article were taken from our survey on U. S. investigational NCEss but were restricted to information provided on 752 selforiginated NCEs (i.e., those owned and developed by a U. S. parent company) that had never before been taken by man anywhere in the world and had received an IND filing between January 1, 1963 and December 31, 1979. Of these 752 NCEs, 691 had received IND filings and were subsequently first tested in man in the United States and 61 were first tested abroad and subsequently returned to the United States for IND filing and continued U. S. investigational study.* For these NCEs, the primary items of data analyzed included IND filing date, country where first taken by man, and either NDA approval date or the date of a firm's decision to cease clinical research without submitting an NDA. This latter information was available only from the firms and provides a more accurate date of research abandonment than the IND closure date, since firms often leave an abandoned IND open to protect its trade secret status. In our previous articles, success rates on all INDs filed between 1963 and the early 1970s were determined from the observed number of INDs reaching NDA approval, allowing at least 8 yr from IND filing to NDA a p p r ~ v a l . ~ ,In this article we have refined this approach by the 752 NCEs with IND filings into 3-yr cohorts based on year of IND t' examine whether success rates have changed with time. For each cohort, a suecess rate was calculated as the cumulative percentage of IND filings that reached NDA ap- *An additional 69 NCEs, first taken by man abroad but as yet without IND filings, were also considered in the foreign testing analysis. Success rates in U . S . drug development 575 proval at any given number of years from IND filing. Observed success rates are based on the full data base of 752 NCEs and 69 NDA approvals as of March 31, 1984. Since observations cease at a fixed point in time (March 31, 1984), the data are right-censored because additional approvals are expected to occur beyond March 31, 1984, particularly in more recent cohorts. To test our observed data statistically and to predict success rates in more recent IND cohorts beyond the range of observation, a mathematical model was developed to describe the manner in which NCEs progress through the IND and NDA phases of drug development. Two aspects of the IND phase were considered separately: residence time (the time from IND filing until termination) and fate (i.e., whether the termination took the form of research abandonment or NDA approval). Thus the model has two stages, with the first stage describing the residence time of an NCE as a function of year of IND filing and the second stage describing the fate of an NCE as a function of residence time. When the two stages are combined, the model* allows us to estimate the average residence times and success rates of compounds in the system for any particular year (or group of years) of IND filing. Because research termination dates required for the development of the first stage of the model were missing for 43 NCE-INDs, the model is based on a data base of 709 NCEs with IND filings between 1963 and 1979 and on approval data for 52 NCEs as of December 31, 1979.t To evaluate the influence of foreign testing on observed success rates, cumulative success rates for INDs first tested abroad and for INDs first tested in the United States were compared *From a statistical point of view, the need for a two-stage model arises from the difficulty of modeling the IND phase, which can terminate either in research abandonment or in NDA approval. Because the orobabilitv structure of a ~rocesswith multi~leoutcomes is comp~ex,'ourtwo-stage model represents a practiA solution for dealing with this complexity. Mathematic details of the model are discussed in the Appendix. tThe lower number of approved NCEs considered in the model and the larger number for the observed success rates are because the model required complete data on both research abandonment and approval. Status of clinical research for those NCEs that were not approved was only available through the end of our investigational survey period (December 31, 1979), while dates of approval were available through March 31, 1984. Clin. Pharmacol. Ther. November 1984 576 Sheck et al. TIME FROM IND FILING TO NDA APPROVAL (YEARS) Fig. 1. Observed success rates for four cohorts of self-originated U. S. NCE-INDs. Table I. Current cumulative and highest possible regulatory success rates for cohorts of IND filings Highest lND cohort 1 INDs $led I No. of approvals* I Current cumulative success rates* No. of INDs still active? Possible success rate (%)$ *As of March 31, 1984. +Number may be fewer than shown because research abandonment data are known only up to December 31, 1979, while NDA approval data are known up to March 31, 1984. $The highest possible success rate for the cohorts is calculated by assuming that the active NCEs for each cohort will all eventually be approved. This rate is not shown for cohorts of INDs filed after 1971, which are too recent for the attrition evident in the earlier cohorts to have occurred. §Incomplete cohort with respect to 3-yr intervals of IND filings. and the overall effect of foreign screening of NCEs was examined. Results Fig. 1 compares observed cumulative success rates for four 3-year cohorts of self-originated NCE-INDs reaching NDA approval after different elapsed times from IND filing. Intermediate success rates 6 yr after IND filing were similar for all four cohorts (3.5% to 4.2%). However, with additional time from IND filing, "final" cumulative success rates have increased in more recent cohorts. The 1963-65 cohort required 17 yr from the end of 1965 to obtain a 9.4% success rate, whereas the 1969-71 cohort required only 12 yr to reach a 13.7% success rate. The 1972-74 cohort also shows a rising trend toward a 9.5% success rate after 8 yr; whether this curve will eventually exceed its predecessors cannot yet be determined. Fig. 1 also illustrates that shorter residence times were required to reach a given success rate for more recent IND cohorts: To reach an 8% cumulative success rate, the 1963-65 cohort required about 13 yr, the 1966-68 cohort required about 12 yr, and both the 1969-71 and 1972-74 cohorts required less than 8 yr. In our survey, only 20 NCE-INDs filed during the period 1963 through 1971 were still active and not approved as of the end of December Volume 36 Number 5 1979. Table I shows by cohort current cumulative success rates and those that would be reached if all remaining active NCEs were approved. Thus for the 1963-65 cohort with only one active IND, a 9.9% success rate is the maximum success rate expected if that IND were eventually approved. For the 1966-68 cohort with five active INDs, a 12.1% success rate is the maximum success rate achievable. For the 1969-71 cohort, the maximum success rate would be 22.9%. For these earlier cohorts with fewer active INDs, estimation of the maximum success rate of an IND cohort seems reasonable. For more recent cohorts, however, the estimation of ultimate success rate becomes less certain because too little time has elapsed to allow for attrition through research abandonment. Not all active INDs will reach NDA approval, and some will almost certainly experience research abandonment without NDA approval. Because of this phenomenon, a mathematic model was constructed to estimate current and future cumulative regulatory success rates for more recent cohorts (Fig. 2). The first stage of the model involves survival distribution analysis (see Appendix) to estimate the residence time distributions for IND terminations (either by NDA approval or by research abandonment) based on year of IND filing. As shown in Fig. 2, top panel, residence times from IND filing to time of termination increase for more recent cohorts. Although this seems to contradict the trend toward shorter residence times described in Fig. 1, it should be noted that the termination rates shown in Fig. 2 are based both on INDs reaching NDA approval (10%) and on those abandoned in research (90%). In contrast, rates shown in Fig. 1 are based only on approval data. This paradox is explained by the larger proportion of INDs that remain in the system for a longer time before being abandoned and overshadow the smaller proportion that successfully reaches NDA approval. A likelihood ratio test proved the statistical significance (P < 0.01) of these increases, indicating that more recent NCEs are remaining in the system longer before a decision on their termination is made. When observed termination rates are superimposed on estimate curves, observed and estimated data are in good agree- Success rates in U . S . drug development 577 63-65 66 - 68 69-71 72 74 ALL TERMINATED NCEs (STAGE 1 OF THE MODEL) O f ' , ! , , , , , , , , , , , , ,, , 5 10 15 TlME FROM IND FILING TO TERMINATION / NCEs TERMINATED BY APPROVAL (STAGE 2 OF THE MODEL) 3 - 1 - TlME FROM IND FILING TO NDA APPROVAL (years) / APPROVAL RATES OF NCEs (COMBINED VERSION OF THE MODEL) 10 20 TlME FROM IND FILING TO NDA APPROVAL (years) Fig. 2. Mathematic model for estimation of success rates. ment (Fig. 2), thus supporting the choice of survival distribution analysis for this stage of the model. The second stage of our mathematical model distinguishes between the two alternative endpoints of IND termination (approval or abandonment) and indicates a modified logistic regression analysis (see Appendix) to estimate the probability of NDA approval as a function of residence time. As shown in Fig. 2, middle 578 Sheck et a / . Cfin. Pharmacof. Ther. November I984 - PREDICTED 1148 1 196365 --- I ? OBSERVED 18- 1972- 74 1969-71 v) v) LU 14- ' . I /' 0 0 14 3 IO- 10 l8I U) 6- . J 2- 2 07 , 5 10 15 0 i 5 10 15 TIME FROM IND FILING TO NDA APPROVAL Fig. 3. Predicted and observed success rates for four IND cohorts panel, the probability of NDA approval increases significantly with increasing residence time. Of those NCEs with residence times of 3 yr or less, fewer than 5% terminate in NDA approval (the remaining 95% terminate by research abandonment), whereas 34% of those NCEs with residence times of 7 yr or more are estimated to terminate in NDA approval. The curve levels off at 36%-the estimated maximal percentage of NDA approvals as described in the Appendix. Unlike the survival functions described in stage I of the model, this modified logistic regression function was not found to depend on year of IND filing. Thus regardless of year of IND filing, an approval is more likely the longer an NCE remains in the system; termination by research abandonment is more likely at earlier points in the development process. Fig. 2, middle panel, also shows that the modified logistic regression function closely approximates the grouped observed data for the earlier part of the curve but deviates somewhat from the later data points. This is in part because the later points are based on very few approvals at the longer residence times, thus introducing more potential error into the righthand portion of the curve. Because the probability of NDA approval increases the longer an NCE remains in the system and only very few NCEs are left at the latest time point (the fate of most of them having been decided much earlier), the number of NDA approvals with longer (8 to 10 yr) residence times is very small and does not influence the overall trend toward shorter residence times shown by the observed success rates of the more recent IND cohorts in Fig. 1. The two stages of the model were combined to estimate success rates as a function of time from IND filing for each cohort of IND filings Volume 36 Number 5 Success rates in U. S . drug development 579 FOREIGN-TESTED NCEs WITHOUT INDs FOREIGN-TESTED NCEs WITH lNDs US-TESTED NCEs WITH lNDs COHORTS BY YEAR OF IND FILING Fig. 4. NCEs tested anywhere in the world with or without INDs included in this study. As shown in Fig. 2, bortom panel, the estimated success rate increases from about 9.9% for the 1963-65 IND cohort (after 17 yr) to 13% for the 1969-71 cohort (after 12 yr). For the 1963-65 IND cohort, the estimated success rate is only slightly higher than the current observed success rate of 9.4% (after 17 yr) and will in fact be reached if the last active IND of that cohort is approved. For the 1969-71 cohort, the estimated success rate is about 0.5% lower than the current observed success rate of 13.7% (after approximately 12 yr). In a similar manner as was shown with observed success rates in Fig. 1 , shorter residence times are required to reach a given estimated success rate for more recent IND cohorts: the 1963-65 cohort requires about 9 yr, while the 1972-74 cohort requires less than 8 yr to reach an 8% cumulative success rate. However, because Fig. 2 shows success rates projected over 17 yr for all IND cohorts, we can discern plateau areas that represent the maximum success rate for each cohort when all INDs have either been abandoned or approved. Given these plateau areas, median residence times for IND cohorts required to reach maximum success rates are increasing for more recent IND cohorts, reflecting the longer times required for decisions to continue or abandon research. To evaluate the extent to which the model adequately estimates the observed data, esti- mated success rates have been plotted with the corresponding observed success rates (as in Fig. 1). Fig. 3 shows differences between observed and estimated NCE success rates. In general, however, the estimated success rates describe increasing success rates after shorter residence times for more recent IND cohorts in the fashion of the observed success rates. Furthermore, the model predicts that success rates will continue to increase for more recent INDs (e.g., INDs filed after 1972 for which few observed data are yet available). Agreement between observed and estimated rates is satisfactory given the complexities of the process being modeled and the relatively simple structure of the model. When a discrepancy occurs, however, the observed value is usually lower than the expected value. This could in part be a result of missing data on research abandonment, resulting in a smaller denominator (709). This smaller denominator produces an upward bias for the estimated values but has no effect on the calculation of observed success rates, since this is with the larger denominator (752). The increase in success rates for the 1969-7 1 and 1972-74 IND cohorts coincides with an increase in initial clinical study abroad. Less than 2% of the NCEs in the two earlier cohorts were first clinically studied abroad, compared to 6% for the 1969-71 cohort and 18% for the 1972-74 cohort. We would expect the probability of success to be higher for NCEs that were first tested Clin. Pharmacol. Ther. November 1984 580 Sheck et al. 1969-1971 COHORT p i FIRST STUDIED ABROAD i (3 Of 9) STUDY) TIME (YEARS) 1972- 1974 COHORT 2 30: 5 p FIRST STUDIED ABROAD 0 39 Z i 20; , / ./' ; 16 01 23) .i / 0 ,./ 0 2 4 COMBINED (FOREIGN 1 US STUDY) (12 01 126) 6 8 10 12 14 TIME (YEARS) Fig. 5. Approval rates for INDs by first study location. abroad because of a screening effect. Based on initial foreign clinic trials, firms will stop research on less promising candidates without applying for an IND and select the more promising candidates for further study under an IND. Fig. 4 shows both the increase in initial foreign clinical testing and the growth in the number of NCEs that have been clinically tested abroad without an IND. To investigate the effect of this screening on IND success rates, we separated the 1969-71 and 1972-74 IND cohorts by location of first clinical testing. As indicated in Fig. 5, INDs with previous foreign study have a much higher success rate than those first studied in the United States: 33% vs 12.7% for the 1969-71 cohort and 26% vs 6% for the 197274 cohort. If we limit our analysis to those NCEs first tested in man in the United States, the differences in success rates among cohorts is significantly narrowed (Fig. 6). The 196971 cohort still exhibits a higher success rate, but the 1972-74 cohort is within the range of the first two. These results indicate that NCEs screened abroad contribute substantially to the observed rise in IND success rates and underscore the importance of including for- Volume 36 Number 5 Success rutes in U . S . drug development 0 2 4 8 6 10 12 14 16 581 18 TIME (YEARS) Fig. 6. Approval rates for INDs first tested in the United States only eign study data in future studies of success rates. Discussion Various estimates and calculations of the percentage of INDs that reach NDA approval have been made. In previous reports we have calculated success rates by a simple descriptive analysis that determines success rate for all INDs filed between 1963 and the early 1970s, allowing at least 8 yr from IND filing to NDA a p p r ~ v a l . ~This , method had two limitations: It calculated a rate for a large group of INDs of different IND ages so that the important question of whether NCE success rates may be changing with time remained unanswered, and it provided no estimates of eventual success rates. We have here made a comprehensive examination of success rates that calculates separate success rates for 3-yr cohorts of NCEIND filings to determine whether success rates may be changing with time, involves a statistical model of the U. S. drug development process to estimate eventual success rates based on past trends in IND research abandonment and NDA approval, and examines the effects of previous foreign clinical study on IND success rates. Success rates of compounds in clinical research under an IND have been increasing over time, from 9.4% after 17 yr for the 196971 cohort to 13.7% after just 12 yr for the 1969-71 IND cohort. The success rate for the 1972-74 IND cohort surpasses that of the 1969-71 cohort after 8 yr of IND study. This indicates a trend towards higher IND success rates. The mathematical model we used produced estimated success rates that were in good agreement with observed data for INDs in the cohorts compared and predicts that success rates will continue to rise for INDs filed after 1974. Eventual success rate is projected at about 10% for the 1963-65 cohort, increasing to 16% for the 1972-74 cohort. For INDs filed between 1975 and 1979, eventual success rates are estimated at about 20%. These projections are for INDs only and assume that current trends will continue. Although the model allows us to predict future success rates for INDs, we emphasize its simplicity and warn that factors that may influence the rate at which an IND moves through the drug development system have not been incorporated into the model. One such factor that has been shown to affect the success rates of INDs is the impact of the increasing trend in initial foreign clinical study. For the last cohort, a substantial portion of the NDA approvals were first studied abroad before 582 Sheck et al. I N D filing. INDs with initial foreign testing had much higher success rates than those first tested in man in the United States, and the proportion of NCEs first tested abroad and having no I N D has increased over time. These findings indicate that foreign screening of compounds may be responsible for much of the rise in IND success rates, and that exclusion of these NCEs studied abroad that as yet have no I N D leads to an overestimate of actual clinical success rates. The relatively simple questions of what the success rate of drugs in clinical development is, and whether o r not it is changing, are not simple to answer. The increasing trend toward initial foreign clinical testing should make us cautious in interpreting I N D trends. Foreign testing may reduce the number of INDs, but will be offset at least in part by an increase in the probability of success for those NCEs selected for further testing in the United States. Thus the declining IND filing rate during the late 1970s overstates the reduction in clinical testing, but the I N D success rate overstates the success rate for all NCEs clinically tested. In a future study w e plan to incorporate data for foreign study into our calculations of success rates and into our mathematical model. Appendix: Statistics Srrccess rate cind residence time for cliniccrllg inrestigrted NCE-INDs. A model for IND success rates must consider the reciprocal relationship between success rate and residence time for NCEs in clinical investigation. The success rate of a class of NCEs depends on the amount of time elapsed since testing began (residence time) and marketing approval is received (point of success). For example, the success rate for a group of NCEs under observation for 10 yr might be lo%, while after 15 yr the success rate might rise to 15%. These hypothetic success rates illustrate the dependence of success rate on residence time, i.e., there is a different success rate associated with each interval of time since testing began. Some general features of the dependence of success rate on elapsed time can be seen from the above example. First, the success rate associated with zero time is zero. Second, as time increases, the success rate either increases or stays constant for a time. Third, the success rate will eventually reach a plateau and the ultimate level of this plateau is clearly much less than 100% (it is currently of the order of 10% to 15%), since most INDs are terminated by research abandonment and hence are not available for NDA approval. Clin. Pharmacol. Ther. November I984 To construct a mathematical model for success rates, we need to model the dependence of success rate on time. To do this, we interpret a success rate as a probability. That is, we assume that a success rate of 9% during the initial 10-yr period of observation represents a probability of success of 0.09 for an individual NCE during its first 10 yr under observation. NCEs of a common type being modeled are assumed to act randomly and independently according to the dictates (in the sense of dictating averages over a great many individual NCEs) of the same distribution (over time) of success rates (probabilities). Rather than having a random sample from some population, however, we have data on the entire population. Second, we are really modeling a subdistribution; i.e., the total probability (ultimate success rate) is less than one. In the fields of industrial reliability testing and epidemiology, the distribution of success rates is often called the "survival distribution." A common feature of survivorship data is that at any particular observation point there will always be NCEs on which research is still proceeding and whose fate is, therefore, unknown. One of the advantages of our statistical approach to modeling is that such "censored" observations can be used in construction of the model. From the point of view of statistical modeling, perhaps the most important feature of the IND-NDA process is the existence of two distinct endpoints: research abandonment or NDA approval. A statistical model can use the extra information on abandonment to gain more knowledge of the process than can be obtained from the observed success rates alone. Our approach to this two-stage process was a two-stage model. We make the assumption that every IND will eventually terminate in either research abandonment or NDA approval, and we define residence time as the time until such termination occurs. The distribution of residence times now becomes a genuine probability distribution that can be modeled with the techniques of survivorship analysis. As discussed below, we chose a model that would permit the distribution of residence times to depend on the year of IND filing. The second stage of the model is designed to separate the two endpoints by modeling the probability of NDA approval as a function of length of residence time and year of IND filing. Total probability is allowed to be less than one, reflecting the fact that some terminations are research abandonments. As described below, this total probability is represented by a parameter of the model and is, therefore, estimated from the data. The two different models can then be combined into a single model to estimate success rates for the entire process. The form of our mathematical model was suggested by two preliminary analyses of the data. First we used the methodology of nonparametric survival analysis, specifically the Kaplan-Meier product limit estimate^,^ to examine residence times. (This re- Volume 36 Number 5 Success rates in U . S. drug development quires the assumption that the residence times of the various NCEs are independent.) Since previous analyses have suggested that residence time might change through the years, it would have been desirable to perform individual Kaplan-Meier analyses for each year; however, there were too few NCEs having INDs filed in any given year for this to be practical. Thus we grouped the NCEs over 3-year intervals for the Kaplan-Meier analysis. Second, we examined fate as a function of residence time by logistic regression.' An additional multiplicative parameter was added to the logistic model to allow the total proportion of NDA approvals to be less than 100%. Constrrrction of the nctrral model. We let G(t) denote the subdistribution for the NDA approval process and g(t) its density. In the construction of G(t), we use two functions corresponding to the two aspects of the IND phase under consideration: ( I ) F(t), the residence time distribution function with density f(t), and (2) Pit), the probability of NDA approval given termination of the IND phase at time t. In this case, g(t) = f(t)P(t), and ified logistic and the multiplicative parameter 0 < y 5 1 is the limit of P(t) as t increases. As shown, G(t) = y,, f(u)P(u) du. Examination of Kaplan-Meier curves for residence times analyses indicated that, for each year of IND filing, the distribution function F(t) was well approximated by an exponential distribution. Therefore, if we assume that F(t) is an exponential distribution for every year of IND filing, we have f(t) = ( I /A)exp(- At) for t > 0 where the parameter A > 0 controls mean residence time and is allowed to depend in a log-linear manner on the year of IND filing. The method of maximum likelihood was used to estimate parameters of the model. A likelihood ratio test was used to examine the questions of dependency of the parameter A on the year of IND filing. As shown in Fig. 2, the predicted curves gave a good fit to the observed rates of abandonmentlapproval. Observed data indicated that P(t) should be a monotone increasing function of t whose range was the interval (0,l). One of the most useful such functions in statistical modeling is the logistic function. For modeling P(t), we chose to modify the usual logistic function by incorporating a multiplicative factor y that would allow the total probability of NDA approval to be less than one. Specifically, we assumed that P(t) had the form where a and /3 are the usual parameters of the unmod- 583 this model provided an adequate fit to the data. The parameter a has an interesting interpretation in our model; specifically, yl[l + exp(-a)] is the approximate probability of NDA approval for NCEs whose residence times are short. The value of y was approximately 36% for both processes. This can be seen in Fig. 2, in which the curve levels off at approximately 100 mo. References Cox DR: Analysis of binary data. London, 1970, Methuen. 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