MEDICAL ADHESIVEONLINE, LLC. IONTOPHORESIS DRUG DELIVERY ELECTRODES, MODELS 23001, 23002, 23003, 23004, AND 24001

K041101 · Medical Adhesiveonline, LLC · EGJ · Jul 7, 2004 · Physical Medicine

Device Facts

Record IDK041101
Device NameMEDICAL ADHESIVEONLINE, LLC. IONTOPHORESIS DRUG DELIVERY ELECTRODES, MODELS 23001, 23002, 23003, 23004, AND 24001
ApplicantMedical Adhesiveonline, LLC
Product CodeEGJ · Physical Medicine
Decision DateJul 7, 2004
DecisionSESE
Submission TypeTraditional
Regulation21 CFR 890.5525
Device ClassClass 2
AttributesTherapeutic

Intended Use

Medical Adhesivesonline, LLC. Iontophoresis Drug Delivery Electrodes are intended to be used to introduce soluble salts and other drugs into the body as an alternative to hypodermic injection.

Device Story

System consists of active drug delivery electrode and passive return electrode. Designed for single-patient, single-use. Facilitates local administration of ionic drug solutions into body via iontophoresis. Multiple sizes/shapes of active electrodes accommodate various body sites; return electrode size is uniform. Used by healthcare providers to deliver medication as alternative to hypodermic injection. Device utilizes Ag/AgCl buffering agent and polyurethane foam reservoir on active electrode; self-adhering polymer on return electrode. Output is delivery of ionic drugs into patient tissue. Benefits include non-invasive drug administration.

Clinical Evidence

No clinical data provided. Substantial equivalence is based on technological characteristics and performance specifications compared to legally marketed predicate devices.

Technological Characteristics

System includes active drug delivery electrode and passive return electrode. Materials: Ag/AgCl buffering agent, polyurethane foam reservoir (active), self-adhering polymer (return). Multiple form factors/sizes available. Non-powered electrode system; requires external iontophoresis device for energy source. Sterilization not specified.

Indications for Use

Indicated for the introduction of soluble salts and other drugs into the body as an alternative to hypodermic injection. For prescription use.

Regulatory Classification

Identification

An iontophoresis device is a device that is intended to use a direct current to introduce ions of soluble salts or other drugs into the body and induce sweating for use in the diagnosis of cystic fibrosis or for other uses if the labeling of the drug intended for use with the device bears adequate directions for the device's use with that drug. When used in the diagnosis of cystic fibrosis, the sweat is collected and its composition and weight are determined. Additionally, an iontophoresis device intended for any other purposes is a prescription device that is intended to use a current to introduce ions of drugs or non-drug solutions into the body for medical purposes other than those specified in paragraph (a) of this section, meaning that the device is not intended for use in diagnosis of cystic fibrosis, or a specific drug is not specified in the labeling of the iontophoresis device.

Special Controls

*Classification.* Class II (special controls). The device is classified as class II. The special controls for this device are:(i) The following performance testing must be conducted: (A) Testing using a drug approved for iontophoretic delivery, or a solution if identified in the labeling, to demonstrate safe use of the device as intended; (B) Testing of the ability of the device to maintain a safe pH level; and (C) If used in the ear, testing of the device to demonstrate mechanical safety. (ii) Labeling must include adequate instructions for use, including sufficient information for the health care provider to determine the device characteristics that affect delivery of the drug or solution and to select appropriate drug or solution dosing information for administration by iontophoresis. This includes the following: (A) A description and/or graphical representation of the electrical output; (B) A description of the electrode materials and pH buffer; (C) When intended for general drug delivery, language referring the user to drug labeling approved for iontophoretic delivery to determine if the drug they intend to deliver is specifically approved for use with that type of device and to obtain relevant dosing information; and (D) A detailed summary of the device-related and procedure-related complications pertinent to use of the device, and appropriate warnings and contraindications, including the following warning: *Warning:* Potential systemic adverse effects may result from use of this device. Drugs or solutions delivered with this device have the potential to reach the blood stream and cause systemic effects. Carefully read all labeling of the drug or solution used with this device to understand all potential adverse effects and to ensure appropriate dosing information. If systemic manifestations occur, refer to the drug or solution labeling for appropriate action.(iii) Appropriate analysis/testing must demonstrate electromagnetic compatibility, electrical safety, thermal safety, and mechanical safety. (iv) Appropriate software verification, validation, and hazard analysis must be performed. (v) The elements of the device that may contact the patient must be demonstrated to be biocompatible. (vi) The elements of the device that may contact the patient must be assessed for sterility, for devices labeled as sterile. (vii) Performance data must support the shelf life of the elements of the device that may be affected by aging by demonstrating continued package integrity and device functionality over the stated shelf life.

Predicate Devices

Related Devices

Submission Summary (Full Text)

{0}------------------------------------------------ K041101 JUL - 7 2004 Image /page/0/Picture/2 description: The image shows the word "MAO" in a bold, sans-serif font. The letters are large and evenly spaced, with a thick line underlining the entire word. The background is plain white, which makes the black letters stand out. Medical Adhesiveonline, LLC. 614-323-0672 10809 Garden Mist #2045 Las Vegas, NV 89135 ### 510(k) SUMMARY [as required by 21 CFR 807.92(c)] # Medical Adhesivesonline, LLC. Iontophoresis Drug Delivery Electrodes - Date Prepared: April 20, 2004 l. #### Submitter Information ll. | Name: | Medical Adhesivesonline, LLC. | |-----------------|---------------------------------------------| | Address: | 10809 Garden Mist #2045 Las Vegas, NV 89135 | | Telephone: | 614-323-0672 | | Contact Person: | Adam Shaw | #### Device Identification Information lll. | Trade Name(s): | Medical Adhesivesonline, LLC. Iontophoresis<br>Drug Delivery Electrodes | |----------------|-------------------------------------------------------------------------| |----------------|-------------------------------------------------------------------------| lontophoresis Electrode Common Name: Classification Name:Device, Iontophoresis, Other Uses #### Predicate Devices IV. The Medical Adhesivesonline, LLC. Iontophoresis Drug Delivery Electrodes are substantially equivalent to the following legally marketed devices: | Trade Name | Manufacturer | 510(k) Number | |------------------------------|-----------------|---------------| | TransQe Electrodes | lomed, Inc. | K932620 | | logel Electrodes | lomed, Inc. | K932621 | | Dupel B.L.U.E.<br>Electrodes | Empi, Inc. | K983484 | | Meditrode Electrodes | Life-Tech, Inc. | K882554 | {1}------------------------------------------------ Image /page/1/Picture/0 description: The image shows the letters "MAO" in a bold, serif font. A horizontal line underlines the letters, emphasizing their presence. The letters are large and prominent, suggesting they are the main focus of the image. Medical Adhesiveonline, LLC. 10809 Garden Mist #2045 Las Vegas, NV 89135 614-323-0672 ### 510(k) SUMMARY [as required by 21 CFR 807.92(c)] Medical Adhesivesonline, LLC. Iontophoresis Drug Delivery Electrodes #### V. Device Description The Medical Adhesivesonline, LLC. Iontophoresis Drug Delivery Electrode System consists of an active drug delivery electrode and a passive return electrode. These electrodes are designed for one use by a single patient for the local administration of ionic drug solutions into the body for medical purposes. There are multiple sizes and shapes of drug delivery electrodes to accommodate placement various sites on the body. The size of the return electrode is the same for all drug delivery electrode sizes. The Medical Adhes. Iontophoresis Drug Delivery Electrodes have technological characteristics equivalent to those of the predicate devices, including comparable performance specifications, comparable materials including the same buffering agent (Ag/AgCl) and polyurethane foam reservoir materials on the active drug delivery electrodes and the same buffering, self-adhering polymer on the return electrode, multiple shapes and sizes of active the drug delivery electrodes, and equivalent packaging and labeling. #### VI. Intended Use Medical Adhesivesonline, LLC. Iontophoresis Drug Delivery Electrodes are intended to be used to introduce soluble salts and other drugs into the body as an alternative to hypodermic injection. {2}------------------------------------------------ Image /page/2/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is an abstract symbol that resembles an eagle or bird in flight, composed of three curved lines. Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850 JUL - 7 2004 Mr. Adam Shaw Quality Assurance Manager Medical Adhesiveonline, LLC 10809 Garden Mist, #2045 Las Vegas, Nevada 89135 Re: K041101 Trade/Device Name: Medical Adhesiveonline, LLC. Iontophoresis Drug Delivery Electrodes Regulation Number: 21 CFR 890.5525 Regulation Name: Iontophoresis device Regulatory Class: III Product Code: EGJ Dated: April 20, 2004 Received: April 27, 2004 Dear Mr. Shaw: We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device mendments or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act), as long as you comply with all of the Act's requirements relating to drugs labeled or promoted with the device as described below. You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register. Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. {3}------------------------------------------------ Page 2 - Mr. Adam Shaw You must comply with all the Act's requirements, including, but not limited to: registration and 1 our mast compty while an labeling (21 CFR Part 801); good manufacturing practice ifsting (21 CF ITT art 007), adoning (27 systems (QS) regulation (21 CFR Part 820); and if requirements as set form in the quality by control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050. Our substantially equivalent decision does not apply to the drugs that you will label or promote Our substantially equivalent accesses assumer neither label nor promote your device for use with for use with your device. "Therefore, your device prior to FDA having approved the drugs for Specific drugs, nor package arage information on the requirements for marketing new drugs, you may contact: > Director Division of Drug Labeling Compliance (HFD-310) Center for Drug Evaluation and Research Food and Drug Administration 5600 Fishers Lane Rockville, Maryland 20857 As you are aware, iontophoresis devices that are intended to use a direct current to introduce ions 713 you are aware, tomophysis as the body and induce sweating for use in the diagnosis of cystic of softone bans or other uses, if the labeling of the drug intended for use with the device bears adequate directions for the device's use with that drug, were classified into Class II. An iontophoresis device that is intended to use a direct current to introduce ions of soluble salts or rolner drugs into the body for medical purposes other than those specified for class II devices is classified into Class III (21 CFR 890.5525). We published our strategy for calling for premarket approval (PMA) applications in the enclosed Federal Register, dated May 6, 1994, and the apploval (1 mill application of the enclosed Federal Register, dated August 22, 2000. If you have any questions regarding this letter, you may contact: Kevin Lee, M.D. Food and Drug Administration Center for Devices and Radiological Health Division of General, Restorative and Neurological Devices 9200 Corporate Boulevard (HFZ-410) Rockville, Maryland 20850 (301) 594-1296 This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market. {4}------------------------------------------------ If you desire specific advice for your device on our labeling regulation, please contact the Office 11 you desire spocific at (301) 594 - 4659. Also, please note the regulation entitled, "Misbranding by reference to premarket notification''(21 CFR Part 807.97). You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll free number (800) 638-2041 or (301) 443-6597, or at its Internet address http://www.fda.gov/cdrh/dsma/dsmamain.html. Sincerely yours, Muriàm C. Provost Celia M. Witten, Ph.D., M.D. Director Division of General, Restorative and Neurological Devices Office of Device Evaluation Center for Devices and Radiological Health Enclosure {5}------------------------------------------------ ## Indications for Use 510(k) Number (if known): K o 4-11 0 I Delivery Electrodas Drug or tophores is Device Name; Indications For Use: Medical Adhesive online, LLC. I ontopher esis introduce is Electrodes are indicated to drugs into the bo other Saluble Salts Prescription Use (Part 21 CFR 801 Subpart D) AND/OF ? (21 CFR 801 Subpart C PLEASE DO NOT WRITE BELOW THIS .'NE-CONTINUE ON ANOTHER PAGE IF NEEDED) Concurrence of CDRH, Offic a of Device Evaluation (ODE) Miriam C. Provost (Division Sign-Off) Division of General, Restorative, and Neurological Devices Page 1 of *_*_ **510(k) Number** K041101
Innolitics
510(k) Summary
Decision Summary
Classification Order
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