K Number
K033192
Device Name
RH-950
Manufacturer
Date Cleared
2003-12-22

(81 days)

Product Code
Regulation Number
890.5525
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Iontophoretic drug delivery electrodes are indicated for the administration of soluble salts or other drugs into the body for medical purposes as an alternative to hypodermic injections. They are also indicated for iontophoretic dermal administration of IONTOCAINE® (Lidocaine HCl 2% and Epinephrine 1:100,000 Topical Solution).
Device Description
An iontophoresis device is intended to use a direct current to introduce ions of soluble salts or other drugs into the body for medical purposes. Iontophoresis technology is based on the principle that an electric potential will cause ions in solution to migrate according to their electrical charges. The quantity and distribution of a drug delivered into and across the skin by iontophoresis is dependent on the charge and molecular wcight of the ion, the strength of the electrical current applied, electrode composition, duration of current flow, and numerous other factors. The IOMED, Inc. RH-950 iontophoresis electrode patch consists of an active delivery electrode and a passive return electrode. These electrodes are designed for a singlepatient, one-application use. This electrode is powered by an on-board 1.5-volt button-cell battery. The maximum allowable electrical current is controlled by means of a fixed in-series resistor included in the device, while the treatment duration is pre-defined and controlled by a printed conductive ink limit switch. The RH-950 iontophoresis electrode consists of dry, monolithic, impregnated polyester nonwoven fabric drug and clectrolyte containment pads designed to be hydrated with aqueous solutions of the drug and electrolyte immediately prior to use. It features a Silver-based metallic conductive current distribution component and a medical-grade pressure sensitive adhesive tape border for skin attachment. All components in contact with the skin are known GRAS materials and/or are listed in the National Formulary.
More Information

Not Found

No
The device description and performance studies focus on the physical and electrical properties of the iontophoresis electrode for drug delivery, with no mention of AI or ML algorithms for analysis, control, or prediction.

Yes

The device is explicitly indicated for the administration of soluble salts or other drugs into the body for medical purposes, which is a therapeutic function. It is designed to deliver medication as an alternative to injections.

No

The device is described as an iontophoretic drug delivery electrode used for administering soluble salts or other drugs into the body, indicating a therapeutic function rather than a diagnostic one.

No

The device description clearly outlines physical components such as electrodes, a battery, a resistor, a limit switch, and containment pads, indicating it is a hardware device.

Based on the provided text, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use is for the administration of drugs into the body through the skin ("iontophoretic drug delivery"). This is a therapeutic or drug delivery function, not a diagnostic one.
  • Device Description: The description details how the device works to deliver ions into the body using an electric current. This mechanism is for drug delivery, not for analyzing samples from the body to diagnose a condition.
  • Performance Studies: The performance studies focus on drug transport through the skin and dermal irritation, which are relevant to drug delivery devices, not IVDs.
  • Lack of IVD Characteristics: There is no mention of analyzing biological samples (blood, urine, tissue, etc.) or providing information for the diagnosis, monitoring, or treatment of a disease or condition based on such analysis.

Therefore, this device falls under the category of a drug delivery device, not an In Vitro Diagnostic device.

N/A

Intended Use / Indications for Use

Iontophoretic drug delivery electrodes are indicated for the administration of soluble salts or other drugs into the body for medical purposes as an alternative to hypodermic injections. They are also indicated for iontophoretic dermal administration of IONTOCAINE® (Lidocaine HCl 2% and Epinephrine 1:100,000 Topical Solution).

Product codes

KTB, EGJ

Device Description

An iontophoresis device is intended to use a direct current to introduce ions of soluble salts or other drugs into the body for medical purposes. Iontophoresis technology is based on the principle that an electric potential will cause ions in solution to migrate according to their electrical charges. The quantity and distribution of a drug delivered into and across the skin by iontophoresis is dependent on the charge and molecular wcight of the ion, the strength of the electrical current applied, electrode composition, duration of current flow, and numerous other factors.

The IOMED, Inc. RH-950 iontophoresis electrode patch consists of an active delivery electrode and a passive return electrode. These electrodes are designed for a singlepatient, one-application use.

This electrode is powered by an on-board 1.5-volt button-cell battery. The maximum allowable electrical current is controlled by means of a fixed in-series resistor included in the device, while the treatment duration is pre-defined and controlled by a printed conductive ink limit switch.

The RH-950 iontophoresis electrode consists of dry, monolithic, impregnated polyester nonwoven fabric drug and clectrolyte containment pads designed to be hydrated with aqueous solutions of the drug and electrolyte immediately prior to use. It features a Silver-based metallic conductive current distribution component and a medical-grade pressure sensitive adhesive tape border for skin attachment. All components in contact with the skin are known GRAS materials and/or are listed in the National Formulary.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Skin

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Not Found

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

Iontophoretic transport with the IOMED, Inc.RH-950 electrode of both negative and positive charged drugs was compared to transport with Iomed's RH-900 electrode in hairless mouse skin in vitro by methods described by Petelenz et al., J Controlled Release 20 (1992), 55-56 (see 'Performance' section of this document). Model drugs used for these comparisons were dexamethazone sodium phosphate (-) (corticosteroid) and lidocaine hydrochloride (+) (local anesthetic). The testing shows that these model drugs can be comparably delivered using the BH-d20.

Primary dermal irritation studies were carried out in rabbits in accordance with FDA regulations for Good Laboratory Practices (GLP) using physiological saline. The protocol was designed according to ISO 10993-10:2002, and the device was tested from both positive and negative polarities.

The results of the testing showed that the RH-900 was rated negligible when opcrated from the negative polarity (0.1) as well as from the positive polarity (0.3). These scores are based on the following scale:

  • 0.0 to 0.4: negligible
  • 0.5 to 1.9: slight i
  • 2.0 to 4.9: moderate
  • 5.0 to 8.0: severe

These scores are comparable to the IOMED, Inc. RH-900 electrode. Similar scores from the Birch Point device are not available for comparison.

The materials in the RH-950 are identical to the IOMED, Inc. RH-900, and the cytotoxicity results of both devices will be the same. Test results on the RH-900 showed a cytotoxic grade of 2 (on a 0 to 4 scale). This indicates 'mild' reactivity. This mccts USP and ISO 10993-10 requirements and shows that all the materials used in the RH-950 are safe to come in limited contact with intact pationt skin.

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s)

K031115, K990318

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 890.5525 Iontophoresis device.

(a)
Iontophoresis device intended for certain specified uses —(1)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.(2)
Classification. Class II (performance standards).(b)
Iontophoresis device intended for any other purposes —(1)Identification. 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.(2)
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.

0

DEC 2 2 2003

Image /page/0/Picture/2 description: The image shows the word "IOMED" in a bold, sans-serif font. The letters are all capitalized, and the word is slightly slanted to the right. The color of the letters is black, and the background is white. The logo is simple and modern.

SUMARY OF SAFETY AND EFFECTIVENESS Iontophoresis Electrode

Date of Summary: September 29, 2003

A. General Provisions

Submitter's Name:IOMED, Inc.
Submitter's Address:2441 South 3850 West, Suite A
Salt Lake City, UT 84120-9941
Contact Person:Curtis Jensen
Quality and Regulatory Manager
Classification Name:Iontophoresis Device
21 CFR 890.5525
Proprietary Name:RH-950
Common Name:Iontophoresis Drug Delivery Electrode

B. Name of Predicate Device(s)

  • Iontophoresis Device: K031115 . Iontophoresis Drug Delivery Electrode IOMED, Inc. RH-900
  • Iontophoresis Device: K990318 . Iontophoresis Drug Delivery Electrode Birch Point IontoPatch

C. Device Description

An iontophoresis device is intended to use a direct current to introduce ions of soluble salts or other drugs into the body for medical purposes. Iontophoresis technology is based on the principle that an electric potential will cause ions in solution to migrate according to their electrical charges. The quantity and distribution of a drug delivered into and across the skin by iontophoresis is dependent on the charge and molecular wcight of the ion, the strength of the electrical current applied, electrode composition, duration of current flow, and numerous other factors.

The IOMED, Inc. RH-950 iontophoresis electrode patch consists of an active delivery electrode and a passive return electrode. These electrodes are designed for a singlepatient, one-application use.

This electrode is powered by an on-board 1.5-volt button-cell battery. The maximum allowable electrical current is controlled by means of a fixed in-series resistor

1

included in the device, while the treatment duration is pre-defined and controlled by a printed conductive ink limit switch.

The RH-950 iontophoresis electrode consists of dry, monolithic, impregnated polyester nonwoven fabric drug and clectrolyte containment pads designed to be hydrated with aqueous solutions of the drug and electrolyte immediately prior to use. It features a Silver-based metallic conductive current distribution component and a medical-grade pressure sensitive adhesive tape border for skin attachment. All components in contact with the skin are known GRAS materials and/or are listed in the National Formulary.

D. Intended Use

Iontophoretic drug delivery electrodes are indicated for the administration of soluble salts or other drugs into the body for medical purposes as an alternative to hypodermic injections. They are also indicated for iontophoretic dermal administration of IONTOCAINE® (Lidocaine HCl 2% and Epinephrine 1:100,000 Topical Solution).

E. Drug Delivery and Biocompatibility

Drug Delivery

Iontophoretic transport with the IOMED, Inc.RH-950 electrode of both negative and positive charged drugs was compared to transport with Iomed's RH-900 electrode in hairless mouse skin in vitro by methods described by Petelenz et al., J Controlled Release 20 (1992), 55-56 (see 'Performance' section of this document). Model drugs used for these comparisons were dexamethazone sodium phosphate (-) (corticosteroid) and lidocaine hydrochloride (+) (local anesthetic). The testing shows that these model drugs can be comparably delivered using the BH-d20

Biocompatibility

Primary dermal irritation studies were carried out in rabbits in accordance with FDA regulations for Good Laboratory Practices (GLP) using physiological saline. The protocol was designed according to ISO 10993-10:2002, and the device was tested from both positive and negative polarities.

The results of the testing showed that the RH-900 was rated negligible when opcrated from the negative polarity (0.1) as well as from the positive polarity (0.3). These scores are based on the following scale:

  • 0.0 to 0.4: negligible -
  • 0.5 to 1.9: slight i
  • 2.0 to 4.9: moderate -
  • 5.0 to 8.0: severe -

These scores are comparable to the IOMED, Inc. RH-900 electrode. Similar scores from the Birch Point device are not available for comparison.

2

The materials in the RH-950 are identical to the IOMED, Inc. RH-900, and the cytotoxicity results of both devices will be the same. Test results on the RH-900 showed a cytotoxic grade of 2 (on a 0 to 4 scale). This indicates 'mild' reactivity. This mccts USP and ISO 10993-10 requirements and shows that all the materials used in the RH-950 are safe to come in limited contact with intact pationt skin.

3

Image /page/3/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo is circular and contains the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. In the center of the logo is an image of a stylized bird with its wings spread.

DEC 2 2 2003

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

Mr. Curtis Jensen Quality and Regulatory Manager lomed, Inc, 2441 South 3850 West, Suite A Salt Lake City, Utah 84120

Re: K033192

Trade/Device Name: RH-950 Iontophoretic Drug Delivery Electrode Regulation Number: 21 CFR 890.5525 (a) and (b) Regulation Name: Iontophoresis device Regulatory Class: II and III Product Code: KTB, EGJ Dated: September 29, 2003 Received: October 3, 2003

Dear Mr. Jensen:

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 Amendments, 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 devices 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. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

4

Page 2 - Mr. Curtis Jensen

Our substantially equivalent decision does not apply to drugs for use with your device. Therefore, you may neither label nor promote your device for use with specific drugs other than Iontocaine (Lidocaine HCl 2% and Epinephrine 1:100,000 Topical Solution), nor package drugs with your device prior to FDA having approved the drugs for iontophoretic administration. For 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, Marvland

As you are aware, iontophoresis devices that are 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, were classified into Class II. An iontophoresis device that is intended to use a direct current to introduce ions of soluble salts or other 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 enclosed memorandum, dated April 19, 1994, and 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, Marvland 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.

If you desire specific advice for your device on our labeling regulation, please contact the Office of Compliance at (301) 594- 4659. Also, please note the regulation entitled,

5

Page 3 - Mr. Curtis Jensen

"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,

Sincerely yours,

Mark N. Mulkern

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

Enclosures

6

Indications for Use

Applicant: Iomed, Inc.

510(k) Number (if known): K033192

Device Name: RH-950

Indications For Use: Iontophoretic drug delivery electrodes are indicated for the administration of soluble salts or other drugs into the body for medical purposes as an alternative to hypodermic injections. They are also indicated for iontophoretic dermal administration of IONTOCAINE® (Lidocaine HCl 2% and Epinephrine 1:100,000 Topical Solution).

Prescription Use (Part 21 CFR 801 Subpart D)

AND/OR

Over-the-Counter Use (21 CFR 807 Subpart C)

(PLEASE DO NOT WRITE BELOW THIS LINE – CONTINUE ON ANOTHER PAGE IF NEEDED)

Concurrence of CDRH, Office of Device Evaluation (ODE)

Mark N. Millhurn

al. Restorative

Number K033192