K Number
K060819
Device Name
COOL.CLICK 2
Date Cleared
2006-06-16

(81 days)

Product Code
Regulation Number
880.5430
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The cool.click 2™ Needle-free Growth Hormone Delivery System is indicated for the administration of Serono's growth hormone drug products and is intended for home use by patients authorized by their physicians to self-inject.
Device Description
cool.click 2™ is a needle-free delivery device for Serono growth hormone products. The device delivers the drug product by firing a jet of liquid directly through the skin to the subcutaneous region. The jet is created via a powerful spring acting on a piston inside the nozzle and the liquid is forced out through a small aperture at high speed, creating a very fine, high pressure stream of drug that penetrates the skin. The key difference of the cool.click 2™ Needle-Free Growth Hormone Delivery System is it has a digital display to provide more clear and accurate information to users.
More Information

cool.click K050734, Serojet K003908, Clicker K994384, Reconstitution Kit & Vial Connector K010623

Not Found

No
The description focuses on the mechanical delivery mechanism and a digital display, with no mention of AI or ML capabilities.

No
The device is a delivery system for a drug, not a therapeutic device itself. Its function is to administer growth hormone, which acts as the therapeutic agent.

No

The device is described as a "Needle-free Growth Hormone Delivery System" and its purpose is to administer growth hormone drug products, not to diagnose medical conditions.

No

The device description clearly describes a physical, mechanical device ("firing a jet of liquid directly through the skin," "powerful spring acting on a piston," "digital display"). It is a hardware device for drug delivery.

Based on the provided information, the cool.click 2™ Needle-free Growth Hormone Delivery System is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use is for the administration of a drug product (growth hormone) to a patient. This is a therapeutic delivery system, not a diagnostic test performed on a sample taken from the body.
  • Device Description: The device description clearly explains how it delivers a liquid drug product through the skin. It does not describe any process of analyzing a biological sample to provide diagnostic information.
  • Lack of IVD Characteristics: The document does not mention any of the typical characteristics of an IVD, such as:
    • Analyzing biological samples (blood, urine, tissue, etc.)
    • Detecting or measuring analytes
    • Providing information for diagnosis, monitoring, or prognosis of a disease or condition

The cool.click 2™ is a drug delivery device, which falls under a different regulatory category than IVDs.

N/A

Intended Use / Indications for Use

The cool.click 2™ Needle-free Growth Hormone Delivery System is indicated for the administration of Serono's growth hormone drug products and is intended for home use by patients authorized by their physicians to self-inject.

Product codes (comma separated list FDA assigned to the subject device)

KZE

Device Description

cool.click 2™ is a needle-free delivery device for Serono growth hormone products. The device delivers the drug product by firing a jet of liquid directly through the skin to the subcutaneous region. The jet is created via a powerful spring acting on a piston inside the nozzle and the liquid is forced out through a small aperture at high speed, creating a very fine, high pressure stream of drug that penetrates the skin. The key difference of the cool.click 2™ Needle-Free Growth Hormone Delivery System is it has a digital display to provide more clear and accurate information to users.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Skin; subcutaneous region

Indicated Patient Age Range

Not Found

Intended User / Care Setting

patients authorized by their physicians to self-inject / home use

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)

Extensive design verification, functional and performance testing have been conducted. The information provided in this premarket notification demonstrates that the cool.click 2TM Needle-Free Growth Hormone Delivery System is safe and effective for the intended use and is substantially equivalent to the legally marketed predicate devices.

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

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

cool.click K050734, Serojet K003908, Clicker K994384, Reconstitution Kit & Vial Connector K010623

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found

§ 880.5430 Nonelectrically powered fluid injector.

(a)
Identification. A nonelectrically powered fluid injector is a nonelectrically powered device used by a health care provider to give a hypodermic injection by means of a narrow, high velocity jet of fluid which can penetrate the surface of the skin and deliver the fluid to the body. It may be used for mass inoculations.(b)
Classification. Class II (performance standards).

0

JUN 1 6 2006

K060819

Page 1 of 2

The Medical House

Medical House Products Limited
Pre-market NotificationRevision No :01
Product: cool.click 2™Section 5.0
510(k) SummaryEffective Date:
22 March 2006

510(k) Summary [As required by 21 CFR 907.92(a)]

A. Submitter Information:

| Submitter: | Medical House Products Limited
199, Newhall Road
Sheffield, S9 2QJ
United Kingdom |

--------------------------------------------------------------------------------------------------------
Contact person:Rose Y Guang
Quality Assurance and Regulatory Affairs Manager
E-mail:rguang@themedicalhouse.com
Phone:(+44) 1142619011
Fax:(+44) 1142431597

Date: March 22 2006

B. Device Information

Trade/Proprietary Name: cool.click 2™

Common Name: Needle-free Injector, Jet Injector

Classification Name: Jet Injector, Non-Electrically Powered Fluid Injector

  • Predicate Devices: cool.click K050734 Serojet K003908 Clicker K994384 Reconstitution Kit & Vial Connector K010623
  • cool.click 2™ is a needle-free delivery device for Serono Device Description: growth hormone products. The device delivers the drug product by firing a jet of liquid directly through the skin to the subcutaneous region. The jet is created via a powerful spring acting on a piston inside the nozzle and the liquid is forced out through a small aperture at high speed, creating a very fine, high pressure stream of drug that penetrates the skin.

5-1.

1

K060819 Page 2042

The Medical HouseMedical House Products Limited
Pre-market NotificationRevision No :01
Product: cool.click 21MSection 5.0
510(k) SummaryEffective Date:
22 March 2006

Intended Use: The cool.click 2™ Needle-free Growth Hormone Delivery System is indicated for the administration of Serono's growth hormone drug products and is intended for home use by patients authorized by their physicians to self-inject.

C. Comparison of Required technological characteristics:

cool.click 2™ Needle-Free Growth Hormone Delivery System applies the same technological characteristics as the predicated devices. It is designed similarly to the devices that are currently marked in the U. S.

The key difference of the cool.click 2™ Needle-Free Growth Hormone Delivery System is it has a digital display to provide more clear and accurate information to users.

Due to the technological identity and the same indications for use of cool.click 2™ Needle-Free Growth Hormone Delivery System and predicated devices, no additional safety items were identified.

D. Summary and conclusion of performance tests:

Extensive design verification, functional and performance testing have been conducted. The information provided in this premarket notification demonstrates that the cool.click 2TM Needle-Free Growth Hormone Delivery System is safe and effective for the intended use and is substantially equivalent to the legally marketed predicate devices.

2

The Medical House Products Limited
Pre-market NotificationSection 4.0
Indication for Use StatementRevision No :01
Product: cool.click 2™Effective Date:
22 March 2006

510(k) Number: K060819

Device Name: cool.click 2TM Needle-free Growth Hormone Delivery System

Indications for Use:

The cool.click 2™ Needle-free Growth Hormone Delivery System is indicated for the administration of Serono's growth hormone drug products and is intended for home use by patients authorized by their physicians to self-inject.

X Prescription Use (Part 21 CFR 801 Subpart D)

AND/OR

Over-The-Counter Use (21 CFR 801 Subpart C)

(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE OF NEEDED)

Concurrence of CDRH, Office of Device Evaluation (ODE)

3

Image /page/3/Picture/1 description: The image shows the logo for the U.S. Department of Health and Human Services. The logo features a stylized eagle with three stripes forming its wing. The text "DEPARTMENT OF HEALTH AND HUMAN SERVICES - USA" is arranged in a circular pattern around the eagle.

JUN 1 6 2006

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

Ms. Rose Y. Guang Quality Assurance & Regulatory Affairs Manager Medical House Products Limited 199 Newhall Road Sheffield, United Kingdom S9 2QJ

Re: K060819

Trade/Device Name: Cool.Click 2 Needle-Free Growth Hormone Delivery System Regulation Number: 880.5430 Regulation Name: Nonelectrically Powered Fluid Injector Regulatory Class: II Product Code: KZE Dated: March 22, 2006 Received: March 27, 2006

Dear Ms. Guang:

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) that do not require approval of a premarket approval application (PMA). 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 such 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.

4

Page 2 - Ms. Guang

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 (OS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

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 (21 CFR Part 801), please contact the Office of Compliance at (240) 276-0115 Also, please note the regulation entitled. "Misbranding by reference to premarket notification" (21CFR 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/industry/support/index.html.

Sincerely yours,

Chiu Lin, Ph.D.

Director Division of Anesthesiology, General Hospital, Infection Control and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

5

The Medical House
Medical House Products Limited

Pre-market Notification
Product: cool.click 2™
Section 4.0
Indication for Use Statement
Revision No:01
Effective Date:22 March 2006

510(k) Number:

Device Name: cool.click 2TM Needle-free Growth Hormone Delivery System

Indications for Use:

The cool.click 2™ Needle-free Growth Hormone Delivery System is indicated for the administration of Serono's growth hormone drug products and is intended for home use by patients authorized by their physicians to self-inject.

X Prescription Use (Part 21 CFR 801 Subpart D)

AND/OR

Over-The-Counter Use (21 CFR 801 Subpart C)

(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE OF NEEDED)

Concurrence of CDRH, Office of Device Evaluation (ODE)

Anton Vons

1-6-6 11) of Anesthesiology, General Hospital, on Control, Dental Devices