(14 days)
The PharmaJet Needle-free Injection System is intended to deliver various medications and vaccines intradermally by means of a narrow, high velocity fluid jet, which penetrates the skin and delivers the medicine or vaccine into the dermis. Healthcare providers who routinely administer injections may use the PharmaJet Needle-free Injection System. It may also be used by patients authorized by their physicians to self-inject, or have other individuals administer injections of prescribed medication.
The PharmaJet 0.1 ml Needle-free Iniection System (PharmaJet Svstem) is a compact, spring-loaded needle-free hypodermic injection system. The PharmaJet System consists of an injector; a reset station; a single use, sterile disposable filling adapter; and, a single use, sterile, disposable needle-free syringe. The components of the system may be sold separately for replacements as they are used. The components of the PharmaJet System are unique and cannot be used with any other needle-free system.
An injector is placed in the reset station and the lid is depressed to reset the spring in the injector. A health care worker puts a filling adapter into a vial of liquid medicine or vaccine. A Needle-free syringe is placed into the filling adapter, the liquid is drawn into the Needle-free syringe and is slightly over filled. The filled Needle-free syringe is removed from the adapter and the plunger is broken off and discarded. The Needle-free syringe is placed into the injector with a ¼ turn to the right, which positions the plunger so that a 0.1ml dose is ready for use. The Needle-free syringe is placed against the injection site; gentle pressure is applied until the inner housing stops. This action allows the trigger to be released. By depressing the trigger the spring is released and the plunger moves forward into the needle-free syringe barrel discharging the contents. Once the injection has been performed, the Needle-free syringe is properly disposed of and a new syringe may be filled, injector reset, and the system again prepped for use.
Acceptance Criteria and Study for PharmaJet 0.1 ml Needle-free Injector System
The PharmaJet 0.1 ml Needle-free Injector System underwent non-clinical testing to establish its performance and substantial equivalence to existing devices. The primary focus was on meeting the requirements of the PharmaJet 0.1ml Product and Engineering Specifications, as well as the essential requirements of ISO21649:2006 Needle-free injectors for medical use - Requirements and test methods.
1. Table of Acceptance Criteria and Reported Device Performance
| Acceptance Criteria / Test Category | Specific Test | Acceptance Limit (Implied/Standard) | Reported Device Performance (Outcome) |
|---|---|---|---|
| Bench Testing (ISO21649:2006) | Temperature (Storage) | Not explicitly stated, implied to withstand transportation/storage conditions | Successfully completed |
| Free-fall | Not explicitly stated, implied to withstand typical handling | Successfully completed | |
| Vibration | Not explicitly stated, implied to withstand typical handling/transportation | Successfully completed | |
| Shock | Not explicitly stated, implied to withstand typical handling/transportation | Successfully completed | |
| Dose Accuracy | Not explicitly stated, but critical for drug delivery as per ISO21649:2006 | Successfully completed | |
| Life Cycle | 20,000 actuations (for spring life cycle) | Successfully completed (PharmaJet 0.1ml & 0.5ml both reported 20,000) | |
| Performance Profile (Upper/Lower Limits) | Not explicitly stated, defined by ISO21649:2006 | Successfully completed | |
| Emitted Noise | Not explicitly stated, defined by ISO21649:2006 | Successfully completed | |
| Material Robustness | Needle-free Syringe Irradiated Dose Test | Maintain structural integrity and function after maximum irradiated sterilization dose | Successfully completed for Robustness |
| Microbial Ingress | Microbial Ingress Testing (Filling Adapter) | Prevent microbial ingress after disinfection | Successfully completed |
| Biocompatibility | Biological Testing (Syringe & Filling Adapter) | Meet requirements for safe short-term exposure | Successfully demonstrated |
| Disinfection Compatibility | Functional Testing after Disinfection | No degradation of performance or damage to Injectors/Reset Stations after Gluteraldehyde-based and peroxide-based high-level disinfection | Successfully demonstrated |
| Substantial Equivalence (Animal Testing) | Bleb Diameter | Comparable to Terumo 1cc Allergy Syringe | Substantially equivalent |
| Depth of Penetration (based on dermal height) | Comparable to Terumo 1cc Allergy Syringe | Substantially equivalent | |
| Dye Dermal Contact Area | Comparable to Terumo 1cc Allergy Syringe | Substantially equivalent | |
| Skin Volume Occupied by Dye (calculated) | Comparable to Terumo 1cc Allergy Syringe | Substantially equivalent |
2. Sample Size Used for the Test Set and Data Provenance
The document does not explicitly state the sample sizes used for most of the non-clinical bench tests (temperature, free-fall, vibration, shock, dose accuracy, life cycle, performance profile, emitted noise, irradiated dose test, microbial ingress, functional testing after disinfection, biological testing). These tests are typically performed on a statistically significant number of units to ensure reliability, but the exact numbers are not provided.
For the animal testing (comparative effectiveness study), the sample size is also not explicitly stated. The data provenance regarding the country of origin and whether it was retrospective or prospective is not mentioned for any of the tests. Given it's animal testing, it was inherently prospective for the purpose of this submission.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications
This information is not provided in the document. The tests performed are primarily engineering and biological studies, where "ground truth" is established by direct measurement against defined standards and technical specifications, rather than expert interpretation of data like in medical imaging.
4. Adjudication Method for the Test Set
The document does not describe any adjudication method. As mentioned above, the tests are objective measurements against established technical standards (e.g., ISO21649:2006 benchmarks, physical measurements, biological assays), rather than subjective assessments requiring adjudication.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
There was no MRMC comparative effectiveness study involving human readers with and without AI assistance mentioned. The comparative study was an animal study comparing the device against a predicate device (Terumo 1cc Allergy Syringe) to demonstrate substantial equivalence in intradermal injection characteristics. Therefore, there is no effect size given for human reader improvement with AI vs. without AI assistance.
6. Standalone (Algorithm Only) Performance
This device is a physical medical device (a needle-free injector system), not an algorithm or AI software. Therefore, the concept of "standalone (algorithm only) performance" does not apply to this submission. The tests performed demonstrate the physical and functional performance of the device itself.
7. Type of Ground Truth Used
For the various bench tests, the ground truth was established by engineering specifications, international standards (ISO21649:2006), and direct physical/chemical measurements.
For the animal study demonstrating substantial equivalence, the ground truth was based on quantifiable biological endpoints (bleb diameter, depth of penetration based on dermal height, dye dermal contact area, skin volume occupied by dye) directly measured from the animal subjects after injection.
8. Sample Size for the Training Set
The document does not mention a "training set" as this is not an AI/machine learning device. The tests described are for the validation and verification of a hardware medical device.
9. How the Ground Truth for the Training Set Was Established
As there is no training set for an AI/ML algorithm, this question is not applicable.
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6 December 2010
MAR - 2 2011
| -510(k) Summary- | KII |
|---|---|
| ------------------------- | ------------ |
| Device Name - Proprietary , Common, Classification, and Panel | |
|---|---|
| Proprietary: | PharmaJet 0.1 ml Needle-free Injector System |
| Common: | Injector, Fluid, Non-Electrically Powered |
| Injector, Fluid, Non-Electrically Powered |
|---|
| 21 CFR 880.5430; Product Code KZE, Class II |
| General Hospital |
Application Information
Applicant:
Classification:
Device Panel:
Date Prepared:
PharmaJet, Inc. 400 Corporate Circle, Suite N Golden, CO 80401
(303) 526-4278
(303) 526-4052
Telephone:
FAX:
Establishment Registration: 3004977013
Owner/Operator: 9063237
Submission Correspondent Information
Michael J. Ryan, R.A. Manager Contact: Telephone: (303) 526-4278 Ext. 4172
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Reason for Premarket Notification
New Device
Predicate Devices
PharmaJet 0.5 ml Needle-free Injection System, K081532 Terumo 1 cc Allergy Syringe, K980796
Description of the Device
The PharmaJet 0.1 ml Needle-free Iniection System (PharmaJet Svstem) is a compact, spring-loaded needle-free hypodermic injection system. The PharmaJet System consists of an injector; a reset station; a single use, sterile disposable filling adapter; and, a single use, sterile, disposable needle-free syringe. The components of the system may be sold separately for replacements as they are used. The components of the PharmaJet System are unique and cannot be used with any other needle-free system.
An injector is placed in the reset station and the lid is depressed to reset the spring in the injector. A health care worker puts a filling adapter into a vial of liquid medicine or vaccine. A Needle-free syringe is placed into the filling adapter, the liquid is drawn into the Needle-free syringe and is slightly over filled. The filled Needle-free syringe is removed from the adapter and the plunger is broken off and discarded. The Needle-free syringe is placed into the injector with a ¼ turn to the right, which positions the plunger so that a 0.1ml dose is ready for use. The Needle-free syringe is placed against the injection site; gentle pressure is applied until the inner housing stops. This action allows the trigger to be released. By depressing the trigger the spring is released and the plunger moves forward into the needle-free syringe barrel discharging the contents. Once the injection has been performed, the Needle-free syringe is properly disposed of and a new syringe may be filled, injector reset, and the system again prepped for use.
Injector
The Injector is a reusable compact spring-actuated needle-free hypodermic injector consisting of the body, inner body/safety collar, trigger, and spring. The injector is made with stainless steel and injection molded amorphous thermoplastic polyetherimide.
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Needle-free syringe
The Needle-free syringe is a sterile, single use, transparent, disposable, polypropylene container consisting of the barrel to hold 0.1ml of medicine or vaccine, a plunger to discharge the medicine or vaccine through a small diameter orifice at the forward end of the barrel, and a silicone seal on the plunger to prevent leakage of the medicine or vaccine rearward.
Reset Station
The Reset Station is used to prepare (reset) the spring, within the injector, for an injection. The reset station is made with stainless steel and injection molded amorphous thermoplastic polyetherimide.
Filling Adapter
The filling adapter allows the needle-free syringe to be filled from medicine or vaccine storage vials. The filling adapter, which does not contact the patient, is made of injection-molded polycarbonate.
Indication for Use
The PharmaJet Needle-free Injection System is intended to deliver various medications and vaccines intradermally by means of a narrow, high velocity fluid jet, which penetrates the skin and delivers the medicine or vaccine into the dermis. Healthcare providers who routinely administer injections may use the PharmaJet Needle-free Injection System. It may be used for adults and children. It can also be used by patients authorized by their physicians to self inject, or have other individuals administer injections of prescribed medication.
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Technological Characteristics
| Characteristic | PharmaJet 0.1 ml Needle-free Injection System | PharmaJet 0.5 ml Needle-free Injection System | Terumo Allergy Syringe |
|---|---|---|---|
| Actuation feature | Trigger | Trigger | Standard piston syringe |
| Trigger safety | Yes | Yes | Not Applicable (NA) |
| Spring life cycle | 20,000 | 20,000 | NA |
| Method of power | Mechanical spring | Mechanical spring | Standard piston syringe |
| Method of spring reset | External resetting device | External resetting device | NA |
| Method of medicine and/or vaccine transfer | Filling adapter | Filling adapter | Fixed hypodermic single lumen 27 gauge, 1/2"or 3/8" needle, with an intradermal bevel. |
| ISO 21649: 2006 compliance | Yes | Yes | NA |
| Volume: | 0.1ml | 0.5ml | 0.1 - 1.0 ml |
| Material | Body - polypropylenePlunger - polycarbonateSeal - silicone rubber | Body - polypropylenePlunger - polycarbonateSeal - silicone rubber | Unknown |
| Orifice Diameter | 0.007" | 0.009" | NA |
| Tip Ring Diameter | 0.419" | 0.529" | NA |
| Disposable | Yes | Yes | Yes |
| Sterile | Yes | Yes | Yes |
| Sterilization Method | Electron beam radiation | Electron beam radiation | Unknown |
Discussion of Non-clinical Tests
The purpose of the Bench Testing for the PharmaJet Needle-free Injection System was to establish that the system meets the requirements of the PharmaJet 0.1ml Product and Engineering Specifications with regard to robustness for customer needs and meet the essential requirements of ISO21649:2006 Needle-free injectors for medical use -------------------------------------------------------------------------------------------------------------------------methods.
The following tests have been successfully completed:
- Temperature, storage temperature, free-fall, vibration, shock, dose o accuracy, life cycle, performance profile upper and lower acceptance limits and emitted noise testing according to ISO21649:2006 Needlefree injectors for medical use -Requirements and test methods
- Needle-free Syringe Irradiated Dose Test for Robustness o
- Microbial Ingress Testing o
Confidential
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Animal testing was performed to demonstrate substantial equivalence to an intradermal injection using the Terumo 1cc Allergy syringe. The test results indicate that the PharmaJet 0.1 ml Needle-free Injection System is substantial equivalence to the Terumo 1 cc Allergy Syringe with regards to the three primary endpoints: bleb diameter, depth of penetration based on dermal height, dye dermal contact area, and the secondary calculated endpoint of skin volume occupied by the dye.
Maximum irradiated sterility dose test was done on the needle-free syringe to demonstrate material robustness and microbial ingress testing on the Filling Adapter was done to demonstrate that the Filling Adaptor can be disinfected using common disinfection techniques.
Biological testing conducted demonstrate that the PharmaJet Needle-free Syringe and Filling Adapter meet the requirements for safe short term exposure,
Functional testing after Gluteraldehyde-based and peroxide-based high level disinfection show no degradation of performance or damage to Injectors or Reset Stations.
Conclusion
Pre-clinical testing and bench testing have shown that for intradermal delivery with needle-free jet injection the PharmaJet 0.1 ml Needle-free Injection System is as effective, as safe, and performs as well as, or better than one of the predicate devices.
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Room-WO66-G609 Silver Spring, MD 20993-0002
Pharmajet. Incorporated C/O Mr. Jeff D. Rongero Responsible Third Party Official Underwriters Laboratories, Incorporated 12 Laboratory Drive Research Triangle, North Carolina 27709
MAR - 2 2011
Re: K110456
Trade/Device Name: PharmaJet 0.1ml Intra-dermal Needle-Free Injection System Regulation Number: 21 CFR 880.5430 Regulation Name: Nonelectrically Powder Fluid Injector Regulatory Class: II Product Code: KZE Dated: February 14, 2011 Received: February 16, 2011
Dear Mr. Rongero:
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. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
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.
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Page Mr. Rongero
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); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); 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.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm 115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to http://www.fda.gov/MedicalDevices/Safety/ReportaProblem /default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
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) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm.
Sincerely yours,
Anthony D. Watson, B.S., M.S., M.B.A. Director Division of Anesthesiology, General Hospital, Infection Control and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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Indications for Use
x110456_______________________________________________________________________________________________________________________________________________________________________ 510(k) Number (if known): Device Name: PharmaJet, Inc., PharmaJet 0.1ml Intra-dermal Needle-free Injection System Indications for Use: The PharmaJet Needle-free Injection System is intended to deliver various medications and vaccines intradermally by means of a narrow, high velocity fluid jet, which penetrates the skin and delivers the medicine or vaccine into the dermis. Healthcare providers who routinely administer injections may use the PharmaJet Needle-free Injection System. It may also be used by patients authorized by their physicians to self-inject, or have other individuals administer injections of prescribed medication.
Prescription Use X (Part 21 CFR 801 Subpart D)
AND/OR
Over-The-Counter Use (Part 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)
All C. Chyn 3/3/4
Division Sign-Off) livision of Anesthesiology, General Hospital ifection Control, Dental Devices
510(k) Number: __
Page 1 of 1
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§ 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).