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Application for
Implantable
Insulin Pump
System
By: Camilo Pascual
Date: 04/02/15
BIOE 689Q
Table of Contents
1.0Device Description
2.0Hazard/Risk Analysis
3.0Pre-Clinical Evaluation
11
14
6.0References
18
1.0
Device Description
Device: Implantable Insulin Pump System
Components: (1) Implantable Insulin Pump, (2) Programmer Device for dosing and diagnostic,
and (3) Refill Kit.
Implant Site: The pump is implanted and anchored in the abdominal wall. The dispensing
portion of the pump is located in the peritoneal cavity while the refill port traverses the muscle.
Implant Battery Life: 10 years (requires surgical intervention to replace)
Device Class/Pathway: Class III / PMA
While insulin infusion pumps are considered a Class II device and require a 510(k) to show
substantial equivalence, this is a novel device that is implanted for a 10 year life (>30 days).
It fits into the requirements of 21 CFR 860.93, which defines it as a Class III device.
It matches well with product code LKK (Pump, Infusion, Implanted, Programmable), which
is listed as Class III device and a PMA submission type.
As per 21 CFR 812 and [1], this device would be considered a significant risk, and
therefore, an approved IDE is needed before starting clinical testing in human subjects, in
order to determine the safety and effectiveness of the device.
When intensive subcutaneous (SC) insulin treatment using multiple daily insulin injections or
continuous subcutaneous insulin delivery fails to control hyperglycemia (recommended
target for HbA1c in type 1 diabetes mellitus is below 7%) in spite of reinforced patient
education and tight medical follow-up.
Implantable insulin pump treatment, that bypasses SC barrier, has been shown as an effective
therapy in cases where SC insulin treatment fails to reach glucose control because of
defective or highly variable SC absorption of insulin, as diffusion of insulin from skin is not
reliable and results in chronic hyperglycemia.
When the therapeutic target is reached at the cost of a low immediate benefit/risk ratio
(HbA1c level below 7% at expense of recurrent severe hypoglycemia or frequent mild
hypoglycemia).
Patients that have high blood glucose variability with unpredictable hyper-and hypoglycemic
fluctuations, neither related to an irrelevant therapeutic behavior, nor secondary to apparent
skin abnormalities, while using continuous subcutaneous insulin delivery. Some of these
patients may either present recurrent severe hypoglycemic episodes or very frequent non
severe hypoglycemia.
To improve quality of life (patients may complain about multiple daily injections or burden
related to external carriage of pump and catheter).
Device Details
Abdominal Wall /
Implantation Site
Dispensing Port
Anchors
anchors to muscle with
connector
Refill Port / Septum
Figure 1: Drawing of Implantable Insulin Pump with Peritoneal Cavity from [18]. (Not to scale)
Implantable Insulin Pump
The Implantable Insulin Pump is a sterile, battery-operated, and implantable (10-year life)
programmable infusion pump with a rigid titanium housing that dispenses short, frequent pulses
of insulin into the peritoneal space. The pump uses a piston-operated driving mechanism and all
functions of the system (e.g. dosing) are controlled externally using a hand-held, batteryoperated programmer.
The reservoir volume is 15mL and the capacity of the pump allows for enough insulin to supply
the patient for at least three (3) months. The pump is refilled by a medical professional and the
injection area is numbed with a local anesthetic. Withdrawal of leftover insulin in the pump is
also performed. The pump reservoir is under negative pressure which allows the insulin to be
slowly drawn into the reservoir if the needle is placed properly and there is no need to exert
positive pressure on the syringe [6].
Programmer Device
The Implantable Insulin Pump can be programmed with the Programmer Device to provide
continuous delivery of basal insulin at user selectable rates (constant or variable) and administer
insulin boluses in user selectable amounts for meals.
The Programmer Device can also be used to provide diagnostics of the Implantable Insulin
Pump, including information regarding functionalization, volume, battery life, and error alarms.
The Pump/Programmer telemetry is accomplished by the transmission of a series of magnetic
pulses to and from the pump.
LCD Panel
Power Button
Clear Button
CL
R
I/O
Navigation Keys
SE
L
Inquire Button
IN
Q
Contraindications
Implantation of this device is contraindicated when [2, 7-9]:
a. Patients with severe emotional, psychiatric or substance abuse problems affecting skills in the
management of insulin therapy.
b. People who are unwilling or unable to maintain contact with their healthcare professional.
c. Patients with serious eating disorders that prevent any possible glucose control.
d. Patients whose vision does not allow recognition of pump signals and alarms.
e. Patients with associated severe co-morbidity affecting short-term life expectancy or patient
ability to manage insulin therapy.
f. The presence of infection is known or suspected.
g. The patient's body size or anatomy is insufficient to accommodate the size of the implanted
pump.
h. The patient is known or is suspected to be allergic to materials contained in the pump (e.g.
titanium or silicone material).
i. The patient has exhibited a prior intolerance to implanted devices.
j. Patients that are pregnant or intend to become pregnant.
k. Children who have not yet reached adult size.
l. Exposure to magnetic fields of high intensity (MRI unsafe), very high temperatures, low
atmospheric pressure (extended stays at an altitude higher or equal to 2500 m) or high
atmospheric pressure (underwater diving exceeding 8.50 m).
m. Contraindications relating to Insuman Implantable must be observed and followed per the
approved drug labeling.
NOTE: There were other details of the device that I should have and needed to include in this
section as per guidance documents on infusion pumps [15-17]. Those missing details include,
power requirements and characteristics, more details about the materials of construction (only
noted titanium and silicone in the Contraindications), pump flow rates and profiles and the
accuracy of the device, and safety/alarm functions with indications of error messages. Also, more
engineering drawings would probably be helpful.
2.0
Hazard/Risk Analysis
Potential Adverse Effects of the Device on Health
Below is a list of the potential adverse effects (or risks) related to the use of the Implantable
Insulin Pump System includes, but is not limited to, the following conditions [2, 5, 7-15]:
Insulin underdelivery
Battery depletion
Bleeding
Fibrosis
Pump stoppage
Refill errors, including incorrect volume, incorrect concentration, difficulty accessing pump
port
Septum leakage
Software error
Risks of the pump hardware problems with possible hypoglycemia from over-delivery of
insulin due to a hardware defect
Hyperglycemia and ketosis possibly leading to ketoacidosis due to pump failure resulting in
cessation of all insulin delivery due to either a hardware defect or software anomaly
Adverse side effects associated with Insuman Implantable
Allows for faster insulin absorption and action and may require smaller doses of insulin
A more rapid clearance of insulin has been suggested as the reason why severe hypoglycemia
occurs less frequently
May also contribute to restoration of glucagon secretion at exercise and after hypoglycemia
Potentially would allow for greater control than multiple daily insulin injections or
continuous subcutaneous insulin delivery
Pump
rupture
s
Valve or
septum is
broken
Softwar
e error
User
error
Faulty
supplies
Quality
testing
fails
Faulty
manufacturing
process
3.0
Pre-Clinical Evaluation
No testing data will be provided in this section (was not required), but details will be provided
regarding the Pre-Clinical Evaluation studies that were performed [7-9, 15-17, 19].
Pump qualifications would include flow accuracy determination especially at the bodys
temperature range (35-40C), at different pressure ranges or altitudes, and at different fluid
viscosities (using different insulins or fluids).
Pump life testing which includes the effect on flow rates of the 10-year life span and battery
life testing.
Cadaver studies to confirm the placement and implantation procedure for the pump.
Testing of the components, such as determination of the average septum puncture life to test
its durability and verification of valve.
Alarm testing, which includes the Programmer Device, would also be performed to confirm
the correct error messages are being displayed for alarm events, such as occlusions, low
battery, and low volume.
Software verification and validation of the Programmer Device was performed and showed
acceptable unresolved anomalies and information security.
In-vitro drug stability and compatibility testing performed on the pump indicates that
Insuman Implantable is stable for 90 days.
In-vitro stability was evaluated with the pump operating at 37C over subsequent refill
periods. The pump was evaluated regarding flow performance and stability of Insuman
Implantable.
As part of the animal studies, in-vivo samples were taken and an analysis was performed of
the solutions recovered from the pump reservoir before a refill.
The data also indicates that the sodium hydroxide (NaOH) rinse procedure is suitable to
prevent pump blockage by fibril formation.
Leachables and extractables testing were performed according to ISO 10993-13, ISO 1099315, ISO 10993-16, and ISO 10993-18.
The studies observed acceptable results for drug assay, degradation products, impurities,
leachables, extractables, and performance of the pump.
Electromagnetic compatibility between the pump and Programmer Device was demonstrated
by meeting the applicable standards in ANSI/AAMI ES606011 (Medical electrical equipment
Part I: General requirements for basic safety and essential performance) and IEC 60601-111 (Medical electrical equipment Part 1-11: General requirements for basic safety and
essential performance Collateral Standard: Requirements for medical electrical equipment
and medical electrical systems used in the home healthcare environment).
Demonstrated that the device will operate within its specification when exposed to
electromagnetic interference at the levels in the excess of those expected in normal use
environment.
Magnetic Resonance Imaging (MRI) compatibility showed that the device is MRI unsafe.
Computed Tomography (CT) compatibility evaluated the device and demonstrated its
compatibility with CT scans.
Biocompatibility Studies
This device is an implanted intraperitoneal pump, and is categorized as a permanent implant in
contact with tissue/bone. Biocompatibility studies were conducted to ensure that the components
and the finished device are safe and perform in accordance with the design specifications.
Biocompatibility testing was performed to evaluate the materials that make direct contact with
tissue/bone. The ISO 10993 Standard and the U.S. FDA Blue Book Memorandum #G95-1 were
used as guidance in determining the appropriate tests for the device. The following
biocompatibility tests were performed.
Pyrogenicity, Subchronic and Chronic Toxicity, and Acute Systemic Toxicity as per ISO
10993-11.
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are applied to the pump. These evaluations demonstrated packaging is acceptable to simulated
shipping and transit conditions.
Validation of the pump sterilization (Moist Heat) demonstrates that the sterilization processes
achieve a sterility assurance level of 10 -6, which meets the standards for a critical device
(introduced directly into blood stream or other normally sterile areas of the body).
The pump has a 2-year shelf life.
Animal Studies
Animal studies were performed in pigs to demonstrate the safety and effectiveness of
intraperitoneal delivery of insulin using the implanted pump. Other items that were evaluated
included,
Ease of implantation regarding the size/shape of the pump and its fixation in the abdominal
wall.
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4.0
To study the safety and efficacy of the Implantable Insulin Pump System for the delivery of
Insuman Implantable into the intraperitoneal space, as programmed.
Allocation: Non-Randomized
Classification: Safety/Efficacy Study
Study Design
Trial
Organization
Comparison
Group
Study
Population
Sample Size
Endpoints
Statistical
Analysis
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Inclusion
Criteria
Exclusion
Criteria
a.
b.
c.
d.
Subject has an HbA1c value greater than 7.0% at time of enrollment, as measured during the
screening visit and/or suffers from recurrent severe hypoglycemia or frequent mild
hypoglycemia;
e.
f.
g.
h.
a.
b.
Subjects anatomy is not large enough to accommodate the pumps size and weight;
c.
Subject is pregnant or is of child-bearing potential and not employing effective birth control;
d.
Subject has known allergies or sensitivities to pump materials (e.g. titanium or silicone);
e.
Subject has known allergies to Insuman Implantable or would be contraindicated for it, based
on the drug labeling (e.g. impaired renal or hepatic function);
f.
Subject has a visual impairment that prevents proper handling of the device.
g.
Subject has a major coexisting medical condition (such as a heart condition), that in the
opinion of the investigator, contraindicates an implantable pump;
h.
Subject has an occupation where he/she would be exposed to high current industrial
equipment, powerful magnets or transmitting towers, such as, electricians, electrical engineers
or MRI technicians;
k.
o.
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Data collection with CGM is started and surgery is scheduled within 3 months (visit 1)
Data collection visit about 1.5 months post-implantation and CGM will be started (visit
2)
Procedures
Data collection visit about 1.5 months after first refill and CGM will be started (visit 5)
Data collection visit about 1.5 months after second refill and CGM will be started (visit
8)
Tests and rinse and refill of pump 9 months after implantation (visit 10)
Data collection visit about 1.5 months after third refill and CGM will be started (visit 11)
Data collection visit about 1.5 months after fourth refill and CGM will be started (visit
14)
Final study clinic visit: Approximately a week later the CGM is returned (visit 15)
NOTE: After research is completed, subjects will still be cared for with the implanted pump,
having visits for refills and tests every 3 months. This long-term follow up will last until the
subject chooses to withdraw, the pump malfunctions, the FDA approves the pump for regular care,
or the company no longer supports the pump. If the subject is no longer taking part in the study,
we will have the pump removed from their body.
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5.0
15
Duration
The research takes place over 12-15 months in total. During that time, it will be necessary for you to have
a hospital stay for 2-3 days, to make 2 phone calls, for 10 minutes each call, and to come to the
clinic/hospital/health facility 15 days, for 30 minutes each day. We will provide long-term follow ups until
you choose to withdraw, the pump malfunctions, the FDA approves the pump for regular care, or the
company no longer supports the pump.
In total, you will be asked to come 15 times to the clinic in 12 months. At the end of 12-15 months, the
research will be finished and you can return every 3 months for refills.
Side Effects
Risks
By participating in this research it is possible that you will be at greater risk than you would otherwise be.
There is, for example, a risk that your disease will not get better and that the new device doesn't work
even as well as the old one. If, however, the device is not working and your A1C level does not improve
we will use standard treatments to make you more comfortable.
While the possibility of this happening is very low, you should still be aware of the possibility. We will
try to decrease the chances of this event occurring, but if something unexpected happens, we will provide
you with $750.
Benefits
If you participate in this research, you will have the following benefits: any interim illnesses will be
treated at no charge to you. If your child falls sick during this period he/she will be treated free of charge.
There may not be any benefit for you but your participation is likely to help us find the answer to the
research question. There may not be any benefit to the society at this stage of the research, but future
generations are likely to benefit.
16
Reimbursements
We will give you $500 to pay for your travel to the clinic/parking and we will give you $750 for lost work
time. You will not be given any other money or gifts to take part in this research.
Confidentiality
With this research, something out of the ordinary is being done in your community. It is possible that if
others in the community are aware that you are participating, they may ask you questions. We will not be
sharing the identity of those participating in the research.
The information that we collect from this research project will be kept confidential. Information about
you that will be collected during the research will be put away and no-one but the researchers will be able
to see it. Any information about you will have a number on it instead of your name. Only the researchers
will know what your number is and we will lock that information up with a lock and key. It will not be
shared with or given to anyone except [name who will have access to the information, such as research
sponsors, DSMB board, your clinician, etc.].
Sharing the Results
The knowledge that we get from doing this research will be shared with you through community meetings
before it is made widely available to the public. Confidential information will not be shared. There will be
small meetings in the community and these will be announced. After these meetings, we may publish the
results in order that other interested people may learn from our research.
Right to Refuse or Withdraw
You do not have to take part in this research if you do not wish to do so and refusing to participate will
not affect your treatment at this clinic in any way. You will still have all the benefits that you would
otherwise have at this clinic. You may stop participating in the research at any time that you wish without
losing any of your rights as a patient here, but if you are no longer taking part in the study, the pump will
be removed from your body. Your treatment at this clinic will not be affected in any way.)
Alternatives to Participating
If you do not wish to take part in the research, you will be provided with the established standard
treatment available at the center/institute/hospital. People who have diabetes mellitus are treated with
multiple daily injections or continuous delivery from a pump and catheter.
Who to Contact
If you have any questions you may ask them now or later, even after the study has started. If you wish to
ask questions later, you may contact any of the following: [name, address/telephone number/e-mail]
This proposal has been reviewed and approved by [name of the local IRB], which is a committee whose
task it is to make sure that research participants are protected from harm. If you wish to find out more
about the IRB, contact [name, address, telephone number]. It has also been reviewed by the Ethics
Review Committee of the World Health Organization (WHO), which is funding/sponsoring/supporting
the study.
You can ask me any more questions about any part of the research study, if you wish to. Do you
have any questions?
17
AND
I have accurately read out the information sheet to the potential participant, and to the best of my
ability made sure that the participant understands that the following will be done:
1.
2.
3.
I confirm that the participant was given an opportunity to ask questions about the study, and all
the questions asked by the participant have been answered correctly and to the best of my ability.
I confirm that the individual has not been coerced into giving consent, and the consent has been
given freely and voluntarily.
A copy of this ICF has been provided to the participant.
Print Name of Researcher/person taking the consent___________________________________
Signature of Researcher/person taking the consent____________________________________
Date ___________________________
Day/month/year
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6.0
References
[1] CDRH. Information Sheet Guidance For IRBs, Clinical Investigators, and Sponsors Significant Risk and Nonsignificant Risk Medical Device Studies. FDA (2006), Guidance
Document No. UCM126418.
[2] Renard E. et al. Implantable insulin pumps. A position statement about their clinical use.
Diabetes & Metabolism (2007), 33(2):158-166.
[3] van Dijk P.R. et al. Report of a 7 year casecontrol study of continuous intraperitoneal
insulin infusion and subcutaneous insulin therapy among patients with poorly controlled
type 1 diabetes mellitus: Favourable effects on hypoglycaemic episodes. Diabetes
Research and Clinical Practice (2014), 106(2):256-263.
[4] van Dijk P.R. et al. Continuous intraperitoneal insulin infusion in type 1 diabetes: a 6-year
post-trial follow-up. BMC Endocrine Disorders (2014), 14(30).
[5] Haveman J.W. et al. Surgical aspects and complications of continuous intraperitoneal
insulin infusion with an implantable pump. Langenbecks Arch Surg. (2010) 395(1):6571.
[6] Witkowski C.J. et al. The Implantable Peritoneal PumpA Patients Perspective. J
Diabetes Sci Technol (2008), 2(4):703706.
[7] Medasys, Inc. Summary of Safety and Effectiveness Data for Implantable Infusion Pump
Prometra Programmable Infusion Pump System. FDA (2012), PMA No. P080012.
[8] Committee for Medicinal Products for Human Use (CHMP). Assessment Report for
Insuman Implantable. European Medicines Agency (2013), Procedure No.
EMEA/H/C/000201/X/0091.
[9] Medtronic MiniMed. Summary of Safety and Effectiveness Data Artificial Pancreas Device
System, Threshold Suspend MiniMed 530G System. FDA (2013), PMA No. P120010.
[10] Kessler L. et al. Macrophage Activation in Type 1 Diabetic Patients With Catheter
Obstruction During Peritoneal Insulin Delivery With an Implantable Pump. Diabetes Care
(2001), 24(2)302-307.
[11] Jeandidier N. et al. Comparison of Antigenicity of Hoechst 21PH Insulin Using Either
Implantable Intraperitoneal Pump or Subcutaneous External Pump Infusion in Type 1
Diabetic Patients. Diabetes Care (2002), 25(1)84-88.
[12] Saudek C.D. et al. Insulin Pumps: Hopes and Expectations. FDA/NIH Joint Symposium
on Diabetes (2004).
[13] TPLC Total Product Life Cycle. Device: Pump, Infusion, Implanted, Programmable.
Product Code: LKK. Device Class: 3.
http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfTPLC/tplc.cfm?id=2589
[14] TPLC Total Product Life Cycle. Device: Pump, Infusion, Insulin. Product Code: LZG.
Device Class: 2. http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfTPLC/tplc.cfm?
id=2479
[15] CDRH. Infusion Pumps Total Product Life Cycle - Guidance for Industry and FDA Staff.
FDA (2014), Guidance Document No. UCM209337.
[16] CDRH. Guidance on 510(k) Submissions for Implanted Infusion Ports. FDA (1990),
Guidance Document No. UCM081374.
19
[17] CDRH. Guidance on the Content of Premarket Notification [510(k)] Submissions for
External Infusion Pumps. FDA (1993), Guidance Document No. UCM081337.
[18] http://web.stanford.edu/dept/radiology/radiologysite/images/Med%20students
%203,%20peritoneal%20cavity/Peritoneal%20cavity,%20normal%20+%20malignant
%20ascites%20(4).png
[19] CDRH. Use of International Standard ISO- 10993, "Biological Evaluation of Medical
Devices Part 1: Evaluation 3 and Testing" - Draft Guidance for Industry and Food and Drug
Administration Staff. FDA (2013), Guidance Document No. UCM348890.
[20] CDER. Guidance for Industry - Diabetes Mellitus: Developing Drugs and Therapeutic
Biologics for Treatment and Prevention Draft Guidance. FDA (2008), Guidance
Document No. UCM071624.
[21] Zhang Y. et al. A Hazard Analysis for a Generic Insulin Infusion Pump. J Diabetes Sci
Technol (2010), 4(2):263283.
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