Back to Explorer

Technical Considerations for Demonstrating Reliability of Emergency-Use Injectors Submitted under a BLA, NDA or ANDA: Draft Guidance for Industry and Food and Drug Administration Staff

DraftOffice of the Commissioner,Office of Clinical Policy and Programs,Office of Combination Products Center for Drug Evaluation and Research Center for Biologics Evaluation and Research Center for Devices and Radiological Health04/21/2020

Description

This guidance covers emergency-use injectors submitted under a biologics license application (BLA), new drug application (NDA), or abbreviated new drug application (ANDA).  The term “emergency-use injector” means injectors marketed with an emergency-use drug  as a prefilled single entity combination product under 21 CFR 3.2(e)(1) or as a co-packaged combination product under 21 CFR 3.2(e)(2).  Emergency-use injector includes pen injectors, autoinjectors, or on-body-wearable delivery systems for drugs for emergency treatment of conditions such as anaphylaxis, opioid overdose, poisoning, or severe hypoglycemia.

Scope & Applicability

Product Classes

3
Emergency-Use Injectors

Injectors marketed with an emergency-use drug as a prefilled single entity combination product or co-packaged combination product.; Technical Considerations for Demonstrating Reliability of Emergency-Use Injectors

Combination Product

Products combining drug, device, or biological constituents; Generally recommended for Enhanced Documentation; Requires 14971-based framework incorporating ICH Q9; A drug-device combination where the device constituent part detects ingestion.

Emergency-use injector

Injectors for treatment of anaphylaxis used by patients or first responders.; Technical considerations for demonstrating reliability of emergency-use injectors.; Technical considerations for demonstrating reliability of these devices.

Stakeholders

2
Lay caregiver

User who may have only one opportunity to use the product.

Applicant

Entity submitting development data and knowledge; Entity performing the work process for change

Regulatory Context

Attributes

7
Reliability

reliability includes accuracy, completeness, and traceability

Geometry / Dimension

Main Spring Geometry / Dimension contributing to failure

High Trigger Force

High Trigger Force Prevents Activation

Sample Size

statistically justified calculation required in the plan

Viscosity

Physicochemical characteristic used to assure product acceptability.

Shelf-life

intended storage conditions throughout the proposed shelf-life

Expiration date

should be based on appropriate supportive stability data

Identified Hazards

Hazards

2
Failure to successfully inject

Primary risk where functional failure modes prevent drug delivery.; The top event in the fault tree analysis for emergency-use injectors.; Top-level failure mode in reliability analysis

Environmental Stressors

Vibration, shock, temperature extremes, and air particulates.

Related CFR Sections (3)

Related Warning Letters (10)

  • CGMP/Finished Pharmaceuticals/Adulterated

    SV Labs Corporation

    2025-12-23
  • CGMP/Finished Pharmaceuticals/Adulterated

    Guangdong Renhe Guozhuang Biotechnology Co., Ltd.

    2025-12-23
  • CGMP/Finished Pharmaceuticals/Adulterated

    Medinatura New Mexico, Inc.

    2025-12-23
  • CGMP/Finished Pharmaceuticals/Adulterated

    Sklar Personal Care Inc.

    2025-12-16
  • CGMP/Deviations/Biologics License Application (BLA)

    Microvascular Tissue, Inc.

    2025-12-16
  • CGMP/Finished Pharmaceuticals/Adulterated

    Catalent Indiana, LLC

    2025-12-11
  • CGMP/Finished Pharmaceuticals/Adulterated

    DeVere Manufacturing Inc.

    2025-12-09
  • CGMP/Finished Pharmaceuticals/Adulterated

    CDL Services, Inc. DBA Technichem

    2025-12-09
  • CGMP/Finished Pharmaceuticals/Adulterated

    Seaway Pharma Inc.

    2025-12-09
  • CGMP/QSR/Medical Devices/Adulterated

    Envoy Medical Inc.

    2025-12-09

See Also (8)