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Comparative Use Human Factors Study of a Manual vs. A Partially Automated Pen Injector for GLP-1 Receptor Agonist
Karthika Natarajan1, Andrew Clerman1, Jennifer Soosaar2
1Center for Drug Evaluation and Research, U.S. Food and Drug Administration, Silver Spring, Maryland, USA.
Clinical Pharmacology and Therapeutics
|April 17, 2026
Summary
A comparative human factors study found a generic manual pen injector to be therapeutically equivalent to a reference partially automated device for glucagon-like peptide-1 receptor agonist delivery. This supports the generic device
Area of Science:
- Pharmacology and Drug Delivery
- Human Factors Engineering
- Regulatory Science
Background:
- Injectable glucagon-like peptide-1 receptor agonists are often delivered via pen or autoinjectors.
- Emerging generic alternatives necessitate evidence of therapeutic equivalence for regulatory approval (Abbreviated New Drug Application).
- Comparative use human factors studies are an FDA-accepted method to demonstrate device substitutability.
Purpose of the Study:
- To evaluate the substitutability of a proposed generic manual pen injector for a reference partially automated pen injector.
- To assess critical task performance and dose delivery success rates between the two devices.
- To provide evidence supporting therapeutic equivalence for regulatory submissions.
Main Methods:
- A randomized, two-period, two-sequence crossover study involving 100 adult patients experienced with partially automated pen injectors.
- Subjects performed critical tasks (dose selection, injection) with both the test manual device and the reference partially automated device across two simulated scenarios.
- Noninferiority testing with a prespecified 10% margin was used to analyze co-primary endpoints (use success rates).
Main Results:
- Both co-primary endpoints demonstrated noninferiority, with all confidence bounds below the 10% margin.
- Scenario 1 (0.6 mg dose selection): Both devices achieved 95% success rates.
- Scenario 2 (3 mg dose selection and injection): The reference device achieved 100% success, while the test device achieved 95% success.
Conclusions:
- The proposed generic manual pen injector demonstrated noninferior performance compared to the reference partially automated pen injector.
- The study provides evidence supporting the substitutability of the generic manual device for the reference device.
- These findings support the use of comparative human factors studies for Abbreviated New Drug Application approval of generic drug-device combination products.
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