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510(k) Data Aggregation
(337 days)
The device is intended for use as a dispenser, a measuring device and an oral fluid transfer device. It is intended to be used to deliver fluids into the body orally or enterally. It is intended to be used in clinical or home care settings by operators ranging from qualified medical practitioners to laypersons (under the supervision of a qualified medical practitioners) in all age groups.
The Oral/Enteral Syringe with ENFit connector is a disposable enteral feeding syringe provided in a variety of sizes from 0.5ml to 60ml. The Oral/Enteral Syringe with ENFit connector consists of plunger, gasket/piston, barrel with ENFit connector, and used to deliver fluids into the body orally or connected to an enteral access device with male ENFit connector. The proposed syringe is sterilized by Ethylene Oxide Gas to achieve a SAL of 10-6 and supplied sterility maintenance package which could maintain the sterility of the device during the shelf life of three years.
This document is a 510(k) premarket notification for an Oral/Enteral Syringe with ENFit connector, seeking substantial equivalence to a predicate device. As such, it does not describe a study to prove a device meets acceptance criteria in the way a clinical trial or performance study for a novel diagnostic algorithm might. Instead, it demonstrates substantial equivalence by showing that the device meets relevant performance standards and has similar technological characteristics to a predicate device.
Therefore, many of the requested categories (sample size for test set, data provenance, number of experts, adjudication method, MRMC study, standalone performance, ground truth for test/training set, training set sample size) are not applicable in the context of this 510(k) submission for a non-active medical device like a syringe.
However, I can extract the acceptance criteria where applicable (i.e., performance standards and biocompatibility) and report the device's performance against those standards as described in the document.
Acceptance Criteria and Device Performance (Oral/Enteral Syringe with ENFit connector)
Device Under Review: Oral/Enteral Syringe with ENFit connector (K222772)
Predicate Device: Oral/Enteral Syringe with ENFit connector (K211025)
1. Table of Acceptance Criteria and Reported Device Performance
| Category / Test Type | Acceptance Criteria (Standard Reference) | Reported Device Performance / Conclusion |
|---|---|---|
| Biocompatibility | ISO 10993-1:2018 (Surface medical device-mucosal membrane, contact < 24 hours) | Biocompatibility was evaluated and "does not show any adverse effect." Specific tests: |
| In Vitro Cytotoxicity Test | ISO 10993-5:2009 | No Cytotoxicity |
| Intracutaneous Reactivity Test | ISO 10993-10:2010 | No Irritation |
| Skin Sensitization Test | ISO 10993-10:2010 | No Sensitization |
| Sterilization | ISO 11135 (Sterilization of health care products — Ethylene oxide) | Sterilization method validated to ISO11135, routine control, and monitoring parameters determined. Device is EO Sterilized to SAL 10-6. |
| EO Residue | ISO 10993-7:2008 | Complied |
| ECH Residue | ISO 10993-7:2008 | Complied |
| Shelf Life | ASTM F1980-16 (Standard Guide for Accelerated Aging of Sterile Medical Device Packages) | Shelf life of three years determined based on stability studies, including accelerated aging test. |
| Package Integrity | ASTM F88/F88M-15 (Seal strength) | All packaging deemed acceptable for protection of product and sterility maintenance after environmental conditioning and simulated transportation. |
| ASTM F1929-2015 (Blue Dye Penetration) | All packaging deemed acceptable for protection of product and sterility maintenance. | |
| ASTM F1886/F1886M-16 (Seal Integrity (Visual Inspection)) | All packaging deemed acceptable for protection of product and sterility maintenance. | |
| Product Performance | ASTM D638-22, ASTM D790-17 Procedure A (Mechanical properties of plastics) | Report of PP 5090T provided, implying compliance with these material property standards. |
| Dose Accuracy | ISO 7886-1:2017 (Sterile hypodermic syringes for single use Part 1: Syringes for manual use) | Testing performed, implying compliance with dose accuracy requirements. |
| Enteral Connectors | ISO 80369-3:2016 (Small-bore connectors for liquids and gases in healthcare applications — Part 3: Connectors for enteral applications) | Performance testing performed, implying compliance with enteral connector standards. The Gasket difference from the predicate was determined not to raise new safety/effectiveness issues as the device "passed the verification of ISO 80369-3, ISO 80369-20 and ISO 7886-1 standard tests, and the results meet the requirements." |
| General Connectors | ISO 80369-1:2018 (Small-bore connectors for liquids and gases in healthcare applications - Part 1: General requirements) | Performance testing performed, implying compliance. |
| Common Test Methods | ISO 80369-20:2015 (Small-bore connectors for liquids and gases in healthcare applications - Part 20: Common test methods) | Performance testing performed, implying compliance. |
2. Sample size used for the test set and the data provenance:
- Sample Size: Not explicitly stated for each test, but standard test methods were followed. The number of devices required for each standard (e.g., ISO 7886-1, ISO 80369-3) would dictate the sample sizes.
- Data Provenance: The tests are non-clinical (bench testing, material testing, biocompatibility testing) performed on the manufactured device. The location of testing labs is not specified, but the applicant is based in China. The data is prospective for the purpose of this submission (i.e., new tests performed on the specific device for this submission).
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not Applicable. This is a non-clinical device submission. "Ground truth" in the diagnostic/AI sense is not relevant. Performance is measured against established international and harmonized standards.
4. Adjudication method for the test set:
- Not Applicable. This refers to clinical assessments or expert review, which is not part of this type of submission. Testing involves laboratory measurements against predefined criteria in standards.
5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance:
- Not Applicable. This is a non-clinical syringe, not an AI-enabled diagnostic device.
6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:
- Not Applicable. This is a non-clinical syringe, not an AI-enabled diagnostic device.
7. The type of ground truth used:
- Not Applicable. For this type of device, performance is evaluated against objective, measurable criteria defined in international scientific and engineering standards (e.g., ISO, ASTM). There isn't a "ground truth" derived from expert consensus, pathology, or outcomes data in the context of a diagnostic product.
8. The sample size for the training set:
- Not Applicable. This is a non-AI device submission; there is no "training set."
9. How the ground truth for the training set was established:
- Not Applicable. This is a non-AI device submission; there is no "training set" or ground truth for it.
Summary of Study (Based on Submitted Information):
The "study" in this context is a collection of non-clinical performance evaluations and testing conducted to demonstrate that the Anhui Tiankang Medical Technology Co., Ltd. Oral/Enteral Syringe with ENFit connector is substantially equivalent to its predicate device. This involves:
- Biocompatibility Testing: Evaluating the device's materials for cytotoxicity, irritation, and sensitization according to ISO 10993 series. The device reported "No Cytotoxicity; No Irritation; No Sensitization."
- Sterilization Validation: Confirming the Ethylene Oxide (EO) sterilization process meets ISO 11135 standards and an SAL of 10-6, along with EO and ECH residue testing per ISO 10993-7. The device was found to comply.
- Shelf Life Determination: Performing accelerated aging tests according to ASTM F1980-16 to support a 3-year shelf life.
- Package Integrity Testing: Conducting tests like seal strength (ASTM F88/F88M-15), blue dye penetration (ASTM F1929-2015), and visual inspection (ASTM F1886/F1886M-16) to ensure packaging maintains sterility. All packaging was deemed acceptable.
- Product Performance Testing: Evaluating the syringe against specific functional standards:
- Dose accuracy according to ISO 7886-1:2017.
- Enteral connector compatibility and performance according to ISO 80369-3:2016.
- General connector requirements and common test methods from ISO 80369-1:2018 and ISO 80369-20:2015.
- Material properties referenced by ASTM D638-22 and ASTM D790-17.
The submission concludes that the non-clinical testing demonstrates the device's safety, effectiveness, and performance are comparable to the legally marketed predicate device, thereby establishing substantial equivalence. No clinical studies were included or deemed necessary for this type of device.
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