(30 days)
The BD Emerald™ Saf-T Single Use, Hypodermic Syringe is intended for use by health care professionals for general purpose aspiration and injection of fluids.
The BD Emerald™ Saf-T Single Use, Hypodermic Syringe is a three-piece sterile, single use, hypodermic syringe with a 6% Luer taper tip and an integrated Sharps Injury Prevention Feature. The syringe is provided in the following syringe sizes: 3ml, 5ml, and 10ml. All sizes will be available with a Luer Lock tip and may be packaged as a syringe only, or syringe and needle combination.
The syringe assembly consists of a lubricated polypropylene barrel with a graduated scale, a resin stopper, a polypropylene plunger rod and a polypropylene sharps injury prevention feature. The sharps injury prevention feature consists of a pivoting cover that can be manually rotated forward after use, allowing for secure encapsulation of the needlepoint. The polypropylene syringe barrel incorporates a male 6% (Luer) connector, and is connectable to a compatible female 6% (Luer) connector. The needle assembly consists of a lubricated stainless steel needle attached to a polypropylene hub with epoxy.
The provided text describes the 510(k) submission for the BD Emerald™ Saf-T Single Use Hypodermic Syringe. This is a medical device modification and the acceptance criteria and supporting studies are focused on demonstrating substantial equivalence to predicate devices, rather than establishing de novo performance for a new type of device. Therefore, many of the typical elements requested for AI/Software as a Medical Device (SaMD) studies (like MRMC studies, training set details, or ground truth establishment by experts for specific diagnostic tasks) are not applicable here.
Here's an analysis based on the provided document:
Acceptance Criteria and Study Details for BD Emerald™ Saf-T Single Use Hypodermic Syringe
1. Table of Acceptance Criteria and Reported Device Performance
The acceptance criteria for this device are primarily based on meeting established international standards and demonstrating equivalence to predicate devices, rather than specific performance metrics like sensitivity/specificity for a diagnostic task.
| Acceptance Criteria Category | Specific Criteria / Standard Met | Reported Device Performance |
|---|---|---|
| Intended Use | Same as predicate devices | Yes, "intended for use by health care professionals for general purpose aspiration and injection of fluids." |
| Operating Principle | Same as predicate devices | Yes |
| Manual Use Requirements | Meet ISO 7886-1:1993 | "Successfully tested to meet the applicable requirements outlined in ISO 7886-1: 1993" |
| Material Biocompatibility | Comply with ISO 10993-1:2009 | "Successfully tested to meet the applicable requirements outlined in ISO 10993-1: 2009" |
| Sterility Assurance Level (SAL) | 10⁻⁶ | "Sterilized to a Sterility Assurance Level (SAL) of 10-6" |
| Needle Requirements (if applicable) | Meet ISO 7864:1993, ISO 9626:2001 | "Needles... meet the applicable requirements outlined in ISO 7864:1993, Sterile Hypodermic Needles for Single Use and ISO 9626: 2001" |
| Sterilization Process | Meet ISO 11135-1 | "Successfully tested to meet the applicable requirements outlined in ISO 11135-1" |
| Design Verification Testing | Equivalent performance to predicate devices | "Results of Design Verification tests demonstrate that the BD Emerald™ Saf-T Single Use, Hypodermic Syringe performed in an equivalent manner to the predicate devices" |
| Does not raise new safety/effectiveness issues | No new issues compared to predicate devices | "The differences between... do not raise new issues of safety or effectiveness." |
2. Sample Size Used for the Test Set and Data Provenance
The document does not specify a distinct "test set" in the context of an AI/SaMD study, as this is a medical device (syringe) rather than a software algorithm. The "testing" refers to physical and biological performance tests.
- Sample Size: Not explicitly stated as a single "test set" size. The document refers to various tests conducted according to international standards (e.g., ISO 7886-1). These standards typically define sampling plans and sample sizes for the specific tests (e.g., tensile strength, flow rate, biocompatibility). These numbers are not provided in this summary.
- Data Provenance: Not applicable in the context of country of origin for clinical imaging data or retrospective/prospective studies. The data provenance would be the manufacturing facility and laboratories where the physical and biological tests were performed.
3. Number of Experts Used to Establish Ground Truth and Qualifications
- Number of Experts: Not applicable. The "ground truth" for a mechanical device like a syringe is adherence to engineering specifications and performance standards through physical measurement and biological testing. It does not involve expert image interpretation or diagnostic adjudication.
- Qualifications of Experts: Not applicable in the context of radiologists or similar clinical experts. The "experts" involved would be engineers, material scientists, and laboratory technicians proficient in performing and interpreting the results of the relevant ISO standard tests.
4. Adjudication Method
- Adjudication Method: Not applicable. There is no concept of adjudication for a test set in the way it is used for clinical diagnostic performance studies. Performance is measured against physical and biological specifications.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
- MRMC Study: No, an MRMC comparative effectiveness study was not done. This type of study is relevant for diagnostic algorithms where human readers interpret medical images or data. This device is a physical medical instrument (syringe).
- Effect Size of Human Readers with/without AI: Not applicable.
6. Standalone (Algorithm Only) Performance Study
- Standalone Study: No, a standalone algorithm performance study was not done. This device is not an algorithm; it is a physical syringe.
7. Type of Ground Truth Used
- Type of Ground Truth: The "ground truth" implicitly used for this device's performance evaluation is adherence to established international standards (e.g., ISO 7886-1, ISO 10993-1, ISO 11135-1) and internal design specifications. These standards define measurable physical, chemical, and biological properties that the device must meet.
8. Sample Size for the Training Set
- Sample Size for Training Set: Not applicable. This device is a physical product, not a machine learning model. There is no "training set" in the AI/ML sense. The design and manufacturing processes are refined through engineering and quality control, but this is not analogous to training data for an algorithm.
9. How Ground Truth for the Training Set Was Established
- How Ground Truth for Training Set Was Established: Not applicable, as there is no training set for an algorithm. The design and development of the BD Emerald™ Saf-T syringe would have been guided by engineering principles, user needs, regulatory requirements, and historical data from previous syringe designs, with verification and validation against established standards.
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KI21283
510(K) Summary of Safety and Effectiveness
MAY 3 0 2012
Submitted By:
Kimberly Lane Staff Regulatory Affairs Specialist BD Medical - Medical Surgical Systems l Becton Drive Franklin Lakes, NJ 07417 Tel: 201 847 7445 Fax: 201 847 5307
Date Prepared: April 13, 2012
Device Name:
| Trade Name: | BD Emerald™ Saf-T Single Use Hypodermic Syringe |
|---|---|
| Common Name: | Piston Syringe |
| Classification Name: | Syringe, Piston |
| Classification: | Class II, 21 CFR 880.5860 |
| Predicate Devices: |
| Trade Name(s): | BD EmeraldTM Single Use Hypodermic Syringe |
|---|---|
| Manufacturer: | Becton, Dickinson and Company |
| 510(k) Number(s): | K113241 |
| Trade Name(s): | BD EclipseTM Hypodermic Needle |
| Manufacturer: | Becton, Dickinson and Company |
| 510(k) Number(s): | K010188 and K043397 |
Device Description:
The BD Emerald™ Saf-T Single Use, Hypodermic Syringe is a three-piece sterile, single use, hypodermic syringe with a 6% Luer taper tip and an integrated Sharps Injury Prevention Feature. The syringe is provided in the following syringe sizes: 3ml, 5ml, and 10ml. All sizes will be available with a Luer Lock tip and may be packaged as a syringe only, or syringe and needle combination.
The syringe assembly consists of a lubricated polypropylene barrel with a graduated scale, a resin stopper, a polypropylene plunger rod and a polypropylene sharps injury prevention feature. The sharps injury prevention feature consists of a pivoting cover that can be manually rotated forward after use, allowing for secure encapsulation of the needlepoint. The polypropylene syringe barrel incorporates a male 6% (Luer) connector, and is connectable to a compatible female 6% (Luer) connector. The needle assembly consists of a lubricated stainless steel needle attached to a polypropylene hub with epoxy.
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Intended Use:
The BD Emerald™ Saf-T Single Use, Hypodermic Syringe is intended for use by health care professionals for general purpose aspiration and injection of fluids.
Technological Characteristics:
The principle device of this 510(k) premarket notification is the result of design changes to the predicate devices K113241, K010188 and K043397 which were conducted in accordance with Quality System Regulations, 21 CFR 820.
The BD Emerald™ Saf-T Single Use Hypodermic Syringe is Substantially Equivalent to the predicate devices, given that both the principle and predicate devices:
- 동 have the same intended use
- operate under the same operating principle ■
- meet the requirements for manual use as defined by ISO 7886-1: 1993 트
- have materials that comply with ISO 10993-1. 2009 and as applicable to the . intended use of the device
- are sterilized to a Sterility Assurance Level (SAL) of 10-6 ■
- demonstrate equivalent performance during design verification testing. ■
Testing:
The results of Design Verification tests demonstrate that the BD Emerald™ Saf-T Single Use, Hypodermic Syringe performed in an equivalent manner to the predicate devices and is safe and effective when used as intended.
Performance Testing:
The BD Emerald™ Saf-T Single Use Hypodermic Syringe have been designed and successfully tested to meet the applicable requirements outlined in ISO 7886-1: 1993, Sterile Hypodermic Syringes for Single Use - Part 1: Syringes for Manual Use. The needles that may be included with the syringe meet the applicable requirements outlined in ISO 7864:1993, Sterile Hypodermic Needles for Single Use and ISO 9626: 2001, Stainless Steel Needle Tubing for the Manufacture of Medical Devices.
Biocompatibility Testing:
The BD Emerald™ Saf-T Single Use Hypodermic Syringe and needles have been designed and successfully tested to meet the applicable requirements outlined in ISO 10993-1: 2009, Biological Evaluation of Medical Devices Part 1: Evaluation and testing within a Risk Management Process.
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Sterilization and Shelf-life Testing:
The BD Emerald™ Saf-T Single Use Hypodermic Syringe and needles have been designed and successfully tested to meet the applicable requirements outlined in ISO 11135-1, Sterilization of Healthcare Products – Ethylene Oxide Sterilization Process for Medical Devices.
Substantial Equivalence: 1 .
The vast similarities of the BD Emerald™ Saf-T Single Use Hypodermic Syringe to the predicate devices support the substantial equivalence in intended use, function and basic composition. The testing to voluntary standards provides additional evidence that the BD Emerald™ Saf-T Single Use Hypodermic Syringe is substantially equivalent to the predicate devices in terms of safety, efficacy and performance.
The differences between the BD Emerald™ Saf-T Single Use Hypodermic Syringe and the predicate devices do not raise new issues of safety or effectiveness.
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DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/3/Picture/1 description: The image is a black and white logo for the Department of Health & Human Services - USA. The logo features a stylized eagle or bird-like symbol with three curved lines forming its body and wings. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES-USA" is arranged in a circular fashion around the bird symbol. The text is in all caps and is smaller than the bird symbol.
Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
BD Medical Surgical C/O Ms. Kimberly Lane Staff Regulatory Affairs Specialist Becton, Dickinson and Company 1 Becton Drive MC237 Franklin Lakes, New Jersey 07417
MAY 3 0 2012
Re: K121283
Trade/Device Name: BD Emerald™ Saf-T, Single Use, Hypodermic Syringe Regulation Number: 21 CFR 880.5860 Regulation Name: Piston Syringe Regulatory Class: II Product Code: FMF Dated: April 13, 2012 Received: April 30, 2012
Dear Ms. Lane:
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 2- Ms. Lane
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 to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices /ucm115809.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.
Fol
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 Statement
510(k) Number (if known): ==
BD EmeraldTM Saf-T, Single Use, Hypodermic Syringe Device Name:
Indications for Use:
The BD Emerald™ Saf-T Single Use, Hypodermic Syringe is intended for use by health carc professionals for general purpose aspiration and injection of fluids.
Over-The-Counter Use Prescription Use X AND/OR (21 CFR 801 Subpart C) (Part 21 CFR 801 Subpart D) (PLEASE DO NOT WRITE BELOW THIS LINE – CONTINUE ON ANOTHER PAGE OF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
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(Division Sign-Off) (Division of Anesthesiology, General Hospital intection Control, Dental Devices
510(k) Number:
§ 880.5860 Piston syringe.
(a)
Identification. A piston syringe is a device intended for medical purposes that consists of a calibrated hollow barrel and a movable plunger. At one end of the barrel there is a male connector (nozzle) for fitting the female connector (hub) of a hypodermic single lumen needle. The device is used to inject fluids into, or withdraw fluids from, the body.(b)
Classification. Class II (performance standards).