(23 days)
The Bak'Snap DuoProSS™ Retractable Safety Syringe is a sterile, single-use, disposable and non-reusable, manual, retractable safety syringe intended for injection of fluids into the body, while reducing the risk of sharps injuries and the potential for syringc reuse.
The 10 mL Bak'Snap DuoProSS™ Retractable Safety Syringe is a sterile, single-use, disposable and non-rcusable, manual, retractable safety syringe provided with or without needle. The modifications to the cleared product are the addition of a brand name, a change in syringe volume, and a change in a single syringe material.
The provided document is a 510(k) summary for a medical device (10 mL Bak'Snap DuoProSS™ Retractable Safety Syringe), which focuses on demonstrating substantial equivalence to a predicate device rather than presenting a study proving performance against acceptance criteria in the context of an AI/algorithm-based device.
Therefore, most of the requested information regarding acceptance criteria, study design, expert involvement, and ground truth for an AI device is not available in these documents. The document describes a traditional medical device (a syringe), not an algorithm or AI product.
Here's an attempt to address the prompts based only on the provided text, recognizing that it pertains to a physical device and not an AI algorithm:
Based on the provided K034031 510(k) Summary for the 10 mL Bak'Snap DuoProSS™ Safety Syringe, the detailed information typically required for an AI/algorithm-based device's acceptance criteria and proving study is not present. This document describes a traditional medical device (a syringe) and its substantial equivalence to a predicate device, rather than the performance of a diagnostic or predictive algorithm.
However, I can extract information related to the device's functional intent and general testing performed.
1. A table of acceptance criteria and the reported device performance
The document does not explicitly list quantitative acceptance criteria in terms of performance metrics (like sensitivity, specificity, AUC) for an AI device, nor does it report specific performance values in that context. Instead, it focuses on demonstrating substantial equivalence based on intended use, design, and technological/operational characteristics, and conformance to standards.
| Acceptance Criterion (Inferred from testing section) | Reported Device Performance (Inferred/Stated) |
|---|---|
| Conformance to standards | Demonstrated conformance to standards |
| FDA guidance comparison with predicate device | Demonstrated comparison with predicate device |
| Biocompatibility (per ISO 10993) | Biocompatibility testing performed |
| Reduces risk of sharps injuries | Intended to reduce sharps injuries |
| Reduces potential for syringe reuse | Intended to reduce syringe reuse |
| Sterile, single-use, disposable, non-reusable | Device is sterile, single-use, disposable, non-reusable |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
Not applicable. The document refers to "verification and validation testing" but does not specify sample sizes for specific tests or the provenance of any 'data' in the context of an algorithm's test set. This is a physical device, and testing would involve physical samples, not a data test set for an algorithm.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)
Not applicable. This information is relevant for AI/algorithm validation, not for the substantial equivalence demonstration of a physical medical device like a syringe.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable. This is typically used for resolving discrepancies in expert labeling or ground truth establishment for AI models.
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 study type is for evaluating the impact of AI on human performance, and this document pertains to a physical syringe, not an AI system.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. This concept applies to the performance of an AI algorithm in isolation.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
Not applicable in the context of an AI algorithm's ground truth. For a physical device like a syringe, "ground truth" would relate to whether the device meets its functional specifications and safety requirements (e.g., sterility, non-reusability, physical dimensions, retraction mechanism function), likely assessed through engineering tests and adherence to standards.
8. The sample size for the training set
Not applicable. This device is not an AI algorithm that requires a training set.
9. How the ground truth for the training set was established
Not applicable. This information pertains to AI model development.
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JAN 2 1 2004
510(k) Summary for the 10 mL Bak'Snap DuoPro™ Safety Syringe (DuoProSS™) (per 21CFR807.92)
1. SPONSOR
M.K. Meditech Co., Ltd. Suite 702, 7th Floor No. 5, Chingdau E. Rd. Taipei, 100 Taiwan, ROC
Contact Person: 1-Ming Shih Telephone: 886-3-3166399, extension 883
Date Prepared: December 23, 2003
2. DEVICE NAME
| Proprietary Name: | 10 mL Bak'Snap DuoProSS™ Retractable Safety Syringe |
|---|---|
| Common/Usual Name: | Hypodermic Syringe (with needle) |
| Classification Name: | Piston syringe |
| Hypodermic single lumen needle |
3. PREDICATE DEVICES
- 5 mL DuoPro™ Safety Syringe (DuoProSS™) (K022806) .
4. DEVICE DESCRIPTION
The 10 mL Bak'Snap DuoProSS™ Retractable Safety Syringe is a sterile, single-use, disposable and non-rcusable, manual, retractable safety syringe provided with or without needle. The modifications to the cleared product are the addition of a brand name, a change in syringe volume, and a change in a single syringe material.
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INTENDED USE 5.
The Bak'Snap DuoPro™ Safety Syringe (DuoProSSTM) is a sterile, single-use, disposable and non-reusable, manual, retractable safety syringe which is intended for injection of fluids into the body, while reducing the risk of sharps injuries and the potential for syringe reuse.
TECHNOLOGICAL CHARACTERISTICS AND SUBSTANTIAL EQUIVALENCE 6.
M.K. Meditech Co., Ltd., makes a claim of substantial equivalence of the 10 mL Bak Snap DuoProSS™ Retractable Safety Syringe to the cited predicate device based on similarities in intended use, design, and technological and operational characteristics. Both are indicated for injecting fluids into the body, while helping to reduce the risk of sharps injuries. Both the 10 mL Bak'Snap DuoProSS™ and predicate device are provided without a needle or with single-lumen hypodermic needles (variety of lengths and gauges).
Both the 10 mL Bak'Snap DuoProSS™ and the predicate device arc provided sterile, single-use, and disposable. Both the 10 mL Bak'Snap DuoProSS™ and the predicate device have two-part plungers. The distal part holds the hypodermic needle and the proximal part has a projection spike that mates with the distal part, thereby locking the needle to the plunger. Both the 10 mL Bak'Snap DuoProSS™ and the prodicate device require the user to manually retract the needle-plunger into the syringe barrel, break of the plunger rod, and discard the picces. M.K. Meditech Co., Ltd., believes that the differences between the 10 mL Bak'Snap DuoProSS™ Retractable Safety Syringe and cited predicate device are minor and they raise no now issues of safety or effectiveness.
TESTING 7.
Verification and validation testing presented in this premarket notification includes testing to demonstrate conformance to standards, testing according to FDA guidance (comparison with predicate device), and biocompatibility testing per ISO 10993.
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Image /page/2/Picture/1 description: The image shows the seal of the Department of Health & Human Services (HHS) of the United States. The seal features a stylized eagle with three wings, representing health, human services, and well-being. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" are arranged in a circular pattern around the eagle.
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
JAN 2 1 2004
M. K. Meditech Company Limited C/O Ms. Rosina Robinson, RN Senior Staff Consultant Medical Device Consultants, Incorporated 49 Plain Street North Attleboro, Massachusetts 02760
Re: K034031
Trade/Device Name: M.K. Meditech Co., Ltd., Bak'Snap DuoProSSTM Retractable Safety Syringe Regulation Number: 21 CFR 880.5860 Regulation Name: Piston Syringe Regulatory Class: II Product Code: MEG Dated: December 23, 2003 Received: December 29, 2003
Dear Ms. Robinson:
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 commercc 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, thereforc, 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.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to such additional controls. Existing major regulations affecting vour 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. Robinson
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); 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.
This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Office of Compliance at (301) 594-4618. Also, please note the regulation entitled. "Misbranding by reference to premarket notification" (21CFR Part 807.97). 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) 443-6597 or at its Internet address http://www.fda.gov/cdrh/dsma/dsmamain.html
Sincerely yours.
Chiu Lin, Ph. D.
Chiu Lin, Ph., D. 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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510(k) Number (if known):
Device Name: M.K. Meditech Co., Ltd., Bak'Snap DuoProSS™ Retractable Safety Syringe
Indications For Use:
The Bak'Snap DuoProSS™ Retractable Safety Syringe is a sterile, single-use, disposable and non-reusable, manual, retractable safety syringe intended for injection of fluids into the body, while reducing the risk of sharps injuries and the potential for syringc reuse.
(PLEASE DO NOT WRITE BFLOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NECESSARY)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Viola Hubbard, Interim Branch Chief
510(k) Number
Prescription Use
(Per 21 CFR 801.109)
ਾਲ
Over-The-Counter Use
(Optional Format 1-2-96)
M. K. Meditech Co., Ltd., Special 510(k) December 23, 2003 10 mL Bak'Snap DuoProSS™ Retractable Safety Syringe
Page vii
§ 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).