(105 days)
The DANA 3cc Syringe Insulin Reservoir is an accessory to the DANA Diabecare® Insulin Pumps. The DANA 3cc Syringe Insulin Reservoir is intended for the delivery of insulin from the DANA Diabecare® Insulin Pumps using specified insulin administration sets.
The DANA 3cc Syringe Insulin Reservoir is intended exclusively for use with the DANA Diabecare® Insulin Pumps. The DANA Diabecare® Insulin Pumps are external programmable syringe infusion pumps used for the subcutaneous delivery of insulin for the treatment of diabetes mellitus. The pumps are not intended for use with blood or blood products.
The DANA 3cc Syringe Insulin Reservoir is a sterile, single-use, non-pyrogenic, syringe that is designed for use with all versions of the DANA Diabcare® Insulin pump that have been cleared for marketing in the U.S. (K001604, K022317, and K063126). The syringe reservoir is a 3 ml polypropylene syringe with a 300 unit insulin capacity that is supplied with a 22 gauge, 12.7 mm straight needle. The reservoir is filled similarly to filling an insulin syringe. Once filled and inspected for entrapped air, the needle is removed and the syringe reservoir is inserted into the distal end for attachment to the linking screw that connects the syringe reservoir to the DANA Diabecare® Insulin pump. The syringe has groves cut into the distal end for attachment to the linking screw that connects the syringe reservoir to the DANA Diabecare® Insulin Pump.
The proposed DANA 3cc Syringe Insulin Reservoir is a modification of the insulin reservoir accessory described in K001604, the original 510(k) premarket notification for the DANA Diabecare® Insulin Pump. The modification was limited to a change in the gasket configuration and material. The proposed DANA 3cc Syringe Insulin Reservoir has a ring shape gasket that is manufactured from silicone.
The provided text describes a 510(k) submission for the DANA 3cc Syringe Insulin Reservoir, focusing on its substantial equivalence to predicate devices and performance testing. However, it does not explicitly detail specific, quantified acceptance criteria or a comprehensive study report with detailed methodologies and results as one might expect from a formal performance study section.
Based on the provided information, here's a breakdown of the requested elements:
1. Table of Acceptance Criteria and Reported Device Performance
The submission does not explicitly state quantified acceptance criteria with pass/fail thresholds for specific performance metrics. Instead, it broadly states that "Design verification activities... included evaluation of physical and functional characteristics, and shelf-life testing. The results confirm that the DANA 3cc Syringe Insulin Reservoir showing to may insulin reservoir for all legally marketed versions of the DANA Diabecare® Insulin Pumps and support the claimed shelf life."
This indicates that the device met internal performance standards, but those specific standards and their numerical results are not provided in this summary. The "Comparison Chart for Determination of Substantial Equivalence" focuses on shared design features rather than performance metrics.
| Performance Metric/Characteristic | Acceptance Criteria (Not explicitly quantified in text) | Reported Device Performance |
|---|---|---|
| Physical Characteristics | (Implied: Meet design specifications)e.g., integrity of syringe, gasket fit, needle attachment. | Confirmed to meet design specifications during "evaluation of physical and functional characteristics." |
| Functional Characteristics | (Implied: Proper insulin delivery, no leakage, compatibility with DANA Diabecare® pumps) | Confirmed through "evaluation of physical and functional characteristics" to function as an insulin reservoir for DANA Diabecare® Insulin Pumps. |
| Shelf-life | (Implied: Maintain integrity and function for claimed shelf-life duration) | "Support the claimed shelf life." (Specific duration not provided in this snippet). |
| Sterility Status | Supplied Sterile | "Supplied sterile" |
| Single Use | Designed for single use | "Single use" |
| Capacity | 3ml syringe 300 unit capacity | "3 ml syringe" "300 unit capacity" |
2. Sample Size Used for the Test Set and Data Provenance
The document does not provide specific details on the sample sizes used for the design verification tests (physical, functional, shelf-life). It also does not specify the data provenance (e.g., country of origin, retrospective or prospective nature of the test data). The tests were conducted internally by Sooil Development Co., Ltd. as part of their "Design verification activities."
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
This type of information is not applicable and not provided in the context of this device. The "ground truth" for an insulin reservoir's performance would typically be established through engineering tests measuring physical and functional attributes against predefined specifications, rather than expert consensus on subjective assessments.
4. Adjudication Method for the Test Set
Not applicable. Adjudication methods (like 2+1, 3+1) are typically used in studies involving human interpretation or subjective assessment where discrepancies need resolution, such as in image analysis or clinical trials. Performance testing for a medical device like an insulin reservoir involves objective measurements, not human adjudication of subjective data.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
No. An MRMC study is not relevant for this type of device. MRMC studies are used to evaluate the diagnostic performance of human readers (e.g., radiologists) in interpreting medical images, often comparing performance with and without AI assistance. This device is an insulin reservoir, not a diagnostic imaging AI.
6. Standalone Performance Study (Algorithm Only Without Human-in-the-Loop Performance)
Yes, a "standalone" performance evaluation was conducted in the sense that the device's physical and functional characteristics were tested independently. The "Design verification activities" were focused on the device itself. While the device is an accessory intended for human use with an insulin pump, the performance reported here is of the reservoir itself, not an AI algorithm.
7. Type of Ground Truth Used
The "ground truth" for the performance testing would be established by predefined engineering specifications, design requirements, and recognized industry standards for insulin delivery devices and sterile medical components. For example, a "ground truth" for capacity would be 300 units as measured by calibrated equipment, or for sterility, it would be the absence of microbial growth as per validated sterilization methods.
8. Sample Size for the Training Set
Not applicable. This device is a physical medical device (an insulin reservoir), not an AI algorithm or a diagnostic tool that requires a "training set" of data in the machine learning sense.
9. How the Ground Truth for the Training Set Was Established
Not applicable, as there is no training set for this type of device.
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510(k) Summary for DANA 3cc Syringe Insulin Reservoir
1. SPONSOR
- 4 2007
Sooil Development Co., Ltd. 196-1, Dogok-dong, Kangnam-gu Seoul, 135-270, KOREA
Soo Bong Choi, CEO Contact: (82) 2-3463-0041 Telephone: (82) 2-3463-7077 Facsimile:
Date Prepared: July 9, 2007
2. DEVICE NAME
| Proprietary Name: | DANA 3cc Syringe Insulin Reservoir |
|---|---|
| Common/Usual Name: | Insulin reservoir |
| Classification Name: | Accessories, infusion pump |
3. PREDICATE DEVICES
- SOOIL Development Co., Ltd., DANA Diabecare® (K001604)*
- Spectrx, Inc., SimpleChoice 3.0 ml Reservoir Pro (K051045)
- Applied Diabetes Research, Inc., SureSet 3.0 ml Reservoir (K024056)
- Sterling Medivations, Inc., Simplicity Infusion Reservoir (K013767)
- Medtronic MiniMed, Inc., 3.0 ml Reservoir Model 103/193 (K991936)
- *Insulin reservoir accessory included in K001604
DEVICE DESCRIPTION
The DANA 3cc Syringe Insulin Reservoir is a sterile, single-use, non-pyrogenic, syringe that is designed for use with all versions of the DANA Diabcare® Insulin pump that have been cleared for marketing in the U.S. (K001604, K022317, and K063126). The syringe reservoir is a 3 ml polypropylene syringe with a 300 unit insulin capacity that is supplied with a 22 gauge, 12.7 mm straight needle. The
SOOIL Development Co., Ltd. Additional Information - K071418
August 20, 2007
510(k) Summary, Page 1 of 3
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reservoir is filled similarly to filling an insulin syringe. Once filled and inspected for reservoir is filled similariy to fining an insume syringer esservor is inserted into the distal entrapped air, the needle is Tentoved and the syringe has groves cut into the distal.
DANA Diabecare® Insulin pump. The syringe thas grooves cut into the DANA Diabecare® Insulin punip. The syrings pringer has g
end for attachment to the linking screw that connects the syringe reservoir to the end Tor attachmont - A Diabecare® Insulin Pump.
The proposed DANA 3cc Syringe Insulin Reservoir is a modification of the insulin
t the insults the first to 1001604 the wriving 510(k) premarket notification The proposed DANA 3CC Syringe Insumi Reserver and 510(k) premarket notification
reservoir accessory described in K001604, the woldfied to a change reservoir accessory described in Rocroor, the modification was limited to a change
for the DANA Diabecare® Insulin Pump. The moresal DANA 3cc Syringe Insulin for the DANA Diabecare@ Insumil Tamp. The monneed DANA 3cc Syringe Insulin
in the gasket configuration and material. The proposed DANA 3cc Syringe Insulin
Systems on igurati in the gasket contriguration and material.
Reservoir has a ring shape gasket that is manufactured from silicone.
5. INTENDED USE
The DANA 3cc Syringe Insulin Reservoir is an accessory to the DANA Dibecare@
in the DANA 3cc Syringe In Decemeir is interveir is intended for the delivery The DANA 3cc Syringe Insumit Reservor is intended for the delivery
Insulin Pumps. The DANA 3cc Syringe Insulin Reservor is unsuling specified, insulin Insulin Pumps. The DANA See Syrings Insulin Pumps using specified insulin administration sets.
The DANA 3cc Syringe Insulin Reservoir is intended exclusively for use with the The DANA 3cc Syringe Insulin Reserver 10 mm Diabecare® Insulin Pumps are DANA Diabecare® Insular Fumps. "The Subcutaneous delivery of
external programmable syringe infusion pumps are not intended for use external programmable syringe midslow painfor and intended for use with blood or blood products.
6. TECHNOLOGICAL CHARACTERISTICS AND SUBSTANTIAL EQUIVALENCE
The material components and technological characteristics of the proposed DANA The material colliponents and the predicate devices are similar. The proposed devices are 3.0 ml piston syringes with a 300 unit insulin capacity. The proposed devices are 3.0 In piston syringes what a comments are supplied sterile and are indicated for single use.
The proposed DANA 3cc Syringe Insulin Reservoir and the predicate devices are indicated for use only with a specified insulin pump. As stated elsewhere, the indicated for use only with a spection on the predicate insulin reservoir reservoir proposed DANA SCC Syringe modial research for use with the DANA Diabecare®
described in K001604 are designed specifically for use with the Bearner The other predicate reservoirs (SimpleChoice 3.0 ml Reservoir Insulin Pump. (K051045), Sureset 3.0 ml Reservoir (K024056), Simplicity Infusion Reservoir (K031043), Surcher 5.0 ml Reservoir (K991936)) are designed exclusively for use with the Medtronic MiniMed® pumps.
SOOIL Development Co., Ltd. Additional Information - K071418 August 20, 2007
510(k) Summary, Page 2 of 3
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| Item for Comparison | DANA 3cc SyringeInsulin Reservoir(Proposed) | DANAInsulin Reservoir(K001604) | Simplicity InfusionReservoir(K013767) | MiniMed 3.0 mlReservoir(K991936) |
|---|---|---|---|---|
| Intended Use | Infusion reservoirs for use to infuse insulin from an external infusion pump | |||
| Insulin Pump | DANA Diabecare®Insulin Pumps | DANA Diabecare®Insulin Pumps | MedtronicMiniMed® Pumps | MedtronicMiniMed® pumps |
| TechnicalSpecifications | • 3 ml syringe• 300 unit capacity | • 3 ml syringe• 300 unit capacity | • 3 ml syringe• 300 unit capacity | • 3 ml syringe• 300-unit capacity |
| Sterility Status | • Supplied sterile• Single use | • Supplied sterile• Single use | • Supplied sterile• Single use | • Supplied sterile• Single use |
Comparison Chart for Determination of Substantial Equivalence
7. PERFORMANCE TESTING
Design verification activities for the DANA 3cc Syringe Insulin Reservoir included Design vermeanon avon evaluation of physical and functional characteristics, and shelf-life testing. The results confirm that the DANA 3cc Syringe Insulin Reservoir showing to may insulin reservoir for all legally marketed versions of the DANA Diabecare® Insulin Pumps and support the claimed shelf life.
Deleted: a three-yea
SOOIL Development Co., Ltd. Additional Information - K071418
August 20, 2007
510(k) Summary, Page 3 of 3
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Image /page/3/Picture/0 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. Inside the circle is an abstract symbol that resembles a stylized caduceus or a series of interconnected human profiles.
Public Health Service
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
Sooil Development Company, Limited C/O Cynthia J.M. Nolte, Ph.D., RAC Senior Regulatory Consultant Medical Device Consultants, Incorporated 49 Plain Street North Attleboro, Massachusetts 02760
SEP - 4 2007
Re: K071418
Trade/Device Name: DANA 3cc Syringe Insulin Reservoir Regulation Number: 21 CFR 880.5725 Regulation Name: Infusion Pump Regulatory Class: II Product Code: MRZ Dated: July 9, 2007 Received: July 10, 2007
Dear Dr. Nolte:
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.
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 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 - Dr. Nolte
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 (240) 276-0115. 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 (240) 276-3150 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.
Sincerely yours,
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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Indications for Use
510(k) Number (if known): K071418
Device Name: DANA 3cc Syringe Insulin Reservoir
Indications for Use:
The DANA 3cc Syringe Insulin Reservoir is an accessory to the DANA Diabecare® Insulin Pumps. The DANA 3cc Syringe Insulin Reservoir is intended for the delivery of insulin from the DANA Diabecare® Insulin Pumps using specified insulin administration sets.
The DANA 3cc Syringe Insulin Reservoir is intended exclusively for use with the DANA Diabecare® Insulin Pumps. The DANA Diabecare® Insulin Pumps external programmable syringe infusion pumps used for the are subcutaneous delivery of insulin for the treatment of diabetes mellitus. The pumps are not intended for use with blood or blood products.
Prescription Use _____________________________________________________________________________________________________________________________________________________________ (Part 21 CFR 801 Subpart D)
AND/OR
Over-The-Counter Use _ (21 CFR 807 Subpart C) хаанаа
מחלק מערב משמעות המועד המונח של המועד המועד המועד המועד המועד המועד המועד המועד המועד המועד המונח של המועד המועד המועד המועד המוזיקה המועד המוזיקה המועד המוזיקה המועד המוזיק
מאמיני
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
id. OQ. for Chulin
(Division Sign-Off)
Division of Anesthesiology, General Hospital Infection Control, Dental Devices
510(k) Number: Lo 7 148
§ 880.5725 Infusion pump.
(a)
Identification. An infusion pump is a device used in a health care facility to pump fluids into a patient in a controlled manner. The device may use a piston pump, a roller pump, or a peristaltic pump and may be powered electrically or mechanically. The device may also operate using a constant force to propel the fluid through a narrow tube which determines the flow rate. The device may include means to detect a fault condition, such as air in, or blockage of, the infusion line and to activate an alarm.(b)
Classification. Class II (performance standards).