K Number
K093182
Device Name
SET GRI-FILL 3.0
Date Cleared
2010-01-27

(111 days)

Product Code
Regulation Number
880.5440
Reference & Predicate Devices
Predicate For
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

SET GRI-FILL 3.0 6 to 1 is a fluid transfer set to be used in conjunction with SETS GRI-FILL 3.0 1 WAY or 2 WAY through which the same substance from up to 6 rubberstoppered glass vials may be delivered into a final IV container.

SET GRI-FILL 3.0 6 TO 1 is an ancillary device used as a fluid pathway in conjunction with the Gri-fill 3.0 Pharmacy Compounder and associated 1 way or 2 way transfer sets through which the same substance from up to 6 rubber-stoppered glass vials may be delivered into a final IV container. Equipped with a spike on each line and a 0.2 µm hydrophobic air-filter, it minimizes the formation of aerosols when preparing / dispensing the source substances. Facilitates easy puncture of thick rubber stoppers of small diameter. Provides fast fluid addition and extraction due to the large surface area of the air-filter.

This device should not be used with lipids, suspensions or solutions that are incompatible with PVC with DEHP plasticizer. Substances that are known to show incompatibility include, but are not limited to, Paclitaxel, Docetaxel, Etoposide, Carmustine, Propofol, Nitroglycerin, Isosorbide Dinitrate and Diazepam. For information concerning compatibility of substances, please consult the information provided with the substance.

Device Description

Fluid transfer set consisting of PVC tubing linking 6 minispikes to be used in conjunction with SETS GRI-FILL 3.0 1 Way or 2 Way transfer sets through which the same substance from up to 6 rubber-stoppered glass vials may be delivered into a final IV container. It is equipped with a 0.2 micron hydrophobic air-filter that minimizes the formation of aerosols when preparing and dispensing the source substances. The spike on each line facilitates easy puncture of thick rubber stoppers of small diameter. The device provides fast fluid addition and extraction due to the large surface area of the air-filter that quickly equalizes pressures.

AI/ML Overview

This document, K093182, describes the SET GRI-FILL 3.0 6 to 1, a fluid transfer set. The information provided outlines the device's technical specifications and a summary of non-clinical data used to establish substantial equivalence to predicate devices, rather than a detailed study demonstrating quantitative performance against specific acceptance criteria. This submission focuses on comparing the new device against existing, legally marketed predicate devices (QUICKPIN and FLEBOSET MULTIPLE).

Here's an analysis based on the provided text:

1. Table of Acceptance Criteria and Reported Device Performance

Acceptance Criteria (Implied)Reported Device Performance
Functional Equivalence: Device facilitates fluid transfer of same substance from up to 6 rubber-stoppered glass vials into a final IV container."Functional laboratory bench testing performed in foreseeable operating conditions showed correct operation of the device as per its intended use." (Page 3)
Aerosol Minimization: Equipped with a 0.2 µm hydrophobic air-filter to minimize aerosol formation."Equipped with a spike on each line and a 0.2 µm hydrophobic air-filter, it minimizes the formation of aerosols when preparing / dispensing the source substances." (Page 2)
Puncture Ease: Spikes facilitate easy puncture of thick rubber stoppers of small diameter."The spike on each line facilitates easy puncture of thick rubber stoppers of small diameter." (Page 1)
Fast Fluid Addition/Extraction: Due to large surface area of air-filter."The device provides fast fluid addition and extraction due to the large surface area of the air-filter that quickly equalizes pressures." (Page 1)
Material Compatibility: Materials must be compatible with its intended use and substances it contacts (except specified incompatibilities with PVC with DEHP plasticizer)."All materials used in the construction of SET GRI-FILL 3.0 6 to 1 have been subject to chemical and biological testing in accordance with the applicable requirements taking account of its intended use." (Page 3)
Safety: No adverse influence on safety by new technological characteristics."Technological differences including the different output connector configuration on the transfer set have been addressed and verified by bench-testing to have no adverse influence on the safety and performance of the proposed device." (Page 3)

2. Sample Size Used for the Test Set and Data Provenance

  • Test Set Sample Size: Not explicitly stated. The document refers generally to "bench testing" and "functional laboratory bench testing" (Page 3). It does not provide specific numerical sample sizes for these tests.
  • Data Provenance: The studies were non-clinical, functional laboratory bench tests. The submitter is Laboratorios Grifols, S.A. in Barcelona, Spain. The data is thus likely from retrospective internal testing performed by the manufacturer in Spain.

3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications of Those Experts

  • This information is not provided. The evaluation relies on "functional laboratory bench testing" and "chemical and biological testing" rather than human expert interpretation of results. The ground truth for device performance would be established by the physical and chemical properties of the device itself and its interaction with fluids, as measured in a lab setting, not by human experts.

4. Adjudication Method for the Test Set

  • An adjudication method is not applicable here as the "ground truth" is determined by objective physical and chemical testing, not by expert consensus on subjective interpretations.

5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, and Effect Size of Human Improvement

  • No, a Multi-Reader Multi-Case (MRMC) comparative effectiveness study was not done. This is a medical device (fluid transfer set), not an imaging or diagnostic AI tool that would typically involve human readers.

6. If a Standalone (Algorithm Only Without Human-in-the-Loop Performance) Was Done

  • This is not applicable as the device is a physical medical device, not a software algorithm. The "performance" refers to the device's physical function and material compatibility, which is inherently "standalone" in its operation.

7. The Type of Ground Truth Used

  • The ground truth used primarily involves the physical and chemical performance measurements of the device components and the assembled system in a laboratory setting. This includes:
    • Verification of fluid transfer functionality.
    • Measurement of aerosol minimization (implied by the 0.2 µm hydrophobic filter).
    • Assessment of spike puncturing capability.
    • Evaluation of fluid addition/extraction speed.
    • Chemical and biological compatibility testing of materials.

8. The Sample Size for the Training Set

  • This concept is not applicable here. This is a physical medical device, not a machine learning model that requires a training set.

9. How the Ground Truth for the Training Set Was Established

  • Not applicable, as there is no "training set" for a physical medical device.

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K093182

GRIFOLS

TECHNICAL EVALUATION # Document: DOCUMENTATION

TED-SET GRI-FILL 3.0 6 to 1 -05

SECTION 5 - SET GRI-FILL 3.0 6-to-1: 510(k) SUMMARY

JAN 2 7 2010

DATE OF SUBMISSION:

2009-09-24

SUBMITTER NAME: SUBMITTER ADDRESS: Laboratorios Grifols, S.A. C/ Can Guasch, 2 08150 PARETS DEL VALLES BARCELONA SPAIN

Contact person:

Phone: e-mail:

DEVICE TRADE NAME: COMMON NAME: CLASSIFICATION NAME:

PREDICATE DEVICE(S):

Sebastián Gascón C/ Can Guasch, 2 08150 PARETS DEL VALLES + 34 93 571 01 40 sebastian.gascon@grifols.com

SET GRI-FILL 3.0 6 to 1 I.V. FLUID TRANSFER SETS I.V. FLUID TRANSFER SETS (21 CFR 880.5440)

QUICKPIN (Laboratorios Grifols - K082752) FLEBOSET MULTIPLE (Laboratorios Grifols - K040456)

DEVICE DESCRIPTION:

Fluid transfer set consisting of PVC tubing linking 6 minispikes to be used in conjunction with SETS GRI-FILL 3.0 1 Way or 2 Way transfer sets through which the same substance from up to 6 rubber-stoppered glass vials may be delivered into a final IV container. It is equipped with a 0.2 micron hydrophobic air-filter that minimizes the formation of aerosols when preparing and dispensing the source substances. The spike on each line facilitates easy puncture of thick rubber stoppers of small diameter. The device provides fast fluid addition and extraction due to the large surface area of the air-filter that quickly equalizes pressures.

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GRIFOLS

TECHNICAL EVALUATION DOCUMENTATION

Document:

TED-SET GRI-FILL 3.0 6 to 1 -05

SECTION 5 - SET GRI-FILL 3.0 6-to-1: 510(k) SUMMARY

INTENDED USE:

SET GRI-FILL 3.0 6 to 1 is a fluid transfer set to be used in conjunction with SETS GRI-FILL 3.0 1 WAY or 2 WAY through which the same substance from up to 6 rubberstoppered glass vials may be delivered into a final IV container.

INDICATIONS FOR USE (as stated in the Statement provided in Section 4):

SET GRI-FILL 3.0 6 TO 1 is an ancillary device used as a fluid pathway in conjunction with the Gri-fill 3.0 Pharmacy Compounder and associated 1 way or 2 way transfer sets through which the same substance from up to 6 rubber-stoppered glass vials may be delivered into a final IV container. Equipped with a spike on each line and a 0.2 µm hydrophobic air-filter, it minimizes the formation of aerosols when preparing / dispensing the source substances. Facilitates easy puncture of thick rubber stoppers of small diameter. Provides fast fluid addition and extraction due to the large surface area of the air-filter.

This device should not be used with lipids, suspensions or solutions that are incompatible with PVC with DEHP plasticizer. Substances that are known to show incompatibility include, but are not limited to, Paclitaxel, Docetaxel, Etoposide, Carmustine, Propofol, Nitroglycerin, Isosorbide Dinitrate and Diazepam. For information concerning compatibility of substances, please consult the information provided with the substance.

This device is intended to be used by trained healthcare personnel. It is restricted to sale by or on the order of a physician.

SUMMARY OF COMPARISON WITH PREDICATE DEVICE:

In the establishment of substantial equivalence, SET GRI-FILL 3.0 6 to 1 is compared with another vial access device (QUICKPIN) and with IV fluid transfer sets (FLEBOSET MULTIPLE) both previously marketed by Laboratorios Grifols.

As described in Section 12 of this submission, features, technological characteristics, mechanical specifications and bench performance of the proposed device have been compared in detail with those of the predicate devices.

On the basis of this data, we believe that the new 6 to 1 device consists of a combination of the predicate devices incorporating small dimension spikes equivalent to the Quickpin on a multiple path fluid transfer set similar to the Fleboset Multiple. Fluid transfer tubing material on the new device is identical to the fluid transfer tubing material of the predicate transfer set. Differences that may be highlighted between the new and predicate devices include the configuration of the output connectors. All differences have been addressed in the different bench tests performed on the proposed device and are discussed further in Section 12 of this submission.

{2}------------------------------------------------

GRIFOLS

TECHNICAL EVALUATION DOCUMENTATION

Document: TED-SET GRI-FILL 3.0 6 to 1 -05

SECTION 5 - SET GRI-FILL 3.0 6-to-1: 510(k) SUMMARY

SUMMARY DISCUSSION OF NON-CLINICAL DATA:

All materials used in the construction of SET GRI-FILL 3.0 6 to 1 have been subject to chemical and biological testing in accordance with the applicable requirements taking account of its intended use. Functional laboratory bench testing performed in foreseeable operating conditions showed correct operation of the device as per its intended use.

CONCLUSIONS:

We believe the intended use, the indications for use, the functionality and the operation of the SET GRI-FILL 3.0 6 to 1 combines the indications for use, functionality and operation of the mentioned predicate devices QUICKPIN and FLEBOSET MULTIPLE. Technological differences including the different output connector configuration on the transfer set have been addressed and verified by bench-testing to have no adverse influence on the safety and performance of the proposed device. Hence, substantial equivalence of SET GRI-FILL 3.0 6 to 1 with the legally marketed predicate devices may be established.

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Image /page/3/Picture/0 description: The image shows the text "DEPARTMENT OF HEALTH & HUMAN SERVICES". The text is in a sans-serif font and is black. To the left of the text is a symbol that is made up of three lines.

Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002

Mr. Sebastián Gascón Technical Director Laboratorios Grifols, S. A. C/ Can Guasch, 2 08150 Parets Del Valles Barcelona SPAIN

JAN 2 7 2010

Re: K093182

Trade/Device Name: Set Gri-Fill 3.0 6 to 1 Regulation Number: 21 CFR 880.5440 Regulation Name: Intravascular Administration Set Regulatory Class: II Product Code: LHI Dated: December 18, 2009 Received: December 24, 2009

Dear Mr. Gascón:

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 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 -- Mr. Gascón

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 (OS) 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/cdrh/mdr/ 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 (240) 276-3150 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.

Sincerely yours,

h fa.

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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GRIFOLSTECHNICAL EVALUATION DOCUMENTATION
# Document:TED-SET GRI-FILL 3.0 6 to 1-04
SECTION 04 – SET GRI-FILL 3.0 6 TO 1:
INDICATIONS FOR USE STATEMENT

Indications for Use

K093182 510(k) Number (if known):

Device Name: SET GRI-FILL 3.0 6 TO 1

Indications For Use:

SET GRI-FILL 3.0 6 TO 1 is an ancillary device used as a fluid pathway in conjunction with the Gri-fill 3.0 Pharmacy Compounder and associated 1 way or 2 way transfer sets through which the same substance from up to 6 rubber-stoppered glass vials may be delivered into a final IV container. Equipped with a spike on each line and a 0.2 um hydrophobic air-filter, it minimizes the formation of aerosols when preparing / dispensing the source substances. Facilitates easy puncture of thick rubber stoppers of small diameter. Provides fast fluid addition and extraction due to the large surface area of the air-filter.

This device should not be used with lipids, suspensions or solutions that are incompatible with PVC with DEHP plasticizer. Substances that are known to show incompatibility include, but are not limited to, Pacifiaxel, Docetaxel, Etoposide, Carmustine, Propofol, Nitroglycerin, Isosorbide Dinitrate and Diazepam. For information concerning compatibility of substances, please consult the information provided with the substance.

This device is intended to be used by trained healthcare personnel. It is restricted to sale by or on the order of a physician.

V Prescription Use (Part 21 CFR 801 Subpart D) AND/OR

Over-The-Counter Use (21 CFR 801 Subpart C)

(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)

Concurrence of CDRH, Office of Device Evaluation (ODE)

(Division Sign. 08)

(Division Sign-UR) Division of Anesthesiology, General Hospital Infection Control, Dental Devices

510(k) Number: K093182

Page 1 of

§ 880.5440 Intravascular administration set.

(a)
Identification. An intravascular administration set is a device used to administer fluids from a container to a patient's vascular system through a needle or catheter inserted into a vein. The device may include the needle or catheter, tubing, a flow regulator, a drip chamber, an infusion line filter, an I.V. set stopcock, fluid delivery tubing, connectors between parts of the set, a side tube with a cap to serve as an injection site, and a hollow spike to penetrate and connect the tubing to an I.V. bag or other infusion fluid container.(b)
Classification. Class II (special controls). The special control for pharmacy compounding systems within this classification is the FDA guidance document entitled “Class II Special Controls Guidance Document: Pharmacy Compounding Systems; Final Guidance for Industry and FDA Reviewers.” Pharmacy compounding systems classified within the intravascular administration set are exempt from the premarket notification procedures in subpart E of this part and subject to the limitations in § 880.9.