(172 days)
The HSW NORM-JECT®- syringes are intended to be used to inject into, or withdraw fluids from the body. The 1 ml- syringe with a purple plunger, labeled with BOTOX® is exclusively produced for use with BOTOX® Cosmetic (onabotulinumtoxinA).
The purpose of this request is for marketing clearance of Henke-Sass, Wolf piston syringe because we have added a new purple-colored plunger for a new version of the syringe. The piston syringes covered by this submission will have the same performance as already marketed devices. The only difference will be the coloring of the plunger in adding a master batch to the original material.
The provided text describes a 510(k) submission for a piston syringe, focusing on demonstrating substantial equivalence to predicate devices rather than a study with acceptance criteria and device performance in the context of diagnostic accuracy or AI assistance.
Therefore, many of the requested elements for describing such a study (e.g., acceptance criteria for diagnostic performance, sample size for test sets with data provenance, number of experts, adjudication methods, MRMC studies, standalone performance, training set details) are not applicable to this document.
The document primarily focuses on bench testing and compliance with recognized standards to show that the new syringe, with a color change to its plunger, performs identically to existing, cleared devices.
Here's the information that can be extracted from the provided text, with the understanding that it pertains to a medical device clearance for a syringe rather than a diagnostic algorithm study:
1. A table of acceptance criteria and the reported device performance
| Acceptance Criteria Category | Specific Acceptance Criteria (Standard Reference) | Reported Device Performance (Summary) |
|---|---|---|
| Biological Evaluation | ISO 10993-1:2009 (General) | Complies (implied by substantial equivalence claim and listing of standards) |
| ISO 10993-4:2002 (Hemocompatibility) | Complies | |
| ISO 10993-5:2009 (Cytotoxicity) | Complies | |
| ISO 10993-10:2002 (Sensitization) | Complies | |
| ISO 10993-10:2002 (Irritation/Intracutaneous Reactivity) | Complies | |
| ISO 10993-11:2006 (Acute Systemic Toxicity) | Complies | |
| Physical Performance | ISO 7886-1:1993 (Sterile hypodermic syringes for single use) | Complies |
| ISO 594-1:1986 (Conical fittings with 6% taper) | Complies | |
| Sterilization & Packaging | ISO 10993-7:2008 (EtO-Residuals) | Complies |
| ISO 11135-1:2007 (Sterilization Validation EtO) | Complies | |
| ISO 11607-1:2006 (Packaging for terminally sterilized medical devices - materials, systems) | Complies | |
| ISO 11607-2:2006 (Packaging for terminally sterilized medical devices - validation) | Complies | |
| Overall Comparison | Substantial Equivalence to Predicate Devices (K821537, K063280) | Device has identical operating principles and same intended uses as predicate devices. The only difference is the coloring of the plunger, which does not affect performance. |
2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
This information is not provided in the document. The submission references international ISO standards for testing but does not detail the specific sample sizes or provenance of data for each test. For a syringe, testing would typically involve a predefined number of units per lot to meet standard requirements, but these specifics are not included in this summary.
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)
This is not applicable as the document describes a physical medical device (syringe) and its compliance with engineering and biological safety standards, not a diagnostic device relying on expert interpretation for ground truth.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
This is not applicable for the same reasons as above.
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
This is not applicable as this submission is for a physical syringe, not an AI-assisted diagnostic device or a study involving human readers.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
This is not applicable as this submission is for a physical syringe, not an algorithm or AI device.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
The "ground truth" for this device is based on compliance with established international standards (ISO standards) for material safety, physical performance, sterilization, and packaging, as well as demonstrating identical operating principles and intended uses to legally marketed predicate devices. There wouldn't be a "ground truth" in the diagnostic sense (like pathology or expert consensus).
8. The sample size for the training set
This is not applicable as this submission is for a physical syringe, not a machine learning or AI device that requires a training set.
9. How the ground truth for the training set was established
This is not applicable for the same reasons as above.
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Attachment 13.2 - Replaces original Section 15
Section 15 - Summary of Safety & Effectiveness
Henke Sass Wolf GmbH 510(k) Submission
NOV 22 2010
1
Submitter:
Henke-Sass, Wolf GmbH Keltenstrasse 1 78532 Tuttlingen Germany
Manufacturing site:
ALMO Erzeugnisse Erwin Busch GmbH Grosse Allee 84 34454 Bad Arolsen Germany
Submission Correspondent / Contact Person:
Lyle Howard Corporation / Lynette Howard 106 East 5th Avenue Mount Dora, FL 32757
Premarket Notification information required by 21 CFR Part 807, subpart E is as follows:
1. GENERAL INFORMATION
| Classification Name: | piston syringe |
|---|---|
| Common usual name: | piston syringe |
| Proprietary name: | sterile single use syringe (NORM-JECT®) |
| Establishment Registration Number (submitter): | 8010418 |
| Establishment Registration Number (manufacturing Site): | 8010674 |
Classification: Class II, FMF, Panel: 80, Regulation Number: 21 CFR 880.5860
The purpose of this request is for marketing clearance of Henke-Sass, Wolf piston syringe because we have added a new purple-colored plunger for a new version of the syringe.
The piston syringes covered by this submission will have the same performance as already marketed devices. The only difference will be the coloring of the plunger in adding a master batch to the original material. The safety and effectiveness will be comparable to the predicate devices.
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Indications for Use:
"The HSW NORM-JECT®- syringes are intended to be used to inject into, or withdraw fluids from the body. The 1 ml- syringe with a purple plunger, labeled with is exclusively produced for for use with BOTOX® Cosmetic BOTOX® (onabotulinumtoxinA)."
SUBSTANTIAL EQUIVALENCE:
The Henke-Sass, Wolf piston syringe is substantially equivalent to the Henke-Sass, Wolf piston syringes under 510(k)# (K821537) and the B.Braun piston syringes under 510(k)# (K063280). (The manufacturing site of B.Braun is also ALMO, Establishment Registration Number: 8010674.)
SAFETY AND EFFECTIVENESS INFORMATION:
The Henke-Sass, Wolf piston syringe is well recognized as being safe and effective for the declared intended use. The Henke-Sass. Wolf piston syringe does have the identical operating principles and the same intended uses than the predicate devices such as Henke-Sass, Wolf piston syringes under 510(k) # K821537 and B.Braun piston syringes under 510(k) # (K063280) already in commercial distribution.
Testing conducted to assure safety and effectiveness includes but is not limited to:
- Biological evaluation of Medical Devices: .
ISO 10993-1:2009: Biological Evaluation for Medical Devices:
ISO 10993-4:2002; Hemocompatibility
ISO 10993-5:2009; Cytotoxicity
ISO 10993-10:2002; Sensitization
ISO 10993-10:2002; Irritation or Intracutaneous Reactivity
ISO 10993-11:2006; Acute Systemic Toxicity
- ISO 7886-1: 1993; Sterile hypodermic syringes for single use ●
- ISO 594-1:1986; Conical fittings with 6% (Luer) taper for Syringes, Needles and other ● Medical Equipment, general requirements
- ISO 10993-7:2008: Biological Evaluation for Medical Devices; EtO- Residuals ●
- ISO 11135-1:2007: Sterilization Validation (EtO) ●
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- ISO 11607-1:2006; Packaging for terminally sterilized medical devices -- Part 1: . Requirements for materials, sterile barrier systems and packaging systems
- ISO 11607-2:2006; Packaging for terminally sterilized medical devices -- Part 2: . Validation requirements for forming, sealing and assembly processes
Summary of Performance Data
The performance data presented in this safety & effectiveness summary and the attachments presented with the 510(k) submission demonstrates that this device is substantially equivalent to the predicate devices.
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DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/3/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo features a stylized eagle or bird symbol with three curved lines representing its wings or body. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" are arranged in a circular pattern around the bird symbol.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
Henke-Sass Wolf, GmbH C/O Ms. Lynette Howard Lyle Howard Corporation 106 East 5" Avenue Mount Dora, Florida 32757
NOV 2 2 2010
Re: K101547
Trade/Device Name: Piston Syringe (Norm -Jet) Regulation Number: 21 CFR 880.5860 Regulation Name: Piston Syringe Regulatory Class: II Product Code: FMF Dated: November 3, 2010 Received: November 4, 2010
Dear Ms. Howard:
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. Howard
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/ucm1115809.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 offer 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.
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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Section 6 - Indications for Use Statement - Revised
HSW- 510(k) for piston syringes
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Indications for Use .
NOV 2 2 2010
510(k) Number (if known): K101547
Device Name: piston syringe
Indications for Use:
"The HSW NORM-JECT®- syringes are intended to be used to inject into, or withdraw fluids from the body. The 1 ml- syringe with a purple plunger, labeled with BOTOX® is exclusively produced for use with BOTOX® Cosmetic (onabotulinumtoxinA)."
Prescription use: X (Part 21 CFR 801 subpart D) And /or
Over-the counter-use: ---(Part 21 CFR 801 subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED)
Suon Rumer fr. Pekl Chappine
(Division Sign-Off) Division of Anesthesioiogy, General Hospital Infection 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).