K Number
K102969
Date Cleared
2010-12-20

(75 days)

Product Code
Regulation Number
880.5860
Reference & Predicate Devices
Predicate For
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

International Medsurg Connection's piston syringe is intended for the injection of fluids into, or withdraw of fluids from, parts of the body below the surface of the skin. The device consists of a metal tube that is sharpened at one end and at the other end joined to a female connector (hub) designed to mate with a male connector (nozzle) of a piston syringe consisting of a calibrated hollow barrel and a movable plunger. The intended use is the same as the intended use on IMC piston syringe sold by International Medsurg Connection, Reference K022159.

This submission includes piston syringe that will be sold both sterile and non-sterile syringes are to be sold to OEMs for EtO sterilization according to their validated process per ANSVAMMISO 11135. Sterile syringes are to be sold directly to users after EO sterilization validation per ANSVAMMI/ISO 11135

Device Description

The device consists of a calibrated hollow barrel and a movable plunger with piston. 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.

AI/ML Overview

The provided text describes a 510(k) submission for an IMC Piston Syringe and does not contain information about an AI/ML device. Therefore, it does not fit the typical structure of an acceptance criteria and study report for such a device. This document is a regulatory submission for a medical device (piston syringe) claiming substantial equivalence to a predicate device.

However, I can extract the relevant "performance data" and "acceptance criteria" presented in the context of this device's submission, along with other requested information where applicable.

Here's the information based on the provided text, adapted to your request format:

1. A table of acceptance criteria and the reported device performance

Performance Characteristic (Acceptance Criteria)Reported New Device Performance (with Isoprene)Predicate Device Performance (K022159)Test Method
Air leakage past syringe piston during aspiration, and for separation of piston and plungerMeet the requirementSameISO 7886-1:Annex B
Liquid leakage at syringe piston under compressionMeet the requirementSameISO 7886-1:Annex D

Note: For this traditional medical device, "acceptance criteria" means meeting the requirements of the specified ISO standards, and "reported device performance" indicates that the new device meets those requirements.

2. Sample sized used for the test set and the data provenance

The document does not specify the sample size used for testing the piston syringes. It also does not explicitly state the provenance (e.g., country of origin, retrospective/prospective) of the data. The tests are referenced by ISO standards, implying laboratory testing.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

This section is not applicable as the device is a physical medical instrument (piston syringe), not an AI/ML device requiring expert ground truth for classification or diagnosis. Performance is evaluated against objective engineering standards (ISO 7886-1).

4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

This section is not applicable. Adjudication methods like 2+1 or 3+1 are used for establishing ground truth in expert-dependent tasks, typically in AI/ML performance evaluation where human experts might disagree. The syringe's performance is determined by objective physical tests according to ISO standards.

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 section is not applicable. This is a submission for a physical medical device (piston syringe), not an AI-assisted device. Therefore, MRMC studies involving human readers and AI assistance are irrelevant to this document.

6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

This section is not applicable. This is a physical medical device, not an algorithm.

7. The type of ground truth used

The "ground truth" for the device's performance is established by objective engineering standards and test methods defined in ISO 7886-1. The device is deemed to meet its performance criteria if it passes these standardized tests, indicating functional equivalence to the predicate device.

8. The sample size for the training set

This section is not applicable. This is a physical medical device, not a machine learning model, so there is no concept of a "training set."

9. How the ground truth for the training set was established

This section is not applicable for the same reasons as above.

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DEC2 0 2010

8.0 510(K) SUMMARY

K102969

Trade Name:IMC Piston Syringe
Common Name:Piston Syringe
Classification Name:Piston Syringe(21 CFR subpart E §880.5860 and §880.5570)
Submitter Information:International Medsurg Connection935 N Plum Grove Rd, STE FSchaumburg, Illinois 60173
Summary Prepared By:Peter KimDirector of Quality AssuranceInternational Medsurg Connection935 N Plum Grove Rd, STE FSchaumburg, Illinois 60173Telephone: 847-619-9926Fax: 847-619-9927e-mail: peterkim@intlmedsurg.com
Date Prepared:September 24, 2010
Predicate Devices:● IMC piston syringe (K022159)

Device Name(s):

IMC Piston Syringe

Classification Panel:

General and Plastic Surgery

Legally Marketed Device Under Which Substantial Equivalence is Being Claimed:

International Medsurg Connections, Inc is claiming substantial equivalence of the new piston syringe with the currently marketed:

Description510(k) NumberClearance Date
IMC piston syringeK02215911/7/2002

Device Description

The device consists of a calibrated hollow barrel and a movable plunger with piston. 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.

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Statement of Intended Use

This device is intended for the injection of fluids into, or withdraws of fluids from, parts of the body below the surface of the skin. The device consists of a metal tube that is sharpened at one end and at the other end joined to a female connector (hub) designed to mate with a male connector (nozzle) of a piston syringe consisting of a calibrated hollow barrel and a movable plunger. This submission includes drapes that will be sold both sterile and non-sterile.

This submission includes piston syringe that will be sold both sterile and non-sterile. Non-sterile syringes are to be sold to OEMs for EtO sterilization according to their validated process per ANSI/AMMI/ISO 11135. Sterile syringes are to be sold directly to users after EO sterilization validation per ANSI/AMMI/ISO 11135

CategoryDevice NameSterility
Piston syringeSyringe 1cc Luer SlipSterile and Non-sterile
Syringe 2cc Luer LockSterile and Non-sterile
Syringe 2cc Luer SlipSterile and Non-sterile
Syringe 3cc Luer lockSterile and Non-sterile
Syringe 3cc Luer SlipSterile and Non-sterile
Syringe 5cc Luer lockSterile and Non-sterile
Syringe 5cc Luer SlipSterile and Non-sterile
Syringe 10cc Luer lockSterile and Non-sterile
Syringe 10cc Luer SlipSterile and Non-sterile
Piston syringeSyringe 20cc Luer lockSterile and Non-sterile
Syringe 20cc Luer SlipSterile and Non-sterile
Syringe 30cc Luer lockSterile and Non-sterile
Syringe 30cc Luer SlipSterile and Non-sterile
Syringe 60cc Luer lockSterile and Non-sterile
Syringe 60cc Luer SlipSterile and Non-sterile
Syringe 100cc Luer lockSterile and Non-sterile
Syringe 100cc Luer SlipSterile and Non-sterile

New Devices as Compared to Marketed Device(s)

The new piston syringe and the predicate device (IMC piston syringe – K022159) are used to inject fluids into, or withdraw fluids from, parts of the body below the surface of the skin. The new piston syringe has the same intended use, the same technological characteristics and the same materials with exception of the piston material. Design differences are considered minor. The current piston material for IMC piston syringe is Santoprene but new piston syringe will use the alternative piston material (Isoprene) which is widely used in syringe manufacturing industry.

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Feature/ CharacteristicNew piston syringe (with Isoprene)IMC piston syringe- K022159 (Predicate)
Material Composition
BarrelPolyethylene R370YSame
PistonIsopreneSantoprene
PlungerPolyethylene R370YSame
LubricantHigh capability silicon oilSame
Design Feature
DesignSee section 13Similar
DimensionSee section 13Similar
Volume1cc, 2cc, 3cc, 5cc, 10cc, 20cc, 30cc, 60ccand 100ccSimilar

Performance Data:

Performance CharacteristicsTest MethodNew piston syringe(with Isoprene)IMC piston syringe-K022159(Predicate)
Test method for air leakage pastsyringe piston during aspiration,and for separation of piston andplungerISO 7886-1:Annex BMeet the requirementSame
Test method for liquid leakage atsyringe piston under compressionISO 7886-1:Annex DMeet the requirementSame

Conclusions:

The indications for use, technology, specification, safety of the piston syringe with Isoprene and the current IMC piston syringe (K022159) are essentially the same. The differences between the syringes are minor and do not raise new issues of safety or effectiveness. Hence, the piston syringe with Isoprene is substantially equivalent to the current IMC piston syringe.

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Image /page/3/Picture/1 description: The image shows the logo for the Department of Health & Human Services USA. The logo is a circular seal with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" arranged around the perimeter. Inside the circle is an emblem of an eagle with its wings spread, stylized with three parallel lines forming the wings and body. The eagle appears to be in flight or poised for action.

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

Mr. Peter Kim Director of Quality Assurance International Medsurg Connection 935 North Plum Grove Road, Suite F Schaumburg, Illinois 60173

DEC 2 0 2010

Re: K102969

Trade/Device Name: IMC Piston Syringes Regulation Number: 21 CFR 880.5570 Regulation Name: Hypodermic Single Lumen Needle Regulatory Class: II Product Code: FMF, FMF, FMI Dated: November 2, 2010 Received: November 2, 2010

Dear Mr. Kim:

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- Mr. Kim .

Enclosure

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/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 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,

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

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4.0 INTENDED USES / INDICATION:

International Medsurg Connection's piston syringe is intended for the injection of fluids into, or withdraw of fluids from, parts of the body below the surface of the skin. The device consists of a metal tube that is sharpened at one end and at the other end joined to a female connector (hub) designed to mate with a male connector (nozzle) of a piston syringe consisting of a calibrated hollow barrel and a movable plunger. The intended use is the same as the intended use on IMC piston syringe sold by International Medsurg Connection, Reference K022159.

This submission includes piston syringe that will be sold both sterile and non-sterile syringes are to be sold to OEMs for EtO sterilization according to their validated process per ANSVAMMISO 11135. Sterile syringes are to be sold directly to users after EO sterilization validation per ANSVAMMI/ISO 11135

CategoryDevice NameSterility
Piston syringeSyringe 1cc Luer SlipSterile and Non-sterile
Syringe 2cc Luer LockSterile and Non-sterile
Syringe 2cc Luer SlipSterile and Non-sterile
Syringe 3cc Luer lockSterile and Non-sterile
Syringe 3cc Luer SlipSterile and Non-sterile
Syringe 5cc Luer lockSterile and Non-sterile
Syringe 5cc Luer SlipSterile and Non-sterile
Syringe 10cc Luer lock.Sterile and Non-sterile
Syringe 10cc Luer SlipSterile and Non-sterile
Syringe 20cc Luer lockSterile and Non-sterile
Syringe 20cc Luer SlipSterile and Non-sterile
Syringe 30cc Luer lockSterile and Non-sterile
Syringe 30cc Luer SlipSterile and Non-sterile
Syringe 60cc Luer lockSterile and Non-sterile
Syringe 60cc Luer SlipSterile and Non-sterile
Syringe 100cc Luer lockSterile and Non-sterile
Syringe 100cc Luer SlipSterile and Non-sterile

Related items are indicated at the table below.

AND/OR Over-The-Counter Use Prescription Use X (Part 21 CFR 801 Subpart D) (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) 12/21/16
(Division Sign-Off)

510(k) Number: K/02969

§ 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).