K Number
K111091
Device Name
MERIT MEDICAL 20 ML SYRINGE
Date Cleared
2011-06-24

(66 days)

Product Code
Regulation Number
880.5860
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
The Merit Medical 20 ml Syringe is used to inject fluids into, or withdraw fluids from, the body.
Device Description
The Merit Medical 20 ml Syringe is a device consisting of a calibrated hollow barrel into which is inserted a closely fitting movable plunger and seal. The barrel contains a male Luer Lock connector which is compatible for attaching devices with standard female Luer hubs.
More Information

Not Found

No
The device description and performance studies focus on the mechanical and material properties of a standard syringe, with no mention of AI or ML capabilities.

No

The intended use of the Merit Medical 20 ml Syringe is to inject or withdraw fluids from the body, which is a diagnostic or procedural function rather than directly treating a disease or condition.

No

Explanation: The intended use of the Merit Medical 20 ml Syringe is to inject or withdraw fluids, which is a therapeutic or procedural function, not a diagnostic one. Diagnostic devices are used to identify or determine the nature of a disease or condition.

No

The device description clearly outlines a physical syringe with a barrel, plunger, and Luer Lock connector, and the performance studies detail testing of physical properties and materials, indicating it is a hardware device.

Based on the provided information, the Merit Medical 20 ml Syringe is not an In Vitro Diagnostic (IVD) device.

Here's why:

  • Intended Use: The intended use is "to inject fluids into, or withdraw fluids from, the body." This describes a direct interaction with the human body for therapeutic or diagnostic purposes within the body, not for testing samples outside the body.
  • Device Description: The description focuses on the mechanical components of a syringe used for fluid transfer. There is no mention of components or features related to analyzing biological samples or performing tests on them.
  • Lack of IVD-Specific Information: The document does not contain any information typically associated with IVD devices, such as:
    • Analysis of biological samples (blood, urine, tissue, etc.)
    • Detection or measurement of specific analytes
    • Use of reagents or test kits
    • Performance metrics related to diagnostic accuracy (sensitivity, specificity, etc.)

The testing described focuses on the physical and biological safety of the syringe for its intended use of fluid transfer within the body, which is consistent with a general medical device, not an IVD.

N/A

Intended Use / Indications for Use

The Merit Medical 20 ml Syringe is used to inject fluids into, or withdraw fluids from, the body.

Product codes

FMF

Device Description

The Merit Medical 20 ml Syringe is a device consisting of a calibrated hollow barrel into which is inserted a closely fitting movable plunger and seal. The barrel contains a male Luer Lock connector which is compatible for attaching devices with standard female Luer hubs.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Not Found

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

Performance testing of the subject Merit Medical 20 ml Syringe was conducted based on the risk analysis and based on the requirements of the following FDA guidance document and international standards:
• Guidance on the Content of Premarket Notification[510(k)] Submissions for Piston Syringes, April 1993
• ISO 7886-1:1993, Sterile hypodermic syringes for single use - Part 1: Syringes for manual use
• ISO 594-1:1986, Conical fittings with a 6% (Luer) taper for syringes, needles and certain other medical equipment – Part 1: General requirements
• ISO 594-2:1998, Conical fittings with 6% (Luer) taper for syringes, needles and certain other medical equipment – Part 2: Lock fittings
• ANSI/AAMI/ISO 11135-1: 2007, Sterilization of health care products - Ethylene oxide – Part 1: Requirements for development, validation and routine control of a sterilization process for medical devices
• ISO 10993-1: 2009, Biological Evaluation of Medical Devices Part-1: Evaluation and Testing within a risk management process, and the FDA Modified ISO 10993 Test Profile
• EN ISO 10993-7:2008, Biological Evaluation of Medical Devices, Part 7: Ethylene Oxide Sterilization Residuals
The following is a list of all significant testing that was successfully completed:
Cleanliness
Limits for acidity and alkalinity
Limits for extractable metals
Inspection for lubricant contaminants
Tolerance on graduation capacity
Graduated scale
Numbering of scale
Overall length of scale to nominal capacity
Position of scale
Barrel - finger grips
Piston/plunger assembly - design
Piston/plunger assembly - fit of piston in barrel
Piston/plunger assembly - fiducial line
Gauging
Separation force
Unscrewing torque
Position of nozzle on end of barrel
Nozzle lumen.
Dead space
Freedom from air leakage
Freedom from liquid leakage
Freedom from liquid leakage with side force
Adhesion of ink
Biocompatibility tests
Cytotoxicity
Sensitization
Irritation
Acute Systemic Toxicity
Hemocompatibility
Packaging performance after exposure to accelerated aging and simulated shipping and handling conditions:
Visual inspection
Dye penetration testing
Underwater leak test (bubble emission testing)
Seal strength-seal peel tensile strength
Burst pressure testing
Ease of assembly
Resistance to overriding
Resistance to cracking
The results of the testing demonstrated that the subject Merit Medical 20 ml Syringe met the pre-determined acceptance criteria applicable to the safety and efficacy of the device.

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s)

K024052

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 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).

0

K 11109 1 JUN 2 4 2011


ll

Section 5
510(k) Summary
General
ProvisionsSubmitter Name:
Merit Medical Systems, Inc.
Address:
1600 West Merit Parkway
South Jordan, UT 84095
Telephone Number:
(801) 208-4196
Fax Number:
(801) 253-6932
Contact Person:
Michaela Rivkowich
Date of Preparation:
April 14, 2011
Registration Number: 1721504
Subject
DeviceTrade Name:
To be assigned
Common/Usual Name:
Merit Medical 20 ml Syringe
Classification Name:
Syringe, Piston
Predicate
DeviceTrade Name:
Merit Medical 1-mL Syringe
Classification Name:
Syringe, Piston
Premarket Notification:K024052
Manufacturer:
Merit Medical Systems, Inc.
ClassificationClass II
21 CFR § 880.5860
General Hospital
Intended UseThe Merit Medical 20 ml Syringe is used to inject fluids into, or
withdraw fluids from, the body.
Device
DescriptionThe Merit Medical 20 ml Syringe is a device consisting of a
calibrated hollow barrel into which is inserted a closely fitting
movable plunger and seal. The barrel contains a male Luer Lock
connector which is compatible for attaching devices with standard
female Luer hubs.
Technological
CharacteristicsThe technological characteristics of the subject Merit Medallion
Syringe are substantially equivalent to those of the predicate device,
the Merit Medical 1-mL Syringe, 510(k) K024052.
No performance standards have been established under Section 514
of the Food, Drug and Cosmetic Act for these devices. Performance
testing of the subject Merit Medical 20 ml Syringe was conducted
based on the risk analysis and based on the requirements of the
following FDA guidance document and international standards:
Safety &
Performance
Tests• Guidance on the Content of Premarket Notification
[510(k)] Submissions for Piston Syringes, April 1993
• ISO 7886-1:1993, Sterile hypodermic syringes for single
use - Part 1: Syringes for manual use
• ISO 594-1:1986, Conical fittings with a 6% (Luer) taper for
syringes, needles and certain other medical equipment –
Part 1: General requirements
• ISO 594-2:1998, Conical fittings with 6% (Luer) taper for
syringes, needles and certain other medical equipment –
Part 2: Lock fittings
• ANSI/AAMI/ISO 11135-1: 2007, Sterilization of health
care products - Ethylene oxide – Part 1: Requirements
for development, validation and routine control of a
sterilization process for medical devices
• ISO 10993-1: 2009, Biological Evaluation of Medical
Devices Part-1: Evaluation and Testing within a risk
management process, and the FDA Modified ISO 10993
Test Profile
• EN ISO 10993-7:2008, Biological Evaluation of Medical
Devices, Part 7: Ethylene Oxide Sterilization Residuals
The following is a list of all significant testing that was successfully
completed:
Cleanliness
Limits for acidity and alkalinity
Limits for extractable metals
Inspection for lubricant contaminants
Tolerance on graduation capacity
Graduated scale
Numbering of scale
Overall length of scale to nominal capacity
Position of scale
Barrel - finger grips
Piston/plunger assembly - design
Piston/plunger assembly - fit of piston in barrel
Piston/plunger assembly - fiducial line
Gauging
Separation force
Unscrewing torque
Safety &
Performance
Tests cont.Position of nozzle on end of barrel
Nozzle lumen.
Dead space
Freedom from air leakage
Freedom from liquid leakage
Freedom from liquid leakage with side force
Adhesion of ink
Biocompatibility tests
Cytotoxicity
Sensitization
Irritation
Acute Systemic Toxicity
Hemocompatibility
Packaging performance after exposure to accelerated aging and
simulated shipping and handling conditions:
Visual inspection
Dye penetration testing
Underwater leak test (bubble emission testing)
Seal strength-seal peel tensile strength
Burst pressure testing
Safety &
Performance
Tests cont.The results of the testing demonstrated that the subject Merit
Medical 20 ml Syringe met the pre-determined acceptance criteria
applicable to the safety and efficacy of the device.
Summary of
Substantial
EquivalenceBased on the indications for use, design, and safety and
performance testing, the subject Merit Medical 20 ml Syringe meets
the requirements that are considered essential for its intended use
and is substantially equivalent to the predicate device, the Merit
Medical 1-mL Syringe, manufactured by Merit Medical Systems, Inc.

. .

1

Ease of assembly

Resistance to overriding

Resistance to cracking

.

2

Merit Medical 20 ml Syringe
Section 5, 510(k) Summary
Special Premarket Notification 510(k)

,

:

:

3

DEPARTMENT OF HEALTH & HUMAN SERVICES

Image /page/3/Picture/1 description: The image shows the seal of the Department of Health & Human Services - USA. The seal features a stylized eagle with three stripes forming its body and two curved lines representing its legs. The eagle is positioned diagonally within a circle, and the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged around the circumference of the circle.

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

Ms. Michaela Rivkowich Principal Regulatory Affairs Specialist Merit Medical Systems, Incorporated 1600 West Merit Parkway South Jordan, Utah 84095

JUN 2 4 2011

Re: K111091

Trade/Device Name: Merit Medical 20 ml Syringe Regulation Number: 21 CFR 880.5860 Regulation Name: Piston Syringe Regulatory Class: II Product Code: FMF Dated: May 24, 2011 Received: May 26, 2011

Dear Ms. Rivkowich

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.

4

Page 2 - Ms. Rivkowich

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.goy/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/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/ResourcesforYou/Industry/default.htm.

Sincerely yours.

Anthony D. Watson

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

5

Merit Medical 20 ml Syringe Section 4, Indications for Use Special Premarket Notification 510(k)

Section 4

Indications for Use

510(k) Number (if known):

Device Name: Merit Medical 20 ml Syringe

Indications for Use:

The Merit Medical 20 ml Syringe is used to inject fluids into, or withdraw fluids from, the body.

KIII09

Prescription Use X (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)

for Rick Chapman

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

510(k) Number: (11109)