K Number
K142636
Date Cleared
2014-10-17

(30 days)

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

The Merit 10mL Syringe is used to inject fluids into, or withdraw fluids from, the body.

Device Description

The Merit 10mL Syringe is a device consisting of a calibrated hollow barrel into which is inserted a closely fitted movable plunger and seal. The barrel contains a male Luer lock connector (which conforms to ISO 594-1 & 2 standards) which is compatible for attaching devices with standard female Luer hubs.

AI/ML Overview

This document is a 510(k) Premarket Notification for the Merit 10mL Syringe. It focuses on demonstrating substantial equivalence to a predicate device, the Merit 20mL Syringe (K111091), rather than a comparative effectiveness study involving AI or human readers. Therefore, several of the requested categories related to AI performance, human reader studies, and ground truth establishment for complex datasets are not applicable.

Here's an analysis based on the provided text:

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

Test Standard / CriteriaReported Device Performance
ISO 7886-1:Met predetermined acceptance criteria for safety and efficacy.
- CleanlinessMet predetermined acceptance criteria
- Sufficient/excessive LubricantMet predetermined acceptance criteria
- Capacity ToleranceMet predetermined acceptance criteria
- Graduated ScaleMet predetermined acceptance criteria
- Scale UniformityMet predetermined acceptance criteria
- Scale - Evenly spacedMet predetermined acceptance criteria
- Scale Vertical AlignmentMet predetermined acceptance criteria
- Scale - IncrementsMet predetermined acceptance criteria
- Scale Vertical PrintMet predetermined acceptance criteria
- Scale LengthMet predetermined acceptance criteria
- Scale PositionMet predetermined acceptance criteria
- Capacity 10% > NominalMet predetermined acceptance criteria
- Finger GripsMet predetermined acceptance criteria
- Piston/Plunger AssemblyMet predetermined acceptance criteria
- Piston fit in BarrelMet predetermined acceptance criteria
- Fiducial line on BarrelMet predetermined acceptance criteria
- Nozzle PlacementMet predetermined acceptance criteria
- Nozzle LumenMet predetermined acceptance criteria
- Dead SpaceMet predetermined acceptance criteria
- Liquid Leak TestMet predetermined acceptance criteria
- Air Leak TestMet predetermined acceptance criteria
- Acidity / AlkalinityMet predetermined acceptance criteria
- Extractable MetalsMet predetermined acceptance criteria
ISO 594-2:Met predetermined acceptance criteria for safety and efficacy.
- Luer GaugingMet predetermined acceptance criteria
- Liquid Leak TestMet predetermined acceptance criteria
- Air Leak TestMet predetermined acceptance criteria
- Separation ForceMet predetermined acceptance criteria
- Unscrewing torqueMet predetermined acceptance criteria
- Ease of assemblyMet predetermined acceptance criteria
- Resistance to overridingMet predetermined acceptance criteria
- Stress CrackingMet predetermined acceptance criteria
Merit's Risk Analysis:Met predetermined acceptance criteria for safety and efficacy.
- Plunger Seal Detachment TestMet predetermined acceptance criteria
- Ink Adhesion TestMet predetermined acceptance criteria
Biocompatibility (based on ISO 10993 series, ASTM F756-08, USP 37):Met predetermined acceptance criteria for safety and efficacy.
- CytotoxicityMet predetermined acceptance criteria
- SensitizationMet predetermined acceptance criteria
- IrritationMet predetermined acceptance criteria
- Acute Systemic ToxicityMet predetermined acceptance criteria
- PyrogenicityMet predetermined acceptance criteria
- HemocompatibilityMet predetermined acceptance criteria

2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

The document does not explicitly state the sample sizes for each test, nor the specific provenance of the data (e.g., country of origin). The testing was conducted by the manufacturer, Merit Medical Systems, Inc., which is based in South Jordan, UT, USA. The nature of these tests (e.g., physical, chemical, and biological performance tests on a medical device) suggests they are prospective, conducted specifically to validate the device against established standards.

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 study involves physical and biological testing of a medical device against objective standards (ISO, ASTM, USP), not interpretation of subjective data by human experts. The "ground truth" is defined by the acceptance criteria within these established standards.

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

Not applicable. As described above, the study involves objective performance testing against predefined criteria, not subjective interpretation requiring adjudication among experts.

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

Not applicable. This is a 510(k) submission for a physical medical device (syringe), not an AI-powered diagnostic tool, and therefore no MRMC study or AI assistance was involved.

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

Not applicable. This is a 510(k) submission for a physical medical device (syringe), not an AI algorithm.

7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

The "ground truth" for this device's performance is established by the acceptance criteria defined within recognized international and national consensus standards such as:

  • ISO 7886-1: Sterile hypodermic syringes for single use
  • ISO 594-1 & -2: Conical fittings (Luer taper)
  • ISO 11135: Sterilization
  • ISO 10993 series: Biological Evaluation of Medical Devices (Biocompatibility)
  • ASTM F756-08: Hemolytic Properties
  • United States Pharmacopeia 37: Pyrogen Test

These standards specify measurable parameters and thresholds for acceptable performance.

8. The sample size for the training set

Not applicable. This is a 510(k) submission for a physical medical device, not a machine learning model. There is no concept of a "training set" in this context.

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

Not applicable. As explained above, there is no training set. The "ground truth" for the device's acceptable performance is derived from the established consensus standards and FDA guidance.

§ 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).