K Number
K153388
Device Name
IMPROSAFE Blood Collection Set with Pre-attached Holder, IMPROVACUTER Blood Collection Set Pre-attached Holder, IMPROSAFE Blood Collection Set, IMPROVACUTER Blood Collection Set, IMPROSAFE Multi Sample Needle, IMPROSAFE Multi Sample Needle (Flashback), IMPROVACUTER Multi Sample Needle
Date Cleared
2016-06-07

(197 days)

Product Code
Regulation Number
880.5570
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
The IMPROSAFE® Blood Collection Sets with Pre-attached to be used with evacuated blood collection tube for the collection of venous blood. The safety shield is intended to aid in the protection against accidental needle stick injury. The IMPROSAFE® Multi-Sample Needles are intended to be used with evacuated blood collection tube for the collection of venous blood. The safety shield is intended to aid in the protection against accidental needle stick injury. The IMPROVACUTER® Blood Collection Sets are intended to be used with evacuated blood collection tube for the collection of venous blood. The IMPROSAFE® Blood Collection Sets are intended to be used with evacuated blood collection tube for the collection of venous blood. The safety shield is intended to aid in the protection against accidental needle stick injury. The IMPROVACUTER® Blood Collection Sets with Pre-attached holder are intended to be used with evacuated blood collection tube for the collection of venous blood. The IMPROSAFE® Multi-Sample Needles (Flashback) are intended to be used with evacuated blood collection tube for the collection of venous blood. The safety shield is intended to aid in the protection against accidental needle stick injury. The IMPROVACUTER® Multi-Sample Needles are used with holder and vacuum blood collection tube for the venous blood collection.
Device Description
The proposed devices are blood collection sets form a channel between patient's vein and the evacuated blood collection tube intended for collection of blood. They are available in different configurations as follows: IMPROSAFE® Blood Collection Set with Pre-attached holder: Patient-End Needle, Non-Patient End Needle, Flexible Tubing, Pre-attached Holder, Safety Mechanism, Visible Flash Back IMPROSAFE® Blood Collection Set: Patient-End Needle, Non-Patient End Needle, Flexible Tubing, N.A., Safety Mechanism, Visible Flash Back IMPROVACUTER® Blood Collection Set with Pre-attached Holder: Patient-End Needle, Non-Patient End Needle, Flexible Tubing, Pre-attached Holder, N.A., Visible Flash Back IMPROVACUTER® Blood Collection Set: Patient-End Needle, Non-Patient End Needle, Flexible Tubing, N.A., N.A., Visible Flash Back IMPROSAFE® Multi Sample Needle: Patient-End Needle, Non-Patient End Needle, N.A., Pre-attached Holder, Safety Mechanism, N.A. IMPROSAFE® Multi Sample Needle (Flashback): Patient-End Needle, Non-Patient End Needle, N.A., Pre-attached Holder, Safety Mechanism, Visible Flash Back IMPROVACUTER® Multi Sample Needle: Patient-End Needle, Non-Patient End Needle, N.A., N.A., N.A., N.A.
More Information

No
The document describes standard blood collection devices and does not mention any AI or ML components or functionalities.

No
The device is described as a blood collection set for venous blood samples, intended for diagnostic purposes rather than therapeutic treatment.

No

Explanation: The devices described are blood collection sets and needles used for the collection of venous blood, which is a preliminary step to diagnostic testing, but the devices themselves do not perform a diagnostic function.

No

The device description clearly outlines physical components such as needles, tubing, and safety mechanisms, indicating it is a hardware device for blood collection. There is no mention of software as a component or the primary function.

Based on the provided text, these devices are not IVDs (In Vitro Diagnostics).

Here's why:

  • Intended Use: The intended use clearly states that these devices are for the collection of venous blood. They are the tools used to obtain the sample.
  • Device Description: The description details the physical components of the blood collection sets and needles, which are designed to facilitate the physical act of drawing blood.
  • Lack of Diagnostic Function: There is no mention of these devices being used to perform any test or analysis on the collected blood sample. They do not provide any diagnostic information themselves.
  • Performance Studies: The performance studies focus on the physical properties of the devices (seal strength, sterility, biocompatibility, etc.) and their ability to collect blood safely and effectively. They do not involve evaluating the accuracy or performance of a diagnostic test.

IVD devices are used in vitro (outside the body) to examine specimens (like blood) to provide information for diagnosis, monitoring, or screening. These blood collection devices are used in vivo (on the body) to obtain the specimen for potential subsequent in vitro diagnostic testing.

N/A

Intended Use / Indications for Use

The IMPROSAFE® Blood Collection Sets with Pre-attached to be used with evacuated blood collection tube for the collection of venous blood. The safety shield is intended to aid in the protection against accidental needle stick injury.

The IMPROSAFE® Multi-Sample Needles are intended to be used with evacuated blood collection tube for the collection of venous blood. The safety shield is intended to aid in the protection against accidental needle stick injury.

The IMPROVACUTER® Blood Collection Sets are intended to be used with evacuated blood collection tube for the collection of venous blood.

The IMPROSAFE® Blood Collection Sets are intended to be used with evacuated blood collection tube for the collection of venous blood. The safety shield is intended to aid in the protection against accidental needle stick injury.

The IMPROVACUTER® Blood Collection Sets with Pre-attached holder are intended to be used with evacuated blood collection tube for the collection of venous blood.

The IMPROSAFE® Multi-Sample Needles (Flashback) are intended to be used with evacuated blood collection tube for the collection of venous blood. The safety shield is intended to aid in the protection against accidental needle stick injury.

The IMPROVACUTER® Multi-Sample Needles are used with holder and vacuum blood collection tube for the venous blood collection.

Product codes (comma separated list FDA assigned to the subject device)

FMI

Device Description

The proposed devices are blood collection sets form a channel between patient's vein and the evacuated blood collection tube intended for collection of blood. They are available in different configurations as follows:

MPROSAFE® Blood Collection Set with Pre-attached holder: Patient-End Needle, Non-Patient End Needle, Flexible Tubing, Pre-attached Holder, Safety Mechanism, Visible Flash Back
IMPROSAFE® Blood Collection Set: Patient-End Needle, Non-Patient End Needle, Flexible Tubing, N.A. (for Pre-attached Holder), Safety Mechanism, Visible Flash Back
IMPROVACUTER® Blood Collection Set with Pre-attached Holder: Patient-End Needle, Non-Patient End Needle, Flexible Tubing, Pre-attached Holder, N.A. (for Safety Mechanism), Visible Flash Back
IMPROVACUTER® Blood Collection Set: Patient-End Needle, Non-Patient End Needle, Flexible Tubing, N.A. (for Pre-attached Holder), N.A. (for Safety Mechanism), Visible Flash Back
IMPROSAFE® Multi Sample Needle: Patient-End Needle, Non-Patient End Needle, N.A. (for Flexible Tubing), Pre-attached Holder, Safety Mechanism, N.A. (for Visible Flash Back)
IMPROSAFE® Multi Sample Needle (Flashback): Patient-End Needle, Non-Patient End Needle, N.A. (for Flexible Tubing), X (for Pre-attached Holder), X (for Safety Mechanism), X (for Visible Flash Back)
IMPROVACUTER® Multi Sample Needle: Patient-End Needle, Non-Patient End Needle, N.A. (for Flexible Tubing), N.A. (for Pre-attached Holder), N.A. (for Safety Mechanism), N.A. (for Visible Flash Back)

Needle Gauge: 21G, 22G, 23G, 25G, 27G
Needle Length: 3/4", 2/5", 1", 1 1/4", 1 1/2"

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Venous blood collection (implies human veins)

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Qualified practitioner

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)

Non clinical tests were conducted to verify that the proposed device met all design specifications as was Substantially Equivalent (SE) to the predicate device. The test results demonstrated that the proposed device complies with the following standards:

ISO 9626:1991+AMENDMENT 1 2001 Stainless steel needle tubing for the manufacture of medical devices;
ISO 7864: 1993 Sterile hypodermic needles for single use
ISO 10993-7:2008 Biological evaluation of medical devices- Part 7: Ethylene oxide sterilization residuals;
ASTM F 88/F88M-09 Standard test method for seal strength of flexible barrier materials;
ASTM F1929-12 Standard Test Method for Detecting Seal Leaks in Porous Medical Packaging by Dye Penetration;
USP38-NF33 Bacterial Endotoxins Limit.
ISO 10993-5:2009 Biological evaluation of medical devices-Part 5: Tests for in vitro cytotoxicity.
ISO 10993-10:2010 Biological evaluation of medical devices- Part 10: Test for irritation and delayed-type hypersensitivity
ISO 10993-11:2006 Biological evaluation of medical devices- Part 11: Tests for systemic toxicity
ASTM F 756-13 Standard practice for assessment of hemolytic properties of materials
Guidance for Industry and FDA Staff: Medical Devices with Sharps Injury Prevention Features

No clinical study is included in this submission.

Key results: Conform with ISO 9626:1991 AMD 2001 and ISO 7864: 1993; EO sterilized; Single Use; Conform with ISO 10993; Conform with 21 CFR Part 801.

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

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

K980414, K982541, K090426

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

K980414, K090426

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found

§ 880.5570 Hypodermic single lumen needle.

(a)
Identification. A hypodermic single lumen needle is a device intended to inject fluids into, or withdraw 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 or an intravascular administration set.(b)
Classification. Class II (performance standards).

0

Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo is a circular seal with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is a stylized image of three human profiles facing to the right, stacked on top of each other.

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

September 12, 2016

Guangzhou Improve Medical Instruments Co., Ltd. % Dianna Hong General Manager Mid-Link Consulting Co., Ltd P.O. Box 120-119 Shanghai, 200120 CHINA

Re: K153388

Trade/Device Name: IMPROSAFE® Blood Collection Set With Pre-attached Holder, IMPROVACUTER® Blood Collection Set Pre-attached Holder, IMPROSAFE® Blood Collection Set, IMPROVACUTER® Blood Collection Set, IMPROSAFE® Multi Sample Needle, IMPROSAFE® Multi Sample Needle (flashback), IMPROVACUTER® Multi Sample Needle Regulation Number: 21 CFR 880.5570 Regulation Name: Hypodermic Single Lumen Needle Regulatory Class: Class II Product Code: FMI Dated: November 3, 2015 Received: February 23, 2016

Dear Dianna Hong:

This letter corrects our substantially equivalent letter of June 7, 2016.

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

1

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.

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 devicerelated 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 contact the Division of Industry and Consumer Education 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. Also, please note the regulation entitled. "Misbranding by reference to premarket notification" (21 CFR 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 Industry and Consumer Education 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,

Michael J. Ryan -S

for Tina Kiang, PhD Acting Director Division of Anesthesiology. General Hospital, Respiratory, Infection Control, and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

2

510(k) Number (if known) K153388

Device Name

IMPROSAFE® Blood Collection Set with Pre-attached Holder

Indications for Use (Describe)

The IMPROSAFE® Blood Collection Sets with Pre-attached to be used with evacuated blood collection tube for the collection of venous blood. The safety shield is intended to aid in the protection against accidental needle stick injury.

Type of Use (Select one or both, as applicable)
---------------------------------------------------

Prescription Use (Part 21 CFR 801 Subpart D)

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

CONTINUE ON A SEPARATE PAGE IF NEEDED.

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov

3

510(k) Number (if known) K153388

Device Name IMPROSAFE® Multi Sample Needle

Indications for Use (Describe)

The IMPROSAFE® Multi-Sample Needles are intended to be used with evacuated blood collection tube for the collection of venous blood. The safety shield is intended to aid in the protection against accidental needle stick injury.

Type of Use (Select one or both, as applicable)
Prescription Use (Part 21 CFR 801 Subpart D)Over-The-Counter Use (21 CFR 801 Subpart C)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov

4

DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Indications for Use

510(k) Number (if known) K153388

Device Name

IMPROVACUTER® Blood Collection Set

Indications for Use (Describe)

The IMPROVACUTER® Blood Collection Sets are intended to be used with evacuated blood collection tube for the collection of venous blood.

Type of Use (Select one or both, as applicable)

Prescription Use (Part 21 CFR 801 Subpart D)

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

CONTINUE ON A SEPARATE PAGE IF NEEDED.

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Druq Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff@fda.hhs.gov

5

DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Indications for Use

510(k) Number (if known) K153388

Device Name

IMPROSAFE® Blood Collection Set

Type of Use (Select one or both, as applicable)

Indications for Use (Describe)

The IMPROSAFE® Blood Collection Sets are intended to be used with evacuated blood collection tube for the collection of venous blood. The safety shield is intended to aid in the protection against accidental needle stick injury.

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

CONTINUE ON A SEPARATE PAGE IF NEEDED.

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the
time to review instructions, search existing data sources, gather and maintain the data needed and complete
and review the collection of information. Send comments regarding this burden estimate or any other aspect
of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services

Food and Drug Administration

Office of Chief Information Officer

Paperwork Reduction Act (PRA) Staff

PRAStaff@fda.hhs.gov "An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

Form Approved: OMB No. 0910-0120 Expiration Date: January 31, 2017 See PRA Statement below.

6

DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Indications for Use

510(k) Number (if known) K153388

Device Name

IMPROVACUTER® Blood Collection Set with Pre-attached Holder

Indications for Use (Describe)

The IMPROVACUTER® Blood Collection Sets with Pre-attached holder are intended to be used with evacuated blood collection tube for the collection of venous blood.

☑ Prescription Use (Part 21 CFR 801 Subpart D)□ Over-The-Counter Use (21 CFR 801 Subpart C)
-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

CONTINUE ON A SEPARATE PAGE IF NEEDED.

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the
time to review instructions, search existing data sources, gather and maintain the data needed and complete
and review the collection of information. Send comments regarding this burden estimate or any other aspect
of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services

Food and Drug Administration

Office of Chief Information Officer

Paperwork Reduction Act (PRA) Staff

Paperwork Reduction Act (PRA) Staff PRAStaff@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

Type of Use (Select one or both, as applicable)

7

510(k) Number (if known) K153388

Device Name

IMPROSAFE® Multi Sample Needle (Flashback)

Indications for Use (Describe)

The IMPROSAFE® Multi-Sample Needles (Flashback) are intended to be used with evacuated blood collection tube for the collection of venous blood. The safety shield is intended to aid in the protection against accidental needle stick injury.

Type of Use (Select one or both, as applicable)

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

CONTINUE ON A SEPARATE PAGE IF NEEDED.

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov

8

510(k) Number (if known) K153388

Device Name IMPROVACUTER® Multi Sample Needle

Indications for Use (Describe)

The IMPROVACUTER® Multi-Sample Needles are used with holder and vacuum blood collection tube for the venous blood collection.

Type of Use (Select one or both, as applicable)
-------------------------------------------------

X Prescription Use (Part 21 CFR 801 Subpart D)

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

CONTINUE ON A SEPARATE PAGE IF NEEDED.

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov

9

510(k) Summary

This 510(k) Summary is being submitted in accordance with requirements of Title 21, CFR Section 807.92.

The assigned 510(k) Number: K153388 Date of Preparation: 08/15/2016

    1. Sponsor Identification
      Guangzhou Improve Medical Instruments Co., Ltd. No.102, Kaiyuan Avenue, Science City, Guangzhou Economic & Technological Development District, Guangzhou, 510530, CHINA

Establishment Registration Number: 3008449424

Contact Person: Bangfu Sun Position: Quality Manager Tel: +86-20-32312660 Fax: +86-20-32312667 Email: qd9@improve-medical.com

  1. Identification of Proposed Device

Trade Name: IMPROSAFE® Blood Collection Set with Pre-attached Holder IMPROVACUTER® Blood Collection Set with Pre-attached Holder IMPROVACUTER® Blood Collection Set IMPROSAFE® Blood Collection Set IMPROSAFE® Multi Sample Needle IMPROVACUTER® Multi Sample Needle IMPROSAFE® Multi Sample Needle (Flashback) Common Name: Blood Collection Set Classification Name: Needle, Hypodermic, Single Lumen Classification: II Product Code: FMI Regulation Number: 21CFR 880.5570 Review Panel: General Hospital

10

Proposed DevicePredicate Device
IMPROSAFE® Blood Collection Set
with Pre-attached holder510(k) Number: K980414
Product Name: VACUTAINER® Brand Blood Collection
Set and Safety-LokTM Blood Collection Set
IMPROSAFE® Blood Collection Set510(k) Number: K980414
Product Name: VACUTAINER® Brand Blood Collection
Set and Safety-LokTM Blood Collection Set
IMPROVACUTER® Blood Collection
Set with Pre-attached Holder510(k) Number: K980414
Product Name: VACUTAINER® Brand Blood Collection
Set and Safety-LokTM Blood Collection Set
IMPROVACUTER® Blood Collection
Set510(k) Number: K980414
Product Name: VACUTAINER® Brand Blood Collection
Set and Safety-LokTM Blood Collection Set
IMPROSAFE® Multi Sample Needle510(k) Number: K982541
Product Name: VACUTAINER® Brand ECLIPSETM Blood
Collection Needle
IMPROSAFE® Multi Sample Needle
(Flashback)510(k) Number: K982541
Product Name: VACUTAINER® Brand ECLIPSETM Blood
Collection Needle
IMPROVACUTER® Multi Sample
Needle510(k) Number: K090426
Product Name: VAKU-8TM Blood Collection Needle
    1. Identification of Predicate Devices
      The IMPROSAFE® Blood Collection Sets with Pre-attached holder are intended to be used with evacuated blood collection tube for the collection of venous blood. The safety shield is intended to aid in the protection against accidental needle stick injury.

The IMPROVACUTER® Blood Collection Sets with Pre-attached holder are intended to be used with evacuated blood collection tube for the collection of venous blood.

The IMPROVACUTER® Blood Collection Sets are intended to be used with evacuated blood collection tube for the collection of venous blood.

The IMPROSAFE® Blood Collection Sets are intended to be used with evacuated blood collection tube for the collection of venous blood. The safety shield is intended to aid in the protection against accidental needle stick injury.

11

The IMPROSAFE® Multi-Sample Needles are intended to be used with evacuated blood collection tube for the collection of yenous blood. The safety shield is intended to aid in the protection against accidental needle stick injury.

The IMPROVACUTER® Multi-Sample Needles are used with holder and vacuum blood collection tube for the venous blood collection.

The IMPROSAFE® Multi-Sample Needles (Flashback) are intended to be used with evacuated blood collection tube for the collection of venous blood. The safety shield is intended to aid in the protection against accidental needle stick injury.

Indication for Use Statement:

The proposed device IMPROSAFE® Blood Collection Set with Pre-attached Holder, IMPROVACUTER® Blood Collection Set with Pre-attached Holder, IMPROVACUTER® Blood Collection Set, IMPROSAFE® Blood Collection Set are not indicated for intravenous administration of fluids compared to predicate device. However, both proposed devices and predicate device are indicated for collection of venous blood. Therefore, this difference does not affect safety and effectiveness.

The indication for use of proposed devices IMPROSAFE® Multi Sample Needle, IMPROVACUTER® Multi Sample Needle, IMPROSAFE® Multi Sample Needle (Flashback) are identical to predicate device .

    1. Device Description
      The proposed devices are blood collection sets form a channel between patient's vein and the evacuated blood collection tube intended for collection of blood. They are available in different configurations as follows:

| Model | Patient-End
Needle | Non-Patient
End Needle | Flexible
Tubing | Pre-attached
Holder | Safety
Mechanism | Visible Flash
Back |
|-------------------------------------------------------------------|-----------------------|---------------------------|--------------------|------------------------|---------------------|-----------------------|
| MPROSAFE® Blood Collection
Set with Pre-attached holder | X | X | X | X | X | X |
| IMPROSAFE® Blood Collection
Set | X | X | X | N.A. | X | X |
| IMPROVACUTER® Blood
Collection Set with Pre-attached
Holder | X | X | X | X | N.A. | X |
| IMPROVACUTER® Blood
Collection Set | X | X | X | N.A. | N.A. | X |
| IMPROSAFE® Multi Sample
Needle | X | X | N.A. | X | X | N.A. |

12

IMPROSAFE® Multi Sample Needle (Flashback)XXN.A.XXX
IMPROVACUTER® Multi Sample NeedleXXN.A.N.A.N.A.N.A.
ModelNeedle GaugeNeedle Length
MPROSAFE® Blood Collection Set with Pre-attached holder21G, 23G, 25G, 27G3/4", 2/5"
IMPROSAFE® Blood Collection Set21G, 23G, 25G, 27G3/4", 2/5"
IMPROVACUTER® Blood Collection Set with Pre-attached Holder21G, 23G, 25G, 27G3/4", 2/5"
IMPROVACUTER® Blood Collection Set21G, 23G, 25G, 27G3/4", 2/5"
IMPROSAFE® Multi Sample Needle21G, 22G1", 1 1/2"
IMPROSAFE® Multi Sample Needle (Flashback)21G, 22G1", 1 1/4"
IMPROVACUTER® Multi Sample Needle21G, 22G1", 1 1/2"

6. Non-Clinical Test Conclusion

Non clinical tests were conducted to verify that the proposed device met all design specifications as was Substantially Equivalent (SE) to the predicate device. The test results demonstrated that the proposed device complies with the following standards:

  • ISO 9626:1991+AMENDMENT 1 2001 Stainless steel needle tubing for the manufacture of medical devices;

  • ISO 7864: 1993 Sterile hypodermic needles for single use

  • ア ISO 10993-7:2008 Biological evaluation of medical devices- Part 7: Ethylene oxide sterilization residuals;
  • A ASTM F 88/F88M-09 Standard test method for seal strength of flexible barrier materials;
  • ASTM F1929-12 Standard Test Method for Detecting Seal Leaks in Porous Medical Packaging by Dye Penetration;

  • USP38-NF33 Bacterial Endotoxins Limit.

  • ISO 10993-5:2009 Biological evaluation of medical devices-Part 5: Tests for in vitro cytotoxicity.

  • A ISO 10993-10:2010 Biological evaluation of medical devices- Part 10: Test for irritation and delayed-type hypersensitivity
  • ISO 10993-11:2006 Biological evaluation of medical devices- Part 11: Tests for systemic toxicity

  • ASTM F 756-13 Standard practice for assessment of hemolytic properties of materials

  • Guidance for Industry and FDA Staff: Medical Devices with Sharps Injury Prevention Features

      1. Clinical Test Conclusion

No clinical study is included in this submission.

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8. Substantially Equivalent (SE) Comparison

ITEMProposed DevicePredicate DeviceReference Device 1Reference Device 2
K982541K980414K090426
ClassIIIIIIII
Intended UseThe IMPROSAFE® Blood Collection
Sets with Pre-attached holder are
intended to be used with evacuated
blood collection tube for the collection
of venous blood. The safety shield is
intended to aid in the protection against
accidental needle stick injury.
The IMPROVACUTER® Blood
Collection Sets with Pre-attached
holder are intended to be used with
evacuated blood collection tube for the
collection of venous blood.
The IMPROVACUTER® Blood
Collection Sets are intended to be used
with evacuated blood collection tube
for the collection of venous blood.
The IMPROSAFE® Blood Collection
Sets are intended to be used with
evacuated blood collection tube for the
collection of venous blood. The safety
shield is intended to aid in theVACUTAINER® Brand ECLIPSE™
Blood Collection Needle is designed
for use with VACUTAINER® Brand
Blood Collection Needle Holders in
performing venipuncture to obtain
blood samples. After venipuncture,
the safety shied is activated with
thumb pressure. The hinged safety
shield pivots up and over the needle,
locking into place. In the activated
position, the safety shield protects
against accidental needle stick during
normal handling and disposal.The VACUTAINER® Brand Blood Collection
Set and Safety-Lok™ Blood Collection Set
are winged blood collection needles with
flexible tubing and a female luer adapter
intended for venipuncture to obtain blood
samples from patients or monitoring blood
pressure. The Safety-Lok™ Blood Collection
Set is provided with a safety shield for
covering the used needle prior to disposal.
Some reorder numbers are provided with a
male luer adapter. The male luer adapter
contains a non-patient needle end for
puncturing the stopper of an evacuated blood
collection tube. Those without a male luer
adapter are provided with a protective cap on
the end of the female luer adapter.
The VACUTAINER® Brand Blood
Collection Set and Safety-Lok™ Blood
Collection Set is also indicated for the
intravenous administration of fluids and may
be used for any patient population withVAKU-8™ Blood Collection Needles
are designed for routine blood
collection by q qualified practitioner.
protection against accidental needle
stick injury.
The IMPROSAFE® Multi-Sample
Needles are intended to be used with
evacuated blood collection tube for the
collection of venous blood. The safety
shield is intended to aid in the
protection against accidental needle
stick injury.
The IMPROVACUTER® Multi-Sample
Needles are used with holder and
vacuum blood collection tube for the
venous blood collection.
The IMPROSAFE® Multi-Sample
Needles (Flashback) are intended to be
used with evacuated blood collection
tube for the collection of venous blood.
The safety shield is intended to aid in
the protection against accidental needle
stick injury.consideration given to patient size,
appropriateness for the solution being infused
and duration of therapy.
ConfigurationProtective Cover of Patient end NeedleProtective Cover of Patient end NeedleProtective Cover of Patient end NeedleTop Cover
Patient end NeedleNeedlePatient end NeedleNeedle
Double Wing Needle HandleNeedleDouble Wing Needle HandleButton Cover
Flexible TubingNeedle HubFlexible TubingNeedle Hub
Conical Fitting ConnectorRubber SleeveConical Fitting ConnectorRubber Sleeve
Conical FittingSafety ShieldConical Fitting
Rubber SleeveRubber Sleeve

Table 1 Comparison of Technology Characteristics

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15

| | Non-patient end Needle
Safety Shield
Needle Holder | | Non-patient End Needle
Safety Shield | |
|------------------|--------------------------------------------------------------|-----------------------------------------------------------|-----------------------------------------------------------|-----------------------------------------------------------|
| Performance | Conform with ISO 9626:1991 AMD
2001 and ISO 7864: 1993 | Conform with ISO 9626:1991 AMD
2001 and ISO 7864: 1993 | Conform with ISO 9626:1991 AMD 2001
and ISO 7864: 1993 | Conform with ISO 9626:1991 AMD
2001 and ISO 7864: 1993 |
| Specification | 21G, 22G, 23G, 25G, 27G
3/4", 2/5", 1", 1 1/4" and 1 1/2" | 21G, 22G
1.25" | 21G, 23G, 25G
0.75" | 21G, 22G, 23G
1" and 1.5" |
| Sterile | EO sterilized | EO sterilized | EO sterilized | EO sterilized |
| Single Use | Single Use | Single Use | Single Use | Single Use |
| Biocompatibility | Conform with ISO 10993 | Conform with ISO 10993 | Conform with ISO 10993 | Conform with ISO 10993 |
| Label/Labeling | Conform with 21 CFR Part 801 | Conform with 21 CFR Part 801 | Conform with 21 CFR Part 801 | Conform with 21 CFR Part 801 |

The intended use of proposed device IMPROSAFE® Blood Collection Set with Pre-attached Holder, MPROVACUTER® Set with Pre-attached Holder, IMPROVACUTER® Blood Collection Set, IMPROSAFE® Blood Collection Set are sterile single use needle with without holder for the collection of venous blood. Although the indication for use are not identical to the predicate devices, it does not change the intended use beause they are both single use devices intended for collection of venous blood.

9. Substantially Equivalent (SE) Conclusion

Comparison results demonstrations and performance of the device are substantially equivalent to the legally market predicate device. Therefore, it is concluded that IMPROSAFE® Multi Sample Needle, MPROVACUTER® Multi Sample Needle (Flashback) are substantially equivalent to the legally marketed predicate devices.