K Number
K153440
Device Name
PowerLoc MAX Power Injectable Infusion Set, SafeStep Huber Needle Set
Manufacturer
Date Cleared
2016-08-18

(265 days)

Product Code
Regulation Number
880.5440
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The PowerLoc MAX® Power-Injectable Infusion Set is an intravascular administration set with a non-coring right angle needle and manually activated needle stick prevention safety mechanism which reduces the risk of accidental needlestick injuries by shielding the needle is used to access surgically implanted vascular ports. The PowerLoc MAX® Power-Injectable Infusion Set is indicated for use in the administration of fluids and drugs, as well as blood sampling through surgically implanted vascular ports. When used with ports that are indicated for power injection of contrast media into the central venous system, the PowerLoc MAX® Power-Injectable Infusion Set is also indicated for power injection of contrast media. For power injection of contrast media, the maximum recommended infusion rate at 11.8 cPs is 5 ml/s for 19 gauge and 20 gauge needles, and 2 ml/s for 22 gauge needles. The SafeStep® Huber Needle Set is a device intended for insertion into the septum of a subcutaneously implanted port and for the infusion of fluids into the port. The SafeStep® Huber Needle safety feature is manually activated during needle removal, and is designed to aid in the prevention of accidental needlesticks.
Device Description
The PowerLoc MAX® Power-Injectable Infusion Set is a standard non-coring intravascular administration set with a non-coring Huber type right angle needle and a manually activated needle-stick prevention safety mechanism which reduces the risk of accidental needlestick injuries by shielding the needle. The device is used to access surgically implanted vascular ports and is indicated for use in the administration of fluids and drugs, as well as blood sampling. The PowerLoc MAX® Power-Injectable Infusion Set is also indicated for power injection of contrast media into the central venous system only through an implanted port that is also indicated for power injection. The maximum recommended infusion rate at 11.8 cPs is 5 ml/s for 19 gauge and 20 gauge needles and 2 ml/s for 22 gauge needles. The PowerLoc MAX® Power-Injectable Infusion Set is offered with and without a Y-site. The SafeStep® Huber Needle Set is a standard right angle Huber needle and administration set with a needlestick prevention feature, designed for use with a vascular access infusion system. It is manufactured with conventional medical grade, biocompatible materials. The SafeStep® Huber Needle Set operates as a standard Huber needle with the addition of a safety feature to aid in the prevention of needlestick injuries to the health practitioner. The SafeStep® Huber Needle Set is offered with and without a Y-site. The stabilization device is intended for use as an accessory to the subject PowerLoc MAX® and SafeStep® infusion sets, and is supplied pre-loaded with the subject devices. It is placed centrally over the implanted port so that the base surrounds the implanted port under the skin. The infusion set needle handle is pressed down until the needle has entered the port septum, then the stabilization device is lifted off of the needle. The stabilization device is then discarded per hospital protocol.
More Information

Not Found

No
The device description and performance studies focus on mechanical and material properties, safety mechanisms, and fluid dynamics, with no mention of AI or ML.

No.
This device is an infusion set that facilitates the administration of fluids and drugs, but it does not directly treat a disease or medical condition.

No

Explanation: The device is described as an "intravascular administration set" and is indicated for the "administration of fluids and drugs, as well as blood sampling" and "power injection of contrast media." These are therapeutic and circulatory access functions, not diagnostic functions. While blood sampling is mentioned, the primary purpose is for access and administration, not for analyzing or diagnosing conditions based on the blood sample itself.

No

The device description clearly outlines physical components such as needles, administration sets, and a stabilization device, indicating it is a hardware medical device.

Based on the provided text, the PowerLoc MAX® Power-Injectable Infusion Set and the SafeStep® Huber Needle Set are not In Vitro Diagnostic (IVD) devices.

Here's why:

  • Intended Use: The intended use clearly states that these devices are for the administration of fluids, drugs, blood sampling, and power injection of contrast media through surgically implanted vascular ports. This involves interacting directly with the patient's circulatory system for therapeutic or diagnostic purposes within the body.
  • Device Description: The description details needles, administration sets, and a stabilization device used for accessing and infusing into vascular ports. This aligns with devices used for direct patient access and treatment.
  • Lack of IVD Characteristics: The text does not mention any of the typical characteristics of an IVD device, such as:
    • Analyzing samples outside the body (in vitro).
    • Detecting or measuring substances in biological samples.
    • Providing information for diagnosis, monitoring, or screening based on in vitro analysis.

In summary, these devices are designed for direct patient access and administration of substances into the body, which falls under the category of medical devices used for treatment and direct patient care, not in vitro diagnostics.

N/A

Intended Use / Indications for Use

The PowerLoc MAX® Power-Injectable Infusion Set is an intravascular administration set with a non-coring right angle needle and manually activated needle stick prevention safety mechanism which reduces the risk of accidental needlestick injuries by shielding the needle is used to access surgically implanted vascular ports.

The PowerLoc MAX® Power-Iniectable Infusion Set is indicated for use in the administration of fluids and drugs, as well as blood sampling through surgically implanted vascular ports.

When used with ports that are indicated for power injection of contrast media into the central venous system, the PowerLoc MAX® Power-Injectable Infusion Set is also indicated for power injection of contrast media. For power injection of contrast media, the maximum recommended infusion rate at 11.8 cPs is 5 ml/s for 19 qauge and 20 gauge needles, and 2 ml/s for 22 gauge needles.

The SafeStep® Huber Needle Set is a device intended for insertion into the septum of a subcutaneously implanted port and for the infusion of fluids into the port. The SafeStep® Huber Needle safety feature is manually activated during needle removal, and is designed to aid in the prevention of accidental needlesticks.

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

FPA

Device Description

PowerLoc MAX® Power-Injectable Infusion Set: The PowerLoc MAX® Power-Injectable Infusion Set is a standard non-coring intravascular administration set with a non-coring Huber type right angle needle and a manually activated needle-stick prevention safety mechanism which reduces the risk of accidental needlestick injuries by shielding the needle. The device is used to access surgically implanted vascular ports and is indicated for use in the administration of fluids and drugs, as well as blood sampling. The PowerLoc MAX® Power-Injectable Infusion Set is also indicated for power injection of contrast media into the central venous system only through an implanted port that is also indicated for power injection. The maximum recommended infusion rate at 11.8 cPs is 5 ml/s for 19 gauge and 20 gauge needles and 2 ml/s for 22 gauge needles. The PowerLoc MAX® Power-Injectable Infusion Set is offered with and without a Y-site.

SafeStep® Huber Needle Set: The SafeStep® Huber Needle Set is a standard right angle Huber needle and administration set with a needlestick prevention feature, designed for use with a vascular access infusion system. It is manufactured with conventional medical grade, biocompatible materials. The SafeStep® Huber Needle Set operates as a standard Huber needle with the addition of a safety feature to aid in the prevention of needlestick injuries to the health practitioner. The SafeStep® Huber Needle Set is offered with and without a Y-site.

Stabilization Device: The stabilization device is intended for use as an accessory to the subject PowerLoc MAX® and SafeStep® infusion sets, and is supplied pre-loaded with the subject devices. It is placed centrally over the implanted port so that the base surrounds the implanted port under the skin. The infusion set needle handle is pressed down until the needle has entered the port septum, then the stabilization device is lifted off of the needle. The stabilization device is then discarded per hospital protocol.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

central venous system

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)

Verification and validation tests were performed in accordance with Design Controls per 21 CFR §820.30. The following performance data were referenced in support of the substantial equivalence determination. Testing was performed based on Bard Access Systems (BAS) internal test protocols as well as on existing standards that are relevant to the subject devices.

Testing performed based on BAS internal test protocols are as follows:
Slide Force testing was performed to ensure that the force required to slide the needle down the length of the stabilization device did not exceed the force required to insert the needle in the port septum.
Stabilization Device Removal Force testing was performed to ensure that it was not difficult to remove the stabilization device once the subject needle was inserted into the port.
Acceptability of the Stabilization Device to verify that the stabilization device was clinically acceptable in the placement of a port access needle.
Acceptability of GuardIVa® with Stabilization Device to validate the use as directed in the IFU of the antimicrobial dressing with the stabilization device.

In addition to BAS internal protocols, the following guidance documents and standards were used to determine appropriate methods for evaluating the performance of the device:
• ISO 23908 First edition 2011-06-11 Sharps injury protection - Requirements and test methods - Sharps protection features for single-use hypodermic needles, introducers for catheters and needles used for blood sampling
• ISO 8536-4 Fifth edition 2010-10-01 Infusion equipment for medical use - Part 4: Infusion sets for single use, gravity feed [Including: Amendment 1 (2013)]10.
• BS EN ISO 8536-10:2015 Infusion equipment for medical use - Part 10: Accessories for fluid lines for single use with pressure infusion equipment.
• ISO 10993-1 Fourth edition, 2009-10-15 - Biological Evaluation of Medical Devices Part 1: Evaluation and Testing within a risk management process.
• ISO 10993-7: 2008 - Biological evaluation of medical devices - Part 7: Ethylene oxide sterilization residuals.
• ISO 11135: 1994 - Medical Devices - Validation and Routine Control of Ethylene Oxide Sterilization.
• BS EN ISO 11607-1 Packaging for terminally sterilized medical devices Part 1: Requirements for materials, sterile barrier systems and packaging systems.
• ISO 594-1: 1986, Conical Fittings with a 6% (Luer) Taper for Syringes, Needles, and Certain Other Equipment.
• ISO 594-2: 1998, Conical Fittings with a 6% (Luer) Taper for Syringes, Needles and Certain Other Medical Equipment - Part 2: Lock Fittings.
• ISO 9626 AMD 1: 2001 - Stainless Steel Needle Tubing for Manufacture of Medical Devices.
• ISO 10555-1: 2013 – Intravascular catheters – Sterile and single-use catheters – Part 1: General requirements.
• ISO 11137-1: 2006 – Sterilization of health care products – Radiation - Part 1: Requirements for development, validation and routine control of a sterilization process for medical devices.
• ISO 7864: 1993 – Sterile hypodermic needles for single use.
• FDA Guidance Medical Devices with Sharps Injury Prevention Features issued August 9, 2005.
• FDA Guidance Establishing Safety and Compatibility of Passive Implants in the Magnetic Resonance (MR) Environment issued December 11, 2014.

The subject devices met all predetermined acceptance criteria derived from the above listed references and demonstrated substantially equivalent performance as compared to the cited predicate devices.
Risk management, including a failure modes and effects analysis (FMEA), of the subject device was conducted in accordance with BS EN ISO 14971:2012, Medical Devices – Risk Management for Medical Devices.

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.

K073050, K040527

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.

Not Found

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

§ 880.5440 Intravascular administration set.

(a)
Identification. An intravascular administration set is a device used to administer fluids from a container to a patient's vascular system through a needle or catheter inserted into a vein. The device may include the needle or catheter, tubing, a flow regulator, a drip chamber, an infusion line filter, an I.V. set stopcock, fluid delivery tubing, connectors between parts of the set, a side tube with a cap to serve as an injection site, and a hollow spike to penetrate and connect the tubing to an I.V. bag or other infusion fluid container.(b)
Classification. Class II (special controls). The special control for pharmacy compounding systems within this classification is the FDA guidance document entitled “Class II Special Controls Guidance Document: Pharmacy Compounding Systems; Final Guidance for Industry and FDA Reviewers.” Pharmacy compounding systems classified within the intravascular administration set are exempt from the premarket notification procedures in subpart E of this part and subject to the limitations in § 880.9.

0

Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. Inside the circle is a stylized image of three human profiles facing 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

August 18, 2016

Darlene Hull Regulatory Affairs Specialist C.R. Bard, Inc. 605 North 5600 West Salt Lake City, Utah 84116

Re: K153440

Trade/Device Name: PowerLoc Max® Power-Injectable Infusion Set, SafeStep® Huber Needle Set Regulation Number: 21 CFR 880.5440 Regulation Name: Intravascular Administration Set Regulatory Class: Class II Product Code: FPA Dated: July 19, 2016 Received: July 20, 2016

Dear Darlene Hull:

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.

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

1

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 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, Ph.D. 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

DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Indications for Use

510(k) Number (if known)

K153440

Device Name PowerLoc MAX® Power-Injectable Infusion Set

Indications for Use

The PowerLoc MAX® Power-Injectable Infusion Set is an intravascular administration set with a non-coring right angle needle and manually activated needle stick prevention safety mechanism which reduces the risk of accidental needlestick injuries by shielding the needle is used to access surgically implanted vascular ports.

The PowerLoc MAX® Power-Iniectable Infusion Set is indicated for use in the administration of fluids and drugs, as well as blood sampling through surgically implanted vascular ports.

When used with ports that are indicated for power injection of contrast media into the central venous system, the PowerLoc MAX® Power-Injectable Infusion Set is also indicated for power injection of contrast media. For power injection of contrast media, the maximum recommended infusion rate at 11.8 cPs is 5 ml/s for 19 qauge and 20 gauge needles, and 2 ml/s for 22 gauge needles.

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) 区

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 FDA 3881 (8/14)Page 1 of 1PSC
Publishing Services (301) 443-6740EF

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

3

DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Indications for Use

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

510(k) Number (if known)

K153440

Device Name SafeStep® Huber Needle Set

Indications for Use

The SafeStep® Huber Needle Set is a device intended for insertion into the septum of a subcutaneously implanted port and for the infusion of fluids into the port. The SafeStep® Huber Needle safety feature is manually activated during needle removal, and is designed to aid in the prevention of accidental needlesticks.

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

区 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 FDA 3881 (8/14)
Publishing Services (301) 443-6740

Page 1 of 1

PSC

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510(k) Summary

21 CFR § 807.92(a)

| General
Provisions | Submitter Name:
Address: | Bard Access Systems, Inc.
605 North 5600 West
Salt Lake City, UT 84116 |
|-----------------------|-------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | Contact Person:
Telephone Number:
Fax Number:
Date of Preparation: | Darlene Hull
Regulatory Affairs Specialist
(801) 522-5613
(801) 522-5425
23 November 2015 |
| Subject
Devices | Trade Name:
Common Name:
Classification Name:
Product Code/
Regulation: | PowerLoc MAX® Power-Injectable Infusion Set
Huber Needle Intravascular Administration Set
Intravascular Administration Set
FPA
21 CFR § 880.5440 |
| | Trade Name:
Common Name:
Classification Name:
Product Code/
Regulation: | SafeStep® Huber Needle Set
Huber Needle Intravascular Administration Set
Intravascular Administration Set
FPA
21 CFR § 880.5440 |
| Predicate
Devices | Trade Name:
Classification Name:
Premarket Notification:
Manufacturer: | SafeStep® MAX Power-Injectable Infusion Set
Intravascular Administration Set
K073050
Bard Access Systems, Inc. |
| | Trade Name:
Classification Name:
Premarket Notification:
Manufacturer: | Luther Safety Huber Needle Set
Intravascular Administration Set
K040527
Bard Access Systems, Inc. |

5

PowerLoc MAX® Power-Injectable Infusion Set
The PowerLoc MAX® Power-Injectable Infusion Set is a standard non-
coring intravascular administration set with a non-coring Huber type
right angle needle and a manually activated needle-stick prevention
safety mechanism which reduces the risk of accidental needlestick
injuries by shielding the needle. The device is used to access
surgically implanted vascular ports and is indicated for use in the
administration of fluids and drugs, as well as blood sampling.
The PowerLoc MAX® Power-Injectable Infusion Set is also indicated
for power injection of contrast media into the central venous system
only through an implanted port that is also indicated for power
injection. The maximum recommended infusion rate at 11.8 cPs is 5
ml/s for 19 gauge and 20 gauge needles and 2 ml/s for 22 gauge
needles. The PowerLoc MAX® Power-Injectable Infusion Set is
offered with and without a Y-site.
Device
DescriptionsSafeStep® Huber Needle Set
The SafeStep® Huber Needle Set is a standard right angle Huber
needle and administration set with a needlestick prevention feature,
designed for use with a vascular access infusion system. It is
manufactured with conventional medical grade, biocompatible
materials. The SafeStep® Huber Needle Set operates as a standard
Huber needle with the addition of a safety feature to aid in the
prevention of needlestick injuries to the health practitioner. The
SafeStep® Huber Needle Set is offered with and without a Y-site.
Stabilization Device
The stabilization device is intended for use as an accessory to the
subject PowerLoc MAX® and SafeStep® infusion sets, and is supplied
pre-loaded with the subject devices. It is placed centrally over the
implanted port so that the base surrounds the implanted port under the
skin. The infusion set needle handle is pressed down until the needle
has entered the port septum, then the stabilization device is lifted off of
the needle. The stabilization device is then discarded per hospital
protocol.
Intended UseBoth the subject PowerLoc MAX® Power-Injectable Infusion Set and
SafeStep® Huber Needle Sets, with and without the stabilization
device, are intended for use in the administration of fluids and drugs,
as well as blood sampling through surgically implanted vascular ports.
Indications For
UsePowerLoc MAX® Power-Injectable Infusion Set
The PowerLoc MAX® Power-Injectable Infusion Set is an intravascular
administration set with a non-coring right angle needle and manually
activated needle stick prevention safety mechanism which reduces the
risk of accidental needlestick injuries by shielding the needle. The
needle is used to access surgically implanted vascular ports.
The PowerLoc MAX® Power-Injectable Infusion Set is indicated for
use in the administration of fluids and drugs, as well as blood sampling
through surgically implanted vascular ports.
When used with ports that are indicated for power injection of contrast
media into the central venous system, the PowerLoc MAX® Power-
Injectable Infusion Set is also indicated for power injection of contrast
media. For power injection of contrast media, the maximum
recommended infusion rate at 11.8 cPs is 5 ml/s for 19 gauge and 20
gauge needles, and 2 ml/s for 22 gauge needles.
SafeStep® Huber Needle Set
The SafeStep® Huber Needle Set is a device intended for insertion
into the septum of a subcutaneously implanted port and for the infusion
of fluids into the port. The SafeStep® Huber Needle safety feature is
manually activated during needle removal, and is designed to aid in the
prevention of accidental needlesticks.
Technological
CharacteristicsTechnological characteristics including design and function of the
subject devices, the PowerLoc MAX® Power-Injectable Infusion Set
and SafeStep® Huber Needle Set without stabilization device, are
similar with respect to those of the predicate devices, SafeStep® MAX
Power-Injectable Infusion Set and Luther Safety Huber Needle Set.
The subject devices may be used with a pre-loaded stabilization device
accessory that is intended to stabilize the port during access and aid
insertion of the needle into the port. The stabilization device utilizes
materials that are a different formulation than materials used in the
predicate devices, and have not been used in another legally marketed
device within the same classification regulation with the same intended
use. The stabilization device constitutes a change to the ergonomics of
the patient/user interface of the subject devices, but does not change
the design or function of the subject devices when used as an
accessory to these devices.
Performance
TestsVerification and validation tests were performed in accordance with
Design Controls per 21 CFR §820.30. The following performance data
were referenced in support of the substantial equivalence
determination. Testing was performed based on Bard Access Systems
(BAS) internal test protocols as well as on existing standards that are
relevant to the subject devices.
Testing performed based on BAS internal test protocols are as follows:
Slide Force testing was performed to ensure that the force
required to slide the needle down the length of the stabilization
device did not exceed the force required to insert the needle in

6

7

| the port septum.
Stabilization Device Removal Force testing was performed to
ensure that it was not difficult to remove the stabilization device
once the subject needle was inserted into the port.

Acceptability of the Stabilization Device to verify that the
stabilization device was clinically acceptable in the placement
of a port access needle.
Acceptability of GuardIVa® with Stabilization Device to
validate the use as directed in the IFU of the antimicrobial
dressing with the stabilization device.
In addition to BAS internal protocols, the following guidance
documents and standards were used to determine appropriate
methods for evaluating the performance of the device:
• ISO 23908 First edition 2011-06-11 Sharps injury protection -
Requirements and test methods - Sharps protection features for
single-use hypodermic needles, introducers for catheters and
needles used for blood sampling
• ISO 8536-4 Fifth edition 2010-10-01 Infusion equipment for
medical use - Part 4: Infusion sets for single use, gravity feed
[Including: Amendment 1 (2013)]10.
• BS EN ISO 8536-10:2015 Infusion equipment for medical use -
Part 10: Accessories for fluid lines for single use with pressure
infusion equipment.
• ISO 10993-1 Fourth edition, 2009-10-15 - Biological Evaluation
of Medical Devices Part 1: Evaluation and Testing within a risk
management process.
• ISO 10993-7: 2008 - Biological evaluation of medical devices -
Part 7: Ethylene oxide sterilization residuals.
• ISO 11135: 1994 - Medical Devices - Validation and Routine
Control of Ethylene Oxide Sterilization.
• BS EN ISO 11607-1 Packaging for terminally sterilized medical
devices Part 1: Requirements for materials, sterile barrier
systems and packaging systems.
• ISO 594-1: 1986, Conical Fittings with a 6% (Luer) Taper for
Syringes, Needles, and Certain Other Equipment.
• ISO 594-2: 1998, Conical Fittings with a 6% (Luer) Taper for
Syringes, Needles and Certain Other Medical Equipment - Part
2: Lock Fittings.
• ISO 9626 AMD 1: 2001 - Stainless Steel Needle Tubing for
Manufacture of Medical Devices.
• ISO 10555-1: 2013 – Intravascular catheters – Sterile and
single-use catheters – Part 1: General requirements.
• ISO 11137-1: 2006 – Sterilization of health care products –
Radiation - Part 1: Requirements for development, validation
and routine control of a sterilization process for medical
devices.
• ISO 7864: 1993 – Sterile hypodermic needles for single use.
• FDA Guidance Medical Devices with Sharps Injury Prevention
Features issued August 9, 2005.
• FDA Guidance Establishing Safety and Compatibility of Passive
Implants in the Magnetic Resonance (MR) Environment issued
December 11, 2014.
The subject devices met all predetermined acceptance criteria derived
from the above listed references and demonstrated substantially
equivalent performance as compared to the cited predicate devices.
Risk management, including a failure modes and effects analysis
(FMEA), of the subject device was conducted in accordance with BS
EN ISO 14971:2012, Medical Devices – Risk Management for Medical
Devices.
Summary of
Substantial
EquivalenceBased on the intended use, technological characteristics, and safety
and performance testing, the subject PowerLoc MAX® Power-
Injectable Infusion Set and SafeStep® Huber Needle Set used with
and without the stabilization device meet the requirements that are
considered sufficient for its intended use as compared to the predicate
devices cited. Therefore, the subject devices are substantially
equivalent to the predicates.

8