K Number
K161800
Device Name
OnSite-IV
Manufacturer
Date Cleared
2016-12-06

(159 days)

Product Code
Regulation Number
880.5440
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
The OnSite-IV™ is a single use sterile device for the preparation and / or transfer of drugs from a standard pharmaceutical vial into an elastomeric pump or IV bag.
Device Description
The OnSite-IV™ device is a sterile, single use device that, through the use of an integrated vial spike, facilitates creation of a sterile fluid path to transfer liquid from the syringe body to a standard pharmaceutical vial with a 20 mm cap containing a drug, in order to mix or reconstitute the drug and aspirate and transfer the prepared drug back into the syringe body for delivery into an IV bag or elastomeric pump. The device is intended to be used by health care professionals (HCPs) such as physicians, nurses and pharmacists in a clinical setting.
More Information

Not Found

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

No
The device is described as a sterile, single-use device for the preparation and transfer of drugs, not for directly treating a disease or condition. It is an accessory for drug delivery.

No

Explanation: The device is intended for the preparation and transfer of drugs, not for diagnosing medical conditions.

No

The device description clearly outlines a physical, sterile, single-use device with an integrated vial spike and syringe body, designed for the preparation and transfer of drugs. The performance studies also detail testing related to physical properties, sterilization, and biocompatibility, all indicative of a hardware device.

Based on the provided information, the OnSite-IV™ device is not an In Vitro Diagnostic (IVD).

Here's why:

  • Intended Use: The intended use is for the "preparation and / or transfer of drugs from a standard pharmaceutical vial into an elastomeric pump or IV bag." This describes a process involving the handling and administration of drugs, not the examination of specimens derived from the human body to provide information for diagnosis, monitoring, or screening.
  • Device Description: The description details a device for transferring liquids between vials, syringes, IV bags, and pumps. It focuses on the mechanical process of drug preparation and transfer.
  • Lack of IVD Characteristics: The document does not mention any of the typical characteristics of an IVD, such as:
    • Analyzing biological specimens (blood, urine, tissue, etc.)
    • Detecting or measuring substances in specimens
    • Providing information for diagnosis, monitoring, or screening of diseases or conditions.

The device is clearly intended for drug handling and administration in a clinical setting, which falls under the category of medical devices, but not specifically In Vitro Diagnostics.

N/A

Intended Use / Indications for Use

The OnSite-IV™ is a single use sterile device for the preparation and / or transfer of drugs from a standard pharmaceutical vial into an elastomeric pump or IV bag.

Product codes

LHI

Device Description

The OnSite-IV™ device is a sterile, single use device that, through the use of an integrated vial spike, facilitates creation of a sterile fluid path to transfer liquid from the syringe body to a standard pharmaceutical vial with a 20 mm cap containing a drug, in order to mix or reconstitute the drug and aspirate and transfer the prepared drug back into the syringe body for delivery into an IV bag or elastomeric pump. The device is intended to be used by health care professionals (HCPs) such as physicians, nurses and pharmacists in a clinical setting.

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

health care professionals (HCPs) such as physicians, nurses and pharmacists in a clinical setting.

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)

Design verification & validation testing was conducted per FDA recognized standards and additional device specific performance requirements. Testing per ISO 7886-1:1993 - Sterile hypodermic syringes for single use -- Part 1: Syringes for manual use included:

  • Limits for Acidity or Alkalinity
  • Limits for Extractable Metals
  • Tolerance on Graduated Capacity
  • Dead Space
  • Liquid Leakage at Syringe Piston under Compression
  • Air Leakage at Syringe Piston under Compression
  • Air Leakage past Syringe Piston during Aspiration
  • Fiducial Line
  • Fit of Piston in Barrel

Sterilization of the device was validated in accordance with the VDmax 25 method described by ANSI/AAMI/ISO 11137-2:2013 to establish a 106 sterility assurance level (SAL).

Biocompatibility testing was conducted based on the nature and duration of contact, the construction of the device, and both the ISO 10993-1 recommendations and the FDA Guidance for Use of ISO10993-1:

  • Cytotoxicity Study using the ISO Elution Method (ISO 10993-5)
  • Maximization Sensitization (ISO 10993-10)
  • Intracutaneous Reactivity Irritation Test in Rabbits (ISO 10993 Part 10)
  • Acute Systemic Toxicity Test in Mice (ISO 10993-11)
  • Hemolysis, Extract Method (ASTM F 756)
  • Hemolysis, Direct Method (ASTM F 756)
  • Materials Mediated Pyrogen Test in Rabbits (ISO 10993-11, USP )

Additional performance testing of the device included:

  • Luer Connection Performance (ISO 594-1, ISO 594-2)
  • Particulate Matter (USP )
  • Performance of the Bacterial Retentive Filter (ASTM F2101)

Further performance-based testing to internal requirements was also conducted after sterilization, simulated transportation conditioning and accelerated aging:

  • Visual Inspection
  • Device Retained Volume After Use
  • Drug Mixing
  • Force to Operate Valve
  • Graduated Marking Durability

All features provided for the OnSite-IV™ have been verified to operate as specified. Testing confirms that the OnSite-IV™ can be used according to its intended use and in an equivalent manner to the predicate devices.

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

Not Found

Predicate Device(s)

E-Z-Link - K133097, IV Fluid Transfer Pin - K925401

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

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.

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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" 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

December 6, 2016

PharmaC, LLC % Sigi Caron Medtech Consultants. Inc. 20370 Skyhawk Lane Topanga, California 90290

Re: K161800

Trade/Device Name: OnSite-IVTM Regulation Number: 21 CFR 880.5440 Regulation Name: Intravascular Administration Set Regulatory Class: II Product Code: LHI Dated: November 7, 2016 Received: November 8, 2016

Dear Sigi Caron:

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.

1

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 of medical devicerelated adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please 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,

Image /page/1/Picture/8 description: The image contains a signature and the name "Tina Kiang". The signature is a complex, looping design to the left of the name. Below the name is the character string "-s".

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

Indications for Use

510(k) Number (if known) K161800

Device Name OnSite-IVTM

Indications for Use (Describe)

The OnSite-IV™ is a single use sterile device for the preparation and / or transfer of drugs from a standard pharmaceutical vial into an elastomeric pump or IV bag.

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)

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510(K) SUMMARY - K161800

This 510(k) summary is being submitted in accordance with the requirements of SMDA 1990 and 21 CFR 807.92.

DATE PREPAREDDecember 6, 2016
APPLICANTPharmaC, LLC.
6655 North Vista Lane
Jackson, WY 83001
Tel: (307) 690-3648
OFFICIAL CORRESPONDENTSigi Caron
Vice President, Regulatory and Clinical Affairs, PharmaC,
LLC.
Principal, MedTech Consultants, Inc.
20370 Skyhawk Lane
Topanga, CA 90290
sigi@medtechconsultants.com
Tel: (310) 455-3473
Fax: (888) 295-1535
TRADE NAMEOnSite-IVTM
COMMON NAMEVial Adapter / Reconstitution Device
DEVICE CLASSIFICATIONRegulation Number - 21 CFR §880.5440
Regulation Name - Intravascular administration set
Product Code LHI, Class-II
PREDICATE DEVICEE-Z-Link - K133097
IV Fluid Transfer Pin - K925401

DESCRIPTION OF THE DEVICE SUBJECT TO PREMARKET NOTIFICATION:

The OnSite-IV™ device is a sterile, single use device that, through the use of an integrated vial spike, facilitates creation of a sterile fluid path to transfer liquid from the syringe body to a standard pharmaceutical vial with a 20 mm cap containing a drug, in order to mix or reconstitute the drug and aspirate and transfer the prepared drug back into the syringe body for delivery into an IV bag or elastomeric pump. The device is intended to be used by health care professionals (HCPs) such as physicians, nurses and pharmacists in a clinical setting.

INDICATIONS FOR USE:

The OnSite-IV™ is a single use sterile device indicated for the preparation and / or transfer of drugs from a standard pharmaceutical vial into an elastomeric pump or IV bag.

4

SUBSTANTIALLY EQUIVALENT TO:

The OnSite-IV™ device is substantially equivalent in intended use and technological features to the E-Z Link device (K133097) and the IV Fluid Transfer Pin (K925401).

TECHNICAL CHARACTERISTICS:

The design and handling characteristics of the OnSite-IV are based on a standard injection syringe. The OnSite-IV consists of three main components: Syringe Barrel, Stopper, and Plunger with integrated vial spike (IV Fluid Transfer Pin - K925401). The Syringe Barrel has an elliptical shape with a Luer lock connector and is printed with graduation markers to indicate volume. The Syringe Barrel also has an arrow marker to indicate rotational position. The Stopper is an elastomeric sealing material that has an elliptical shape to prevent rotation within the Syringe Barrel. Rotation of the Stopper is prevented to allow the stopper to act as a valve. The Stopper has a fluid pathway and features that create a valve at the interface between the Plunger and Stopper. The Plunger has an internal fluid pathway along its length and an arrow marker to indicate rotational position. The integrated vial spike on the Plunger utilizes a bacterial retentive air-venting filter.

The OnSite-IV™ device shares the same design features as the predicate devices and does not introduce any new technological characteristics. The indications for use are similar. Both are intended for use to mix drugs in a standard pharmaceutical vial and to transfer the prepared drug back into the syringe. The OnSite-IV™ is used to transfer prepared drug into an IV bag or an elastomeric pump. This additional capability does not impact the performance of the OnSite-IVTM. The following table compares the feature of the proposed device and its predicates.

| ELEMENT | ONSITE-IV™ | E-Z-LINK
K133097 | IV FLUID
TRANSFER PIN
K925401 |
|-----------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------|
| Indications for Use | The OnSite-IV™ is a
sterile, single use
device indicated for
the preparation and /
or transfer of drugs
from a standard
pharmaceutical vial
into an elastomeric
pump or IV bag. | Single use, sterile
device for
preparation or drugs
in a standard vial
using liquid from a
standard luer
syringe to transfer
the prepared drug
back into the
syringe for delivery. | Vented with
security clip for
preparing and
dispensing
diluent from
standard 20 mm
rubber-
stoppered vials |
| Design Features | | | |
| Has vial adapter / vial
access component | yes | yes | yes |
| Has a syringe component | yes | yes | No syringe
component |
| ELEMENT | ONSITE-IVTM | E-Z-LINK
K133097 | IV FLUID
TRANSFER PIN
K925401 |
| Syringe and vial adapter
integrated into one
component | yes | No, 2 component
system | No. Only vial
adapter |
| Needleless access to vial | yes | No, contains plastic
and stainless steel
cannulas | yes |
| Sterile, biocompatible
fluid path | yes | yes | yes |
| Assembled from plastic
injection molded
components | yes | yes | yes |
| Single use, sterile | yes | yes | yes |
| Principles of Operation | | | |
| Manually operated | yes | yes | yes |
| • mechanically
connected to a drug
vial | yes | yes | yes |
| • transfers liquid
manually using a
syringe plunger rod | yes | yes | No. Not
supplied with
syringe |
| • mixing / drug
reconstitution
achieved through
manual agitation of
the vial while
connected to device | yes | yes | yes |
| • mixed drug is
manually aspirated
back into the syringe
barrel using the
syringe plunger rod | yes | yes | No. Not
supplied with
syringe |

5

SUMMARY OF NONCLINICAL TESTING:

Design verification & validation testing was conducted per FDA recognized standards and additional device specific performance requirements. Testing per ISO 7886-1:1993 - Sterile hypodermic syringes for single use -- Part 1: Syringes for manual use included:

  • Limits for Acidity or Alkalinity ●
  • . Limits for Extractable Metals
  • Tolerance on Graduated Capacity ●

6

  • Dead Space ●
  • Liquid Leakage at Syringe Piston under Compression
  • Air Leakage at Syringe Piston under Compression ●
  • Air Leakage past Syringe Piston during Aspiration
  • Fiducial Line
  • . Fit of Piston in Barrel

Sterilization of the device was validated in accordance with the VDmax 25 method described by ANSI/AAMI/ISO 11137-2:2013 to establish a 106 sterility assurance level (SAL).

Biocompatibility testing was conducted based on the nature and duration of contact, the construction of the device, and both the ISO 10993-1 recommendations and the FDA Guidance for Use of ISO10993-1:

  • Cytotoxicity Study using the ISO Elution Method (ISO 10993-5) ●
  • Maximization Sensitization (ISO 10993-10)
  • Intracutaneous Reactivity Irritation Test in Rabbits (ISO 10993 Part 10)
  • Acute Systemic Toxicity Test in Mice (ISO 10993-11)
  • Hemolysis, Extract Method (ASTM F 756)
  • Hemolysis, Direct Method (ASTM F 756)
  • Materials Mediated Pyrogen Test in Rabbits (ISO 10993-11, USP )

Additional performance testing of the device included:

  • Luer Connection Performance (ISO 594-1, ISO 594-2) ●
  • Particulate Matter (USP )
  • . Performance of the Bacterial Retentive Filter (ASTM F2101)

Further performance-based testing to internal requirements was also conducted after sterilization, simulated transportation conditioning and accelerated aging:

  • Visual Inspection ●
  • Device Retained Volume After Use
  • Drug Mixing
  • Force to Operate Valve ●
  • Graduated Marking Durability

All features provided for the OnSite-IV™ have been verified to operate as specified. Testing confirms that the OnSite-IV™ can be used according to its intended use and in an equivalent manner to the predicate devices.

7

CONCLUSIONS - BASIS FOR DETERMINATION OF SUBSTANTIAL EQUIVALENCE:

The OnSite-IV™ is substantially equivalent to the listed predicate devices (E-Z Link device, K133097 and IV Fluid Transfer Pin - K925401) with respect to its indications for use (intended use) and technical characteristics. The differences between the E-Z Link and the OnSite-IV™ are that the E-Z link uses plastic and stainless steel cannulas to access the drug vial, and the syringe and adapter are provided as separate components. The OnSite-IV™, on the other hand, utilizes an integrated universal vial spike adapter (one integrated device, not two components). Testing per FDA recognized consensus standards, other standards and device specific bench testing demonstrate that the OnSite-IV™ functions as intended in the specific use conditions. The information and data provided in this 510(k) submission identifies that the subject device is substantially equivalent to the predicate devices.