K Number
K163162
Device Name
Sterile Hypodermic Safety Syringes for Single Use
Date Cleared
2017-03-20

(130 days)

Product Code
Regulation Number
880.5860
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Sterile Hypodermic Safety Syringes for Single Use is intended to be used for medical purpose to inject fluids into or withdraw fluids from the body. After injection, the anti-needlestick feature is manually activated to aid in the prevention of accidental needle stick injuries.
Device Description
The proposed devices are for single use only, which are comprised of syringes and needles with various specifications. The proposed devices are available in a variety combination of needle sizes and syringe volumes. All specifications of proposed devices subject to the same design. The proposed devices are intended for manual use only.
More Information

Not Found

No
The device description and performance studies focus on the physical, mechanical, and safety features of a manual syringe, with no mention of AI or ML.

No.
The device is a syringe and needle used for injection or withdrawal of fluids, and its primary function is not to treat or alleviate a disease, injury, or disability. The safety feature is for injury prevention during use, not for therapeutic effect on the patient.

No

The device is a sterile hypodermic safety syringe used for injecting or withdrawing fluids from the body; its function is interventional (delivery/extraction), not diagnostic (identifying a condition).

No

The device description clearly states it is comprised of syringes and needles, which are physical hardware components, not software.

Based on the provided information, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use is clearly stated as "to inject fluids into or withdraw fluids from the body." This describes a device used on the body for therapeutic or diagnostic procedures, not a device used with samples taken from the body to diagnose conditions.
  • Device Description: The description focuses on the physical components (syringes and needles) and their function in injecting and withdrawing fluids. There is no mention of analyzing biological samples.
  • Lack of IVD Characteristics: The document does not mention any of the typical characteristics of an IVD, such as:
    • Analyzing biological samples (blood, urine, tissue, etc.)
    • Detecting specific analytes (proteins, genes, pathogens, etc.)
    • Providing diagnostic information based on sample analysis.

The device described is a medical device used for administering substances or collecting samples directly from a patient, which falls under a different regulatory category than IVDs.

N/A

Intended Use / Indications for Use

The Sterile Hypodermic Safety Syringes for Single Use is intended to be used for medical purpose to inject fluids into or withdraw fluids from the body. After injection, the anti-needlestick feature is manually activated to aid in the prevention of accidental needle stick injuries.

Product codes

MEG, FMI

Device Description

The proposed devices are for single use only, which are comprised of syringes and needles with various specifications. The proposed devices are available in a variety combination of needle sizes and syringe volumes. All specifications of proposed devices subject to the same design. The proposed devices are intended for manual use only.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Not Found

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

Not Found

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

Not Found

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

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 provided in this submission include:
Physical, Mechanical and Chemical Tests performed on the proposed device according to ISO 9626:1991/AMD-1:2001, ISO 7886:1993, ISO 594-2:1998, ISO 7864:1993, and ISO 594-1:1986.
Sterile Barrier Packaging Testing performed on the proposed device using ASTM F88/F88-09 and ASTM F1140/F1140M-13.
Sterilization and Shelf Life Testing performed on the proposed device using ISO 10993-7:2008, ISO 11737-2: 2009, and USP 36-NF 31. Shelf Life Evaluation involved Physical, Mechanical, Chemical, Package and Sterility Tests performed on real time aging samples.
Biocompatibility Testing: performed according to ISO 10993 standards.
Simulated Clinical Study: Performed on proposed device according to FDA Guidance, Guidance for Industry and FDA Staff: Medical Device with Sharps Injury Prevention Feature, issued on August 9, 2005 to evaluate the safety mechanism. The results demonstrated that the proposed device met the pre-established criteria.
Safety Feature Test: performed on both proposed device and predicate device. The results demonstrated that the proposed device did not show a significant difference from predicate device.
No clinical study is included in this submission.

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

Not Found

Predicate Device(s)

K072739

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 880.5860 Piston syringe.

(a)
Identification. A piston syringe is a device intended for medical purposes that consists of a calibrated hollow barrel and a movable plunger. At one end of the barrel there is a male connector (nozzle) for fitting the female connector (hub) of a hypodermic single lumen needle. The device is used to inject fluids into, or withdraw fluids from, the body.(b)
Classification. Class II (performance standards).

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

March 20, 2017

JiangXi HongDa Medical Equipment Group Ltd. c/o Ms. Diana Hong Mid-Link Consulting Co., Ltd P.O. Box 120-119 Shanghai. 200120 CHINA

Re: K163162

Trade/Device Name: Sterile Hypodermic Safety Syringes for Single Use Regulation Number: 21 CFR 880.5860 Regulation Name: Piston Syringe Regulatory Class: II Product Code: MEG, FMI Dated: February 14, 2017 Received: February 15, 2017

Dear Ms. Diana Hong:

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. Isting 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.

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Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807): labeling (21 CFR Part 801): medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please 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" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to

http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.

You may obtain other general information on your responsibilities under the Act from the Division of 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, Tina Kiang -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

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Indications for Use

510(k) Number (if known) K163162

Device Name

Sterile Hypodermic Safety Syringes for Single Use

Indications for Use (Describe)

The Sterile Hypodermic Safety Syringes for Single Use is intended to be used for medical purpose to inject fluids into or withdraw fluids from the body. After injection, the anti-needlestick feature is manually activated to aid in the prevention of accidental needle stick injuries.

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)

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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: K163162

    1. Date of Preparation: 03/15/2017
    1. Sponsor Identification

JiangXi HongDa Medical Equipment Group Ltd.

No. 39 South Shengli Road, Jinxian County, Nanchang City, Jiangxi Province, 331700, China

Establishment Registration Number: Not yet registered

Contact Person: Yang Xiaohua Position: Vice-general Manager Tel: +86-791-85628918 Fax: +86-791-85628881 Email: yxh2821006@126.com

    1. Designated Submission Correspondent
      Ms. Diana Hong (Primary Contact Person) Ms. Ying Xu (Alternative Contact Person)

Mid-Link Consulting Co., Ltd

P.O. Box 120-119, Shanghai, 200120, China

Tel: +86-21-22815850, Fax: 240-238-7587 Email: info@mid-link.net

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4. Identification of Proposed Device

Trade Name: Sterile Hypodermic Safety Syringes for Single Use Common Name: Piston Syringe with Needle

Regulatory Information Classification Name: Syringe Antistick Classification: II Product Code: MEG Subsequent Product Code: FMI Regulation Number: 21 CFR 880.5860 Review Panel: General Hospital

Indication for Use:

The Sterile Hypodermic Safety Syringes for Single Use is intended to be used for medical purpose to inject fluids into or withdraw fluids from the body. After injection, the anti-needlestick feature is manually activated to aid in the prevention of accidental needle stick injuries.

Device Description

The proposed devices are for single use only, which are comprised of syringes and needles with various specifications. The proposed devices are available in a variety combination of needle sizes and syringe volumes. All specifications of proposed devices subject to the same design. The proposed devices are intended for manual use only.

5. Identification of Predicate Device

510(k) Number: K072739 Product Name: Retractable Auto-Disable Syringe for single use, with/without needle

    1. 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 provided in this submission include:

Physical, Mechanical and Chemical Tests performed on the proposed device

MaterialsClause 3 of ISO 9626:1991/AMD-1:200
Surface finishClause 4 of ISO 9626:1991/AMD-1:200
CleanlinessClause 5 of ISO 9626:1991/AMD-1:200

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Limits for acidity and alkalinityClause 6 of ISO 9626:1991/AMD-1:2001
Size designationClause 7 of ISO 9626:1991/AMD-1:2001
DimensionsClause 8 of ISO 9626:1991/AMD-1:2001
StiffnessClause 9 of ISO 9626:1991/AMD-1:2001
Resistance to breakageClause 10 of ISO 9626:1991/AMD-1:2001
Resistance to corrosionClause 11 of ISO 9626:1991/AMD-1:2001

Cleanliness

  • Limits for acidity or alkalinity Limits for extractable metals Size designation Colour coding Needle hub Sheath Needle tube Needle point Performance

Cleanliness

Limits for acidity or alkalinityClause 6 of ISO 7886:1993
Limits for extractable metalsClause 7 of ISO 7886:1993
LubricantClause 8 of ISO 7886:1993
Tolerance on graduated capacityClause 9 of ISO 7886:1993
Graduated scaleClause 10 of ISO 7886:1993
BarrelClause 11 of ISO 7886:1993
Piston/plunger assemblyClause 12 of ISO 7886:1993
NozzleClause 13 of ISO 7886:1993
PerformanceClause 14 of ISO 7886:1993

Dimension Gauging Liquid leakage Air leakage Separation force Stress cracking

Gauging Clause 4.1 of ISO 594-2:1998 Leakage Clause 4.2 of ISO 594-2:1998 Separation force Clause 4.3 of ISO 594-2:1998 Unscrewing torque Clause 4.4 of ISO 594-2:1998

Clause 4 of ISO 7864:1993 Clause 5 of ISO 7864:1993 Clause 6 of ISO 7864:1993 Clause 7 of ISO 7864:1993

Clause 8 of ISO 7864:1993 Clause 9 of ISO 7864:1993 Clause 10 of ISO 7864:1993 Clause 11 of ISO 7864:1993 Clause 12 of ISO 7864:1993 Clause 13 of ISO 7864:1993

Clause 5 of ISO 7886:1993

ISO 7886:1993 ISO 7886:1993 ISO 7886:1993 f ISO 7886:1993 f ISO 7886:1993 f ISO 7886:1993 f ISO 7886:1993 f ISO 7886:1993 Clause 3 of ISO 594-1:1986 Clause 4.1 of ISO 594-1:1986 Clause 4.2 of ISO 594-1:1986

Clause 4.3 of ISO 594-1:1986 Clause 4.4 of ISO 594-1:1986 Clause 4.5 of ISO 594-1:1986

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Ease of assemblyClause 4.5 of ISO 594-2:1998
Resistance to overridingClause 4.6 of ISO 594-2:1998
Stress crackingClause 4.7 of ISO 594-2:1998

Sterile Barrier Packaging Testing performed on the proposed device:

Seal strengthASTM F88/F88-09
Internal pressureASTM F1140/F1140M-13

Sterilization and Shelf Life Testing performed on the proposed device:

EO residueISO 10993-7:2008
ECH residueISO 10993-7:2008
Sterility testISO 11737-2: 2009
Bacteria Endotoxin LimitUSP 36-NF 31
Shelf Life EvaluationPhysical, Mechanical, Chemical, Package and Sterility
Tests were performed on real time aging samples to
verify the claimed shelf life of the device

Biocompatibility Testing

The patient-contact materials of Sterile Hypodermic Safety Syringes for Single Use are identified and biocompatibility testing is performed according to ISO 10993 standards

Simulated Clinical Study

A simulated clinical study was performed on proposed device according to FDA Guidance, Guidance for Industry and FDA Staff: Medical Device with Sharps Injury Prevention Feature, issued on August 9, 2005 to evaluate the safety mechanism of the proposed device. The results demonstrated that the proposed device met the pre-established criteria.

Safety Feature Test

The safety feature test was performed on both proposed device and predicate device to determine its safety feature. The results demonstrated that the proposed device did not show a significant difference from predicate device.

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7. Clinical Test Conclusion

No clinical study is included in this submission.

Substantially Equivalent (SE) Comparison 8.

Table 1 Comparison of Technology Characteristics

| Item | Proposed Device | Predicate Device
K072739 | |
|-------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------|----------------|
| Product Code | MEG | Same | |
| Regulation Number | 21 CFR 880.5860 | Same | |
| Class | II | Same | |
| Indication for Use | The Sterile Hypodermic Safety Syringes for
Single Use is intended to be used for medical
purpose to inject fluids into or withdraw fluids
from the body. After injection, the
anti-needlestick feature is manually activated to
aid in the prevention of accidental needle stick
injuries. | Similar | |
| Configuration
and material | Barrel | Polypropylene (PP) | Same |
| | Plunger | Polypropylene (PP) | |
| | Piston | Polyisoprene | |
| | Needle hub | Polypropylene (PP) | |
| | Needle cap | Polypropylene (PP) | |
| | Needle tube | Stainless Steel, SUS304 | |
| Operation Mode | For manual use only | | Same |
| Syringe Volume | 5ml | | 3ml, 5ml, 10ml |
| Connector Type | Luer Lock | | Same |
| Needle Gauge and
Length | Gauge:21G, 22G, 23G
Length: 1", 1 1/4", 1 1/2" | | Similar |
| Biocompatibility | Cytotoxicity | No cytotoxicity | Same |
| | Irritation | No intracutaneous reactivity | |
| | Sensitization | No skin sensitization | |
| | Systemic Toxicity | No systemic toxicity | |
| | Hemolysis | No Hemolysis | |
| | Pyrogen | No Pyrogen | |
| Sterilization | EO Sterilization | | Same |
| SAL | $10^{-6}$ | | Same |
| Single Use | Yes | Same | |
| Label/Labeling | Complied with 21 CFR part 801 | Same | |

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The Sterile Hypodermic Safety Syringe for Single Use is similar to the predicate device in device design, Indications for use, materials, sterilization, method of operation and technological characteristics. The differences are in needle lengths/gauges and barrel sizes. The predicate device submission K072739 also includes insulin syringes and non-safety svringes but the subject device is claiming substantial equivalence to the predicates safety syringe. Through performance testing comparison the subject device and predicate device have demonstrated substantial equivalence.

9. Substantially Equivalent (SE) Conclusion

Based on the bench performance testing, comparison and analysis above, the proposed devices are determined to be Substantially Equivalent (SE) to the predicate devices.