K Number
K171518
Device Name
Epidural Anesthesia Needles, Spinal Anesthesia Needles, Combined Anesthesia Needles
Date Cleared
2018-01-05

(226 days)

Product Code
Regulation Number
868.5150
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Epidural Anesthesia Needles are intended to be used for injection into the epidural space/or placing the enidural catheter into the epidural space. The Spinal Anesthesia Needles are intended to be used for injection of local anesthetic agent into the subarachnoid cavity for pain management. The Combined Anesthesia Needles are intended for injection of local anesthetics into the spinal and epidural spaces of a patient to provide regional anesthesia. The administration of the spinal anesthesia onset and the placement of an epidural catheter allows for bolus injections or continuous infusion of local anesthetics or other drugs into the epidural space.
Device Description
The proposed device, Epidural Anesthesia Needles are available in a series combination of needle size and length. The needle tubing is stabilized during puncture with use of an inner stylet. The stylet is withdrawn after the epidural anesthesia needle its anatomical site for neuraxial anesthesia. Then an epidural catheter is introduced into epidural cavities for convenience of injecting anesthetic continuously. The proposed device, Spinal Anesthesia Needles are available in a series combination of needle size and length. The spinal anesthesia needle has a tightly fitting removable stylet that completely occludes the lumen to avoid block. The stylet is withdrawn after the spinal anesthesia needle has penetrated into the subarachnoid space for injecting anesthetic. The needles are available in Sprotte and Quincke two type. The proposed device, Combination Anesthesia Needle are instruments for a spinal (subarachnoid) injection of anesthetics, followed by the placement of an epidural catheter to allow modification of the spinal analgesia if necessary, or continuous infusion of local anesthetics into the epidural space for subsequent pain relief if required. The needles are a matched set. The epidural needle and the spinal needle are locked by conical fitting that enable the spinal needle to be locked into position once the dura has been pierced so that it is secured to the epidural needle to prevent accidental displacement.
More Information

Not Found

No
The device description and intended use are purely mechanical in nature, describing needles for delivering anesthesia. There is no mention of any computational or analytical capabilities that would suggest the use of AI or ML.

Yes

This device is used for pain management through the injection of anesthetic agents, which is a therapeutic intervention.

No

The device is described as needles intended for the injection of anesthetics into the epidural and subarachnoid spaces, and for the placement of epidural catheters. Its function is to deliver substances for pain management and regional anesthesia, not to diagnose a condition.

No

The device description clearly details physical needles and associated components for administering anesthesia, indicating it is a hardware medical device.

No, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • IVD Definition: In Vitro Diagnostic devices are used to examine specimens taken from the human body (like blood, urine, tissue) to provide information about a person's health. This testing is done outside of the body ("in vitro").
  • Device Function: The described devices (Epidural, Spinal, and Combined Anesthesia Needles) are used to deliver substances directly into the body (anesthetics into the epidural and subarachnoid spaces). They are used in vivo (within the living body) for a therapeutic purpose (pain management/anesthesia).
  • Lack of Specimen Analysis: There is no mention of these needles being used to collect or analyze any bodily fluids or tissues for diagnostic purposes. Their function is purely for drug delivery and catheter placement.

The description clearly indicates these are instruments for administering anesthesia directly to a patient, which falls under the category of surgical or therapeutic devices, not in vitro diagnostics.

N/A

Intended Use / Indications for Use

The Epidural Anesthesia Needles are intended to be used for injection into the epidural space/or placing the enidural catheter into the epidural space.

The Spinal Anesthesia Needles are intended to be used for injection of local anesthetic agent into the subarachnoid cavity for pain management.

The Combined Anesthesia Needles are intended for injection of local anesthetics into the spinal and epidural spaces of a patient to provide regional anesthesia. The administration of the spinal anesthesia allows rapid anesthesia onset and the placement of an epidural catheter allows for bolus injections or continuous infusion of local anesthetics or other drugs into the epidural space.

Product codes

BSP

Device Description

The proposed device, Epidural Anesthesia Needles are available in a series combination of needle size and length. The needle tubing is stabilized during puncture with use of an inner stylet. The stylet is withdrawn after the epidural anesthesia needle its anatomical site for neuraxial anesthesia. Then an epidural catheter is introduced into epidural cavities for convenience of injecting anesthetic continuously.

The proposed device, Spinal Anesthesia Needles are available in a series combination of needle size and length. The spinal anesthesia needle has a tightly fitting removable stylet that completely occludes the lumen to avoid block. The stylet is withdrawn after the spinal anesthesia needle has penetrated into the subarachnoid space for injecting anesthetic. The needles are available in Sprotte and Quincke two type.

The proposed device, Combination Anesthesia Needle are instruments for a spinal (subarachnoid) injection of anesthetics, followed by the placement of an epidural catheter to allow modification of the spinal analgesia if necessary, or continuous infusion of local anesthetics into the epidural space for subsequent pain relief if required. The needles are a matched set. The epidural needle and the spinal needle are locked by conical fitting that enable the spinal needle to be locked into position once the dura has been pierced so that it is secured to the epidural needle to prevent accidental displacement.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Epidural space, subarachnoid cavity, spinal and epidural spaces.

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 results demonstrated that the proposed device complies with the following standards:

  • A ISO 9626:1991 AMD 1:2001 Stainless Steel Needle Tubing for the Manufacture of Medical Devices.
  • A ISO 7864:1993 Sterile Hypodermic Needles for Single Use
  • ISO 594-1:1986 Conical fittings with a 6% (Luer) taper for syringes, needles and certain other medical equipment- Part 1: General requirements

  • ISO 594-2:1998 Conical fittings with 6% (Luer) taper for syringes, needles and certain other medical equipment- Part 2: Lock fittings

  • ISO 10993-7:2008 Biological evaluation of medical devices- Part 7: Ethylene oxide sterilization residuals;

  • ASTM F88/88M-09 Standard test method for seal strength of flexible barrier materials;

  • ASTM F1140/1140M-13 Standard test methods for internal pressurization failure resistance of unrestrained packages

  • USP38-NF33 Bacterial Endotoxins Test

  • 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

  • ISO 10993-4: 2002/Amd 1: 2006 Biological evaluation of medical devices- Part 4: Selection of tests for interactions with blood

No clinical study is included in this submission.

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

Not Found

Predicate Device(s)

K142553, K141126, K993619

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 868.5150 Anesthesia conduction needle.

(a)
Identification. An anesthesia conduction needle is a device used to inject local anesthetics into a patient to provide regional anesthesia.(b)
Classification. Class II (performance standards).

0

Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: the Department of Health & Human Services logo on the left and the FDA logo on the right. The FDA logo is a blue square with the letters "FDA" in white, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue.

January 5, 2018

Zhejiang kindly Medical Devices Co., Ltd % Diana Hong General Manager Mid-Link Consulting Co., Ltd P.O. Box 120-119 Shanghai, 200120 China

Re: K171518

Trade/Device Name: Epidural Anesthesia Needles, Spinal Anesthesia Needles, Combined Anesthesia Needles Regulation Number: 21 CFR 868.5150 Regulation Name: Anesthesia Conduction Needle Regulatory Class: Class II Product Code: BSP Dated: December 11, 2017 Received: December 13, 2017

Dear 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, 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 of medical device-related adverse events) (21 CFR 803); good

1

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.

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.

For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely,

Tara A. Ryan -S 2018.01.05 11:04:19 -05'00'

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

Indications for Use

510(k) Number (if known) K171518

Device Name

Spinal Anesthesia Needles, Epidural Anesthesia Needles, Combined Anesthesia Needles

Indications for Use (Describe)

The Epidural Anesthesia Needles are intended to be used for injection into the epidural space/or placing the enidural catheter into the epidural space.

The Spinal Anesthesia Needles are intended to be used for injection of local anesthetic agent into the subarachnoid cavity for pain management.

The Combined Anesthesia Needles are intended for injection of local anesthetics into the spinal and epidural spaces of a patient to provide regional anesthesia. The administration of the spinal anesthesia onset and the placement of an epidural catheter allows for bolus injections or continuous infusion of local anesthetics or other drugs into the epidural space.

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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3

Exhibit #2 510(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: K171518

    1. Date of Preparation: 01/02/2017
    1. Sponsor Identification

Zhejiang kindly medical devices Co., Ltd.

No.758, 5th Binhai Road, Binhai Industrial Park, Longwan District, 325025 Wenzhou, Zhejiang Province, PRC.

Establishment Registration Number: Not yet registered

Contact Person: Zenghua Zhang Position: General Manager Tel: +86-577-86872005 Fax: +86-577-86374972 Email: zhangzh@kdlchina.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

4

4. Identification of Proposed Device

Trade Name: Spinal Anesthesia Needles Epidural Anesthesia Needles Combined Anesthesia Needles Common Name: Anesthesia conduction needle

Regulatory Information

Classification Name: Anesthesia conduction needle Classification: II; Product Code: BSP; Regulation Number: 21CFR 868.5150 Review Panel: Anesthesiology

Intended Use Statement:

The Epidural Anesthesia Needles are intended to be used for injection into the epidural space/or placing the epidural catheter into the epidural space.

The Spinal Anesthesia Needles are intended to be used for injection of local anesthetic agent into the subarachnoid cavity for pain management.

The Combined Anesthesia Needles are intended for injection of local anesthetics into the spinal and epidural spaces of a patient to provide regional anesthesia. The administration of the spinal anesthesia allows rapid anesthesia onset and the placement of an epidural catheter allows for bolus injections or continuous infusion of local anesthetics or other drugs into the epidural space.

Device Description

The proposed device, Epidural Anesthesia Needles are available in a series combination of needle size and length. The needle tubing is stabilized during puncture with use of an inner stylet. The stylet is withdrawn after the epidural anesthesia needle its anatomical site for neuraxial anesthesia. Then an epidural catheter is introduced into epidural cavities for convenience of injecting anesthetic continuously.

The proposed device, Spinal Anesthesia Needles are available in a series combination of needle size and length. The spinal anesthesia needle has a tightly fitting removable stylet that completely occludes the lumen to avoid block. The stylet is withdrawn after the spinal anesthesia needle has penetrated into the subarachnoid space for injecting anesthetic. The needles are available in Sprotte and Quincke two type.

5

The proposed device, Combination Anesthesia Needle are instruments for a spinal (subarachnoid) injection of anesthetics, followed by the placement of an epidural catheter to allow modification of the spinal analgesia if necessary, or continuous infusion of local anesthetics into the epidural space for subsequent pain relief if required. The needles are a matched set. The epidural needle and the spinal needle are locked by conical fitting that enable the spinal needle to be locked into position once the dura has been pierced so that it is secured to the epidural needle to prevent accidental displacement.

  • ર. Identification of Predicate Devices
    Predicate Device 1 510(k) Number: K142553 Product Name: Uniever Disposable Epidural Anesthesia Needle

Predicate Device 2 510(k) Number: K141126 Product Name: UNIEVER Disposable Spinal Anesthesia Needle

Predicate Device 3 510(k) Number: K993619 Product Name: CSEcure™ Combined Spinal/Epidural Anesthesia System with Lock

    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 results demonstrated that the proposed device complies with the following standards:
  • A ISO 9626:1991 AMD 1:2001 Stainless Steel Needle Tubing for the Manufacture of Medical Devices.

  • A ISO 7864:1993 Sterile Hypodermic Needles for Single Use

  • ISO 594-1:1986 Conical fittings with a 6% (Luer) taper for syringes, needles and certain other medical equipment- Part 1: General requirements

  • ISO 594-2:1998 Conical fittings with 6% (Luer) taper for syringes, needles and certain other medical equipment- Part 2: Lock fittings

  • ISO 10993-7:2008 Biological evaluation of medical devices- Part 7: Ethylene oxide sterilization residuals;

  • ASTM F88/88M-09 Standard test method for seal strength of flexible barrier materials;

  • ASTM F1140/1140M-13 Standard test methods for internal pressurization failure resistance of

6

unrestrained packages

  • USP38-NF33 Bacterial Endotoxins Test

  • 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

  • ISO 10993-4: 2002/Amd 1: 2006 Biological evaluation of medical devices- Part 4: Selection of tests for interactions with blood

    1. Clinical Test Conclusion

No clinical study is included in this submission.

7

8. Substantially Equivalent (SE) Comparison

ItemProposed DevicePredicate Device 1
Product CodeBSPK142553
Regulation Number21 CFR 868.5150Same
ClassIISame
Intended UseThe Epidural Anesthesia Needles are
intended to be used for injection into
the epidural space/or placing the
epidural catheter into the epidural
space.The Uniever Disposable Epidural
Anesthesia Needle is intended to
be used for injection into the
epidural space/or placing the
epidural catheter into the epidural
space.
ConfigurationStylet Hub
Stylet
Needle Tube
Needle Hub
Needle Hub Insert
Protective Cap of NeedleStylet Hub
Stylet
Needle Tube
Needle Hub
Needle Hub Insert
Protective Cap of Needle
Needle Gauge14G~22G14G~25G
Needle Length65mm, 70mm, 80mm, 90mm,
100mm, 110mm, 120mm, 150mm30~160mm
SterileEO Sterilized
10-6Same
Single UseSingle UseSame
Needle TipTuohyHuber, Hustead and Crawford
Label/LabelingConform with 21 CFR 801Same
Biocompatibility
CytotoxicityNo CytotoxicityConform with ISO 10993
Intracutaneous ReactivityNo Intracutaneous Reactivity
Skin SensitizationNo Sensitization
Acute Systemic ToxicityNo Systemic Toxicity
HemolysisNo Hemolysis
PyrogenNo Pyrogen
ItemProposed DevicePredicate Device 2
Product CodeBSPSame
Regulation Number21 CFR 868.5150Same
ClassIISame
Intended UseThe Spinal Anesthesia Needles are
intended to be used for injection of
local anesthetic agent into the
subarachnoid cavity for pain
management.UNIEVER Disposable Spinal
Anesthesia Needle is intended to
be used for injection of local
anesthetic agent into the
subarachnoid cavity for pain
management.
ConfigurationStylet Hub
Stylet
Needle Tube
Needle Hub
Needle Hub Insert
Protective Cap of Needle
Cannula Needle TubeStylet Hub
Stylet
Needle Tube
Needle Hub
Needle Hub Insert
Protective Cap of Needle
Cannula Needle Tube
Needle Gauge18G~27G18G~29G
Needle Length40mm, 50mm, 65mm, 70mm, 80mm,
90mm, 120mm30~150mm
SterileEO Sterilized
10-6Same
Needle TipQuincke and PencileSharp and blunt
Single UseSingle UseSame
Label/LabelingConform with 21 CFR 801Same
BiocompatibilityConform with ISO 10993
CytotoxicityNo Cytotoxicity
Intracutaneous ReactivityNo Intracutaneous Reactivity
Skin SensitizationNo Sensitization
Acute Systemic ToxicityNo Systemic Toxicity
HemolysisNo Hemolysis
PyrogenNo Pyrogen

Table 1 Comparison of Technology Characteristics for Epidural Anesthesia Needles

8

Table 2 Comparison of Technology Characteristics for Spinal Anesthesia Needles

9

ItemProposed DevicePredicate Device 3
Product CodeBSPK993619
Regulation Number21 CFR 868.5150Same
ClassIISame
Intended UseThe Combined Anesthesia Needles are intended for injection of local anesthetics into the spinal and epidural spaces of a patient to provide regional anesthesia. The administration of the spinal anesthesia allows rapid anesthesia onset and the placement of an epidural catheter allows for bolus injections or continuous infusion of local anesthetics or other drugs into the epidural space.The combined spinal epidural needle kit is intended for injection of local anesthetics into the spinal and epidural spaces of a patient to provide regional anesthesia. The administration of the spinal anesthesia allows rapid anesthesia onset and the placement of an epidural catheter allows for bolus injections or continuous infusion of local anesthetics or other drugs into the epidural space.
ConfigurationStylet Hub
Stylet
Needle Tube
Needle Hub
Needle Hub Insert
Protective Cap of Needle
Cannula Needle TubeStylet Hub
Stylet
Needle Tube
Needle Hub
Needle Hub Insert
Protective Cap of Needle
Cannula Needle Tube
Needle Gauge and LengthEpidural Needle
14G~18G
60~120mm
                                                                                                                                                                                                                                                                                                                                                       | Spinal Needle

22G27G
110
150mm |
| | Epidural Needle
17G, 18G | Spinal Needle
26G, 27G
132mm |
| | 90mm | |
| Sterile | EO Sterilized
10-6 | Same |
| Single Use | Single Use | Same |
| Label/Labeling | Conform with 21 CFR 801 | Same |
| Biocompatibility | | |
| Cytotoxicity | No Cytotoxicity | Conform with ISO 10993 |
| Intracutaneous Reactivity | No Intracutaneous Reactivity | |
| Skin Sensitization | No Sensitization | |
| Acute Systemic Toxicity | No Systemic Toxicity | |
| Hemolysis | No Hemolysis | |
| Pyrogen | No Pyrogen | |

Table 3 Comparison of Technology Characteristics for Combined Anesthesia Needles

10

From above comparison table, the proposed devices have different combination of needle gauge and needle length compared with predicate devices. However, the different specification will be selected by physician per patient's condition. Therefore, this difference is not considered to affect substantially equivalence.

  • Substantially Equivalent (SE) Conclusion 9.
    Based on the comparison and analysis above, the proposed devices are determined to be Substantially Equivalent (SE) to the predicate devices.