AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The Blood Collecting Needle is intended to be used with vacuum blood collection tube for multiple collections of venous blood.

The Safety Blood Collecting Needle is intended to be used with vacuum blood collection tube for multiple collections of venous blood. The safety shield is intended to aid in the protection against accidental needle stick injury.

The Blood Collecting Needle with Holder is intended to be used with vacuum blood collection tube for multiple collections of venous blood.

The Safety Blood Collecting Needle with Holder is intended to be used with vacuum blood collection tube for multiple collections of venous blood. The safety shield is intended to aid in the protection against accidental needle stick injury.

The Blood Collecting Set is intended to be used with vacuum blood collection tube for multiple collections of venous blood.

The Safety Blood Collecting Set is intended to be used with vacuum blood collection of venous blood. The safety shield is intended to aid in the protection against accidental needle stick injury.

The Blood Collecting Set with Holder is intended to be used with vacuum blood collection tube for multiple collections of venous blood.

The Safety Blood Collecting Set with Holder is intended to be used with vacuum blood collection tube for multiple collections of venous blood. The safety shield is intended to aid in the protection against accidental needle stick injury.

Device Description

The proposed devices are blood collection devices form a channel between patient's vein and the vacuum blood collection tube. The patient-end needle is punctured into vein, and non-patient end needle will penetrate into vacuum blood collection tube, blood will flow into blood collection tube under the action of differential pressure. The proposed devices are divided into several types and available in different specifications.

AI/ML Overview

The provided document is a 510(k) Pre-market Notification from the FDA for blood collection needles and sets. It describes non-clinical testing performed to establish substantial equivalence to predicate devices, but it does not contain information about studies involving human or expert evaluation of AI/algorithm performance, which is what your request is focused on. Therefore, I cannot provide details on the requested criteria related to AI/algorithm acceptance criteria, ground truth, expert involvement, or MRMC studies.

However, I can extract the acceptance criteria and performance related to the non-clinical tests performed on the physical device.

Here's the relevant information based on the non-clinical tests described in the document:

1. A table of acceptance criteria and the reported device performance

Acceptance Criteria (Standard / Clause)Device Performance
Physical, Mechanical, Chemical Testing (ISO 7864:2016)
Cleanliness (Clause 4.3)Met design specifications
Limits for acidity or alkalinity (Clause 4.4)Met design specifications
Limits for extractable metals (Clause 4.5)Met design specifications
Size designation (Clause 4.6)Met design specifications
Colour coding (Clause 4.7)Met design specifications
Needle hub (Clause 4.8)Met design specifications
Needle Cap (Clause 4.9)Met design specifications
Needle tube (Clause 4.10)Met design specifications
Needle point (Clause 4.11)Met design specifications
Bond between hub and needle tube (Clause 4.12)Met design specifications
Patency of lumen (Clause 4.13)Met design specifications
Physical, Mechanical, Chemical Testing (ISO 9626:2016)
Surface finish (Clause 5.2)Met design specifications
Cleanliness (Clause 5.3)Met design specifications
Limits for acidity and alkalinity (Clause 5.4)Met design specifications
Size designation (Clause 5.5)Met design specifications
Dimensions (Clause 5.6)Met design specifications
Stiffness (Clause 5.8)Met design specifications
Resistance to breakage (Clause 5.9)Met design specifications
Resistance to corrosion (Clause 5.10)Met design specifications
Sterile Barrier Packaging Testing
Seal strength (ASTM F88/F88-15)Met design specifications
Dye penetration (ASTM F1929-15)Met design specifications
Sterilization and Shelf Life Testing
EO residue (ISO 10993-7:2008)Met design specifications
ECH residue (ISO 10993-7:2008)Met design specifications
Bacteria Endotoxin Limit (USP 38-NF 33 <85>)Met design specifications
Shelf Life Evaluation (Physical, Mechanical, Chemical, Package Tests on aging samples)Verified claimed shelf life
Biocompatibility Testing
In vitro cytotoxicity (ISO 10993-5)Met design specifications
Skin sensitization (ISO 10993-10)Met design specifications
Irritation sensitivity (ISO 10993-10)Met design specifications
Acute Toxicity Test (ISO 10993-11)Met design specifications
Pyrogen test (ISO 10993-11)Met design specifications
Hemolysis Test (ASTM F756-17)Met design specifications
Simulated Clinical Study (FDA Guidance, 2005)
Safety mechanism evaluationMet pre-established criteria
Safety Feature Test
Comparison to predicate devicesDid not show a significant difference from predicate devices

2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
The document does not specify the sample sizes or data provenance (country of origin, retrospective/prospective) for the non-clinical tests. It only states that tests were "performed on the proposed device" and "on aging samples."

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)
Not applicable. This document describes non-clinical testing of a physical medical device (blood collection needles/sets), not an AI/algorithm. No experts were mentioned for establishing ground truth for a test set in the context of AI evaluation.

4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable. This document is not about AI/algorithm evaluation.

5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
Not applicable. This document is not about AI/algorithm performance or MRMC studies.

6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. This document is not about an AI/algorithm.

7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
For the non-clinical tests, the "ground truth" refers to the established standards and specifications outlined in the referenced ISO, ASTM, and USP documents, as well as the company's own design specifications. For the simulated clinical study, "pre-established criteria" defined the success of the safety mechanism.

8. The sample size for the training set
Not applicable. This document is not about an AI/algorithm and therefore has no "training set."

9. How the ground truth for the training set was established
Not applicable. This document is not about an AI/algorithm and therefore has no "training set."

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Image /page/0/Picture/0 description: The image contains 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 in blue and includes the letters "FDA" in a square and the words "U.S. Food & Drug Administration".

August 26, 2020

Zhejiang Kindly Medical Devices Co.,Ltd % Diana Hong General Manager Mid-Link Consulting Co.,Ltd P.O.Box 120-119 Shanghai, Zhejiang 325025 China

Re: K172763

Trade/Device Name: Blood Collecting Needle, Safety Blood Collecting Needle, Blood Collecting Needle with Holder, Safety Blood Collecting Needle with Holder, Blood Collecting Set, Safety Blood Collecting Set, Blood Collecting Set with Holder, Safety Blood Collecting Set with Holder Regulation Number: 21 CFR 862.1675 Regulation Name: Blood specimen collection device Regulatory Class: Class II Product Code: JKA

Dear Diana Hong:

The Food and Drug Administration (FDA) is sending this letter to notify you of an administrative change related to your previous substantial equivalence (SE) determination letter dated June 4, 2018. Specifically, FDA is updating this SE Letter to update the product code to better categorize your device technology.

Please note that the 510(k) submission was not re-reviewed. For questions regarding this letter please contact Vacant, OHT3: Office of Gastrorenal, ObGyn, General Hospital and Urology Devices, Paval Patel, (240) 402-6029, payal.patel(@fda.hhs.gov.

Sincerely,

Sapana Patel -S

for Payal Patel Acting Assistant Director DHT3C: Division of Drug Delivery and General Hospital Devices, and Human Factors OHT3: Office of Gastrorenal, ObGyn, General Hospital and Urology Devices

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Office of Product Evaluation and Quality Center for Devices and Radiological Health

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Image /page/2/Picture/0 description: The image contains the logos of the U.S. Department of Health & Human Services and the U.S. Food & Drug Administration (FDA). The Department of Health & Human Services logo is on the left, and the FDA logo is on the right. The FDA logo is a blue square with the letters "FDA" in white, followed by the words "U.S. FOOD & DRUG" in blue and "ADMINISTRATION" in a smaller font size.

June 4, 2018

Zhejiang kindly medical devices Co., Ltd % Diana Hong Mid-Link Consulting Co., Ltd P.O. Box 120-119 Shanghai. 200120 CHINA

Re: K172763

Trade/Device Name: Blood Collecting Needle, Safety Blood Collecting Needle, Blood Collecting Needle with Holder, Safety Blood Collecting Needle with Holder, Blood Collecting Set, Safety Blood Collecting Set, Blood Collecting Set with Holder, Safety Blood Collecting Set with Holder

Regulation Number: 21 CFR 880.5570 Regulation Name: Hypodermic Single Lumen Needle Regulatory Class: Class II Product Code: FMI Dated: April 28, 2018 Received: May 4, 2018

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.

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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 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.

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 mediation-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, 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) K172763

Device Name

Blood Collecting Needle, Safety Blood Collecting Needle, With Holder, Safety Blood Collecting Needle with Holder, Blood Collecting Set, Safety Blood Collecting Set with Holder, Safety Blood Collecting Set with Holder

Indications for Use (Describe)

The Blood Collecting Needle is intended to be used with vacuum blood collection tube for multiple collections of venous blood.

The Safety Blood Collecting Needle is intended to be used with vacuum blood collection tube for multiple collections of venous blood. The safety shield is intended to aid in the protection against accidental needle stick injury.

The Blood Collecting Needle with Holder is intended to be used with vacuum blood collection tube for multiple collections of venous blood.

The Safety Blood Collecting Needle with Holder is intended to be used with vacuum blood collection tube for multiple collections of venous blood. The safety shield is intended to aid in the protection against accidental needle stick injury.

The Blood Collecting Set is intended to be used with vacuum blood collection tube for multiple collections of venous blood.

The Safety Blood Collecting Set is intended to be used with vacuum blood collection of venous blood. The safety shield is intended to aid in the protection against accidental needle stick injury.

The Blood Collecting Set with Holder is intended to be used with vacuum blood collection tube for multiple collections of venous blood.

The Safety Blood Collecting Set with Holder is intended to be used with vacuum blood collection tube for multiple collections of venous blood. The safety shield is intended to aid in the protection against accidental needle stick injury.

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

☑ Requisition Use (Part 21 CFR 601 Subpart D)☐ Over-The-Counter Use (21 CFR 601 Subpart G)
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Prescription Use (Part 21 CFR 801 Subpart D)

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

CONTINUE ON A SEPARATE PAGE IF NEEDED.

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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: K172763

    1. Date of Preparation: 04/28/2018
    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: Yong Zhang Position: General Manager Tel: +86-577-86960616 Fax: +86-577-86374972 Email: zjkdl@kdlchina.com

  • Designated Submission Correspondent 3.
    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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K172763

Identification of Proposed Device 4.

Trade Name: Blood Collecting Needle

  • Safety Blood Collecting Needle Blood Collecting Needle with Holder Safety Blood Collecting Needle with Holder Blood Collecting Set Safety Blood Collecting Set Blood Collecting Set with Holder Safety Blood Collecting Set with Holder
    Common Name: Blood Collecting Needle and Set

Regulatory Information

Classification Name: Needle, Hypodermic, Single Lumen Classification: II; Product Code: FMI: Regulation Number: 21 CFR 880.5570 Review Panel: General Hospital;

Indications for Use:

The Blood Collecting Needle is intended to be used with vacuum blood collection tube for multiple collections of venous blood.

The Safety Blood Collecting Needle is intended to be used with vacuum blood collection tube for multiple collections of venous blood. The safety shield is intended to aid in the protection against accidental needle stick injury.

The Blood Collecting Needle with Holder is intended to be used with vacuum blood collection tube for multiple collections of venous blood.

The Safety Blood Collecting Needle with Holder is intended to be used with vacuum blood collection tube for multiple collections of venous blood. The safety shield is intended to aid in the protection against accidental needle stick injury.

The Blood Collecting Set is intended to be used with vacuum blood collection tube for multiple collections of venous blood.

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The Safety Blood Collecting Set is intended to be used with vacuumblood collection tube for multiple collections of venous blood. The safety shield is intended to aid in the protection against accidental needle stick injury.

The Blood Collecting Set with Holder is intended to be used with vacuum blood collection tube for multiple collections of venous blood.

The Safety Blood Collecting Set with Holder is intended to be used with vacuum blood collection tube for multiple collections of venous blood. The safety shield is intended to aid in the protection against accidental needle stick injury.

Device Description

The proposed devices are blood collection devices form a channel between patient's vein and the vacuum blood collection tube. The patient-end needle is punctured into vein, and non-patient end needle will penetrate into vacuum blood collection tube, blood will flow into blood collection tube under the action of differential pressure. The proposed devices are divided into several types and available in different specifications, see following table

Device NameRef No.NeedleGaugeNeedle Length
Blood Collecting Needle04-1118G~23G1", 1 1/4", 1 1/2"
Blood Collecting Needle04-1318G~23G1", 1 1/4", 1 1/2"
Blood Collecting Needle04-3119G, 25G5/8", 3/4", 1", 1 1/4", 1 1/2", 1 3/4", 2"
Safety Blood Collecting Needle04-1218G~23G1", 1 1/4", 1 1/2"
Safety Blood Collecting Needle04-3219G, 25G5/8", 3/4", 1", 1 1/4", 1 1/2", 1 3/4", 2"
Blood Collecting Needle with Holder04-1418G~23G1", 1 1/4", 1 1/2"
Blood Collecting Needle with Holder04-1618G~23G1", 1 1/4", 1 1/2"
Blood Collecting Needle with Holder04-3319G, 25G5/8", 3/4", 1", 1 1/4", 1 1/2", 1 3/4", 2"
Safety Blood Collecting Needle with Holder04-1518G~23G1", 1 1/4", 1 1/2"
Safety Blood Collecting Needle with Holder04-3419G, 25G5/8", 3/4", 1", 1 1/4", 1 1/2", 1 3/4", 2"
Blood Collecting Set04-2119G, 25G5/8", 3/4", 1"
Safety Blood Collecting Set04-2219G, 25G5/8", 3/4", 1"
Blood Collecting Set with Holder04-2319G, 25G5/8", 3/4", 1"
Safety Blood Collecting Set with Holder04-2419G, 25G5/8", 3/4", 1"

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5. Identification of Predicate Devices

Predicate Device 1 510(k) Number: K982541 Product Name: VACUTAINER® Brand ECLIPSE™ Blood Collection Needle

Predicate Device 2 510(k) Number: K965202 Product Name: VACUTAINER® Brand Safety-Lok Blood Collection Set

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6. Technological Characteristics

ITEMProposed DevicePredicate Device 1Predicate Device 2
K982541K965202
ClassIIIIII
Indications for UseThe Blood Collecting Needle is intended to be used with vacuum blood collection tube for multiple collections of venous blood.The Safety Blood Collecting Needle is intended to be used with vacuum blood collection tube for multiple collections of venous blood. The safety shield is intended to aid in the protection against accidental needle stick injury.The Blood Collecting Needle with Holder is intended to be used with vacuum blood collection tube for multiple collections of venous blood. The Safety Blood Collecting Needle with Holder is intended to be used with vacuum blood collection tube for multiple collections of venous blood. The safety shield is intended to aid in the protection against accidental needle stick injury.The Blood Collecting Set is intended to be used with vacuum blood collection tube for multiple collections of venous blood. The Safety Blood Collecting Set is intended to be used with vacuum blood collection tube for multiple collections of venous blood. The safetyThe VACUTAINER® Brand ECLIPSETM Blood Collection Needle is a sterile, multiple sample, single-use device for blood collection. The needle is designed with an attached safety shield, which can be activated to cover the needle immediately after venipuncture to provide protection from accidental needle sticks.The VACUTAINER® Brand Safety-Lok™ Blood Collection Set is a winged blood collection needle and flexible tubing for venipuncture to collect blood specimens from patients. The Safety-Lok™ Blood Collection Set also contains a needle safety shield which minimizes the possibility of needlesticks if manually activated following blood collection. The VACUTAINER® Brand Safety-Lok™ Blood Collection Set is also recommended for use in patients with small veins
shield is intended to aid in the protection againstaccidental needle stick injury.
The Blood Collecting Set with Holder is intendedto be used with vacuum blood collection tube formultiple collections of venous blood.
The Safety Blood Collecting Set with Holder isintended to be used with vacuum blood collectiontube for multiple collections of venous blood.
The safety shield is intended to aid in theprotection against accidental needle stick injury.
Configurationand materialPatient-end Needle (Stainless Steel)Protective Cover of NeedleProtective Cover of Patient-end Needle
Protective Cover of Patient-end Needle (PP)NeedlePatient-end Needle
Patient-end Needle Hub (PP)Needle HubNeedle Handle
Non-patient end Needle Hub (ABS)Rubber SleeveDouble Wing
Non-patient end Needle (Stainless Steel)Safety ShieldFlexible Tube
Rubber Sleeve (Natural Rubber)Conical Fitting Connector
Protective Cover of Non-patient end Needle (PP)Conical Fitting
Double Wing (PVC)Non-patient end Needle
Flexible Tube (PVC)Rubber Sleeve
Conical Fitting Connector (ABS)Protective Cover of Non Patient endNeedle
Conical Fitting (ABS)Safety Shield
Safety Shield (PP)
Needle Holder (PP)
Operate modeManualSameSame
Specification18G, 19G, 20G, 21G, 22G, 23G, 25GSimilarSimilar
5/8", 3/4", 1", 1 1/4", 1 1/2", 1 3/4", 2"
SafetyMechanismThe safety shield is intended to prevent needlesticksSameSame

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K172763
Label/LabelingConform with Part 801SameSame
SterilizationEO sterilizedSAL: $10^{-6}$Endotoxin Limit: 20 EU per deviceSameSame
Single UseSingle UseSameSame
BiocompatibilityIn Vitro CytotoxicityConform with ISO 10993 StandardsConform with ISO 10993 Standard
Skin Sensitization
Intracutaneous Reactivity
Acute Systemic Toxicity
Hemolytic Properties
Pyrogen

The proposed devices Blood Collecting Needle, Blood Collecting Needle with Holder, Safety Blood Collecting Neede with Holder are similar to the predicate device design, Indications for use, sterilization, method of operation and technological characteristics. The proposed devices Blood Collecting Set, Blood Collecting Set with Holder, Safety Blood Collecting Set with Holder are similar to the predicate device design, Indications for use, sterilization, method of operation and technological characteristics. The difference in configuration between proposed devices is that the proposed devices have the additional configuration of the needle holder. In addition the proposed devices are available in a series of specification will be selected by physician per patients' condition. These two differ intended use, therefore, the proposed devices can be determined substantially equivalence to predicate devices.

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7. Non-Clinical Test Conclusion

Non clinical tests were conducted to verify that the proposed devices met all design specifications. The test include following items

Physical, Mechanical, Chemical testing performed on the proposed device:

CleanlinessClause 4.3 of ISO 7864:2016
Limits for acidity or alkalinityClause 4.4 of ISO 7864:2016
Limits for extractable metalsClause 4.5 of ISO 7864:2016
Size designationClause 4.6 of ISO 7864:2016
Colour codingClause 4.7 of ISO 7864:2016
Needle hubClause 4.8 of ISO 7864:2016
Needle CapClause 4.9 of ISO 7864:2016
Needle tubeClause 4.10 of ISO 7864:2016
Needle pointClause 4.11 of ISO 7864:2016
Bond between hub and needle tubeClause 4.12 of ISO 7864:2016
Patency of lumenClause 4.13 of ISO 7864:2016
Surface finishClause 5.2 of ISO 9626:2016
CleanlinessClause 5.3 of ISO 9626:2016
Limits for acidity and alkalinityClause 5.4 of ISO 9626:2016
Size designationClause 5.5 of ISO 9626:2016
DimensionsClause 5.6 of ISO 9626:2016
StiffnessClause 5.8 of ISO 9626:2016
Resistance to breakageClause 5.9 of ISO 9626:2016
Resistance to corrosionClause 5.10 of ISO 9626:2016

Sterile Barrier Packaging Testing performed on the proposed device:

Seal strengthASTM F88/F88-15
Dye penetrationASTM F1929-15

Sterilization and Shelf Life Testing performed on the proposed device:

EO residueISO 10993-7:2008
ECH residueISO 10993-7:2008
Bacteria Endotoxin LimitUSP 38-NF 33 <85>
Shelf Life EvaluationPhysical, Mechanical, Chemical, Package Tests

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were performed on aging samples to verify the claimed shelf life of the device

Biocompatibility testing include in vitro cytotoxicity test (ISO 10993-5), skin sensitization test (ISO 10993-10), irritation sensitivity (ISO 10993-10), Acute Toxicity Test (ISO 10993-11), pyrogen test (ISO 10993-11) and Hemolysis Test (ASTM F756-17).

Simulated Clinical Study

A simulated clinical study was performed on proposed device according to FDA 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 devices. 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 safety feature. The results demonstrated that the proposed devices did not show a significant difference from predicate devices.

    1. Clinical Test Conclusion
      No clinical study is included in this submission.

9. Substantially Equivalent (SE) Conclusion

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

§ 862.1675 Blood specimen collection device.

(a)
Identification. A blood specimen collection device is a device intended for medical purposes to collect and to handle blood specimens and to separate serum from nonserum (cellular) components prior to further testing. This generic type device may include blood collection tubes, vials, systems, serum separators, blood collection trays, or vacuum sample tubes.(b)
Classification. Class II.