K Number
K180843
Date Cleared
2019-04-04

(367 days)

Product Code
Regulation Number
880.5440
Reference & Predicate Devices
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

RMS High-FLO Super26™ Subcutaneous Needle Sets are indicated for subcutaneous infusion of medications in the home, hospital, or ambulatory settings when administered according to the approved biologic or drug product labeling for the capacity for infusion of high flow rates including human plasma-derived immunoglobulins when used according to the FDA approved biologic labeling for: Hizentra®, Immune Globulin Subcutaneous (Human) 20% Liquid (manufactured by CSL Behring); and Cuvitru™ Immune Globulin Infusion (Human) 20% (manufactured by Shire).

Device Description

The RMS HIgH-Flo Super26™ Subcutaneous Needle Sets are sterile, non-pyrogenic, single use, Class II Subcutaneous Administration Set, per 21 CFR 880.5440, comprised of a Super 26-gauge needle assembly, combined with 24-gauge needle tubing and are intended for the delivery of medication to the subcutaneous tissue. Each set consists of a sterile infusion set and a commercially available adhesive dressing used to hold the device in place. The infusion set is a 90-degree, 26gauge stainless steel needle, mounted to a butterfly winged safety closure on one end which is used to close the set upon completion. The other end consists of a luer lock which connects to PVC medic al grade tubing (Figure I). Additionally, each tubing set is equipped with a slide clamp used to stop flow, immediately; as needed. RMS HigH-Flo Super 26TM Subcutaneous Needle Sets are available as a single-needle set, as well as 2-needle, 4- needle, 5-needle, 6-needle sets; through use of a Y-connector, 7-needle and 8-needle sets may also be assembled. The device is for single use only.

AI/ML Overview

The provided document is a 510(k) premarket notification for a medical device (HIgH-Flo Super26™ Subcutaneous Needle Sets) and focuses on demonstrating substantial equivalence to a predicate device rather than a comprehensive study proving acceptance criteria for a new AI/software-based device.

Therefore, many of the requested details regarding acceptance criteria for a study proving device performance (e.g., sample size for test set, data provenance, number of experts, adjudication methods, MRMC studies, standalone performance, ground truth establishment) are not applicable to this document as it's primarily a regulatory submission for a physical medical device based on bench testing for an incremental design modification, not a study of an AI algorithm or a diagnostic tool requiring extensive human reader involvement or ground truth establishment in a clinical context.

However, I can extract information related to the acceptance criteria for this specific device, which are mainly focused on bench performance to demonstrate equivalence.

Here's an attempt to answer the questions based on the provided text, noting where specific questions are not applicable to this type of regulatory submission:

Acceptance Criteria and Device Performance Study (Based on 510(k) Submission)

The study described here is a bench performance study designed to demonstrate that the redesigned device (HIgH-Flo Super26™ Subcutaneous Needle Sets) is substantially equivalent to its predicate device (Integrated Catch-up Freedom Syringe Driver Infusion System) despite differences in tubing diameter and needle set configurations. The primary performance metric assessed is flow rate.

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

Given that this is a 510(k) summary for a physical device where the "acceptance criteria" are implicitly meeting functional specifications and demonstrating performance comparable to a predicate, the "acceptance criteria" are not explicitly stated with numerical thresholds in the same way they would be for an AI algorithm's performance metrics (e.g., sensitivity > X%, specificity > Y%). Instead, the "conclusion" is that the device "performs as intended and is substantially equivalent to the predicate device" based on bench testing.

The reported device performance presented is the achievable flow rates under various conditions (different fluid types, number of needles, and pump settings). The tables themselves represent the performance data that presumably met the implicit acceptance criteria of demonstrating comparable or improved flow for the intended use.

Implicit Acceptance Criteria (derived from context):

  • Biocompatibility: Device materials must meet ISO 10993 standards and be non-hemolytic.
  • Flow Rate: The device must achieve flow rates suitable for the intended subcutaneous infusion of specified medications (Hizentra, Cuvitru) across various needle configurations and pump settings, and ideally meet or exceed drug manufacturer's recommended flow rates. The stated purpose of the design modification was to allow for "high flow rates."
  • Sterility, non-pyrogenicity, single-use, safety features: These are standard performance and design criteria for such devices.

Reported Device Performance:

The document provides tables of "Achievable Flow Rates with Super26™ and Specific Medications/Indications." These tables are the reported performance data. For brevity, only a summary of insights from these tables is provided here, rather than reproducing them entirely:

Performance Aspect / CriteriaReported Device Performance (HIgH-Flo Super26™)
BiocompatibilityMeets ISO 10993 requirements. Modified ASTM Hemolysis test showed 0.68% difference in hemolytic index, placing it in a non-hemolytic range. (Based on identical materials and manufacturing to predicate).
Hizentra - Max Flow Rate Per Site (ml/hr/site) (Example rows)Varied by needle count and pump setting. Examples (F275 pump setting):- 1 needle: 19.5 ml/hr/site- 4 needles: 5.8 ml/hr/site- 8 needles: 3.0 ml/hr/siteSome combinations "Exceeds drug manufacturer's maximum indicated flow rate."
Hizentra® CIDP - Max Flow Rate Per Site (ml/hr/site) (Example rows)Varied by needle count and pump setting. Examples (F275 pump setting):- 1 needle: 19.5 ml/hr/site- 4 needles: 5.8 ml/hr/site- 8 needles: 3.0 ml/hr/siteSome combinations "Exceeds drug manufacturer's maximum indicated flow rate."
Cuvitru™ PI - Max Flow Rate Per Site (ml/hr/site) (Example rows)Varied by needle count and pump setting. Examples (F275 pump setting):- 1 needle: 19.1 ml/hr/site- 4 needles: 5.7 ml/hr/siteSome combinations "Exceeds drug manufacturer's maximum indicated flow rate."*Some combinations were "Flow rate per site is lower than what is recommended on the biologic label" (e.g., 1-4 needles at lower F-settings).

Note on "Acceptance Criteria" for this submission: The document states, "Bench testing has been conducted to verify that the product performance of the subject device and predicate device are substantially equivalent." The tables of flow rates are the data used to demonstrate this equivalence, implicitly meeting the "acceptance criteria" that the new design performs effectively for its intended use.

2. Sample size used for the test set and the data provenance

  • Sample Size: Not specified in terms of number of devices tested for flow rates. The text only mentions "Bench Performance Studies" and "Flow Rate Testing." Typical bench testing involves a statistically significant number of samples, but the exact count isn't in this summary.
  • Data Provenance: The data is generated from bench testing conducted by the manufacturer, Repro-Med Systems, Inc. dba RMS Medical Products. It is not clinical data from patients.
  • Retrospective or Prospective: N/A. This is bench testing, not a clinical study.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

  • N/A. This is a physical device (subcutaneous needle set) and the "ground truth" for flow rate performance is established through repeatable physical measurements using laboratory equipment (e.g., pumps, timers, volume measurements), not by expert human interpretation of images or other clinical data.

4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

  • N/A. See point 3.

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

  • N/A. This is not an AI/diagnostic device.

6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done

  • N/A. This is not an AI/diagnostic device.

7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

  • The "ground truth" for the performance (flow rate) is established via direct physical measurement during bench testing. For biocompatibility, it's based on laboratory test results (ISO 10993 series standards, Modified ASTM Hemolysis).

8. The sample size for the training set

  • N/A. This is not an AI/machine learning device that requires a training set. The device is a physical product for which performance is verified through engineering bench tests.

9. How the ground truth for the training set was established

  • N/A. See point 8.

In summary: The provided document is a 510(k) premarket notification for a physical medical device, not an AI or software-based medical device. Therefore, many of the questions related to AI study design, expert ground truth, and human reader studies are not applicable. The "study" proving the device meets acceptance criteria is primarily bench testing to demonstrate functional equivalency, particularly concerning flow rates and biocompatibility, compared to a legally marketed predicate device.

{0}------------------------------------------------

Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

April 4, 2019

Repro-Med Systems, Inc. dba RMS Medical Products Cynthia Lacatena Senior Regulatory Associate 24 Carpenter Road Chester, New York 10918

Re: K180843

Trade/Device Name: HIgH-Flo Super26 Subcutaneous Needle Sets Regulation Number: 21 CFR 880.5440 Regulation Name: Intravascular administration set Regulatory Class: Class II Product Code: FPA Dated: February 28, 2019 Received: March 4, 2019

Dear Cynthia Lacatena:

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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, 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

{1}------------------------------------------------

801); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.html; good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, fi 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 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.

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) K180843

Device Name

HIgH-Flo Super26TM Subcutaneous Needle Sets

Indications for Use (Describe)

RMS High-FLO Super26™ Subcutaneous Needle Sets are indicated for subcutaneous infusion of medications in the home, hospital, or ambulatory settings when administered according to the approved biologic or drug product labeling for the capacity for infusion of high flow rates including human plasma-derived immunoglobulins when used according to the FDA approved biologic labeling for: Hizentra®, Immune Globulin Subcutaneous (Human) 20% Liquid (manufactured by CSL Behring); and Cuvitru™ Immune Globulin Infusion (Human) 20% (manufactured by Shire).

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)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

{3}------------------------------------------------

Submitted By: Harry Shaffer Director, Regulatory and Quality Affairs Repro Med System, Inc., D/B/A RMS Medical Products 24 Carpenter Road Chester, NY 10918 Tel: 845-469-2042 Fax: 845-469-5518

Summary Prepared: April 2, 2019

  • RMS HIgH-Flo Super26TM Subcutaneous Needle Set Device Name: Trade Name: Common Name: Intravascular Administration Set Classification: Class II device, 21 CFR §880.5440 Product Code: FPA
    Legally marketed predicate device to which substantial equivalence is claimed: (K162613) Integrated Catch-up Freedom Syringe Driver Infusion System

Device Description:

The RMS HIgH-Flo Super26™ Subcutaneous Needle Sets are sterile, non-pyrogenic, single use, Class II Subcutaneous Administration Set, per 21 CFR 880.5440, comprised of a Super 26-gauge needle assembly, combined with 24-gauge needle tubing and are intended for the delivery of medication to the subcutaneous tissue. Each set consists of a sterile infusion set and a commercially available adhesive dressing used to hold the device in place. The infusion set is a 90-degree, 26gauge stainless steel needle, mounted to a butterfly winged safety closure on one end which is used to close the set upon completion. The other end consists of a luer lock which connects to PVC medic al grade tubing (Figure I). Additionally, each tubing set is equipped with a slide clamp used to stop flow, immediately; as needed. RMS HigH-Flo Super 26TM Subcutaneous Needle Sets are available as a single-needle set, as well as 2-needle, 4- needle, 5-needle, 6-needle sets; through use of a Y-connector, 7-needle and 8-needle sets may also be assembled. The device is for single use only.

Image /page/3/Picture/7 description: The image shows a medical device with a white connector on the left side and a clear adhesive patch in the center. The device has thin wires that connect the connector to the patch. There is also a white clip on the right side of the device, which is attached to the wires.

Figure I

{4}------------------------------------------------

Indications for Use:

RMS High-FLO Super26™ Subcutaneous Needle Sets are indicated for subcutaneous infusion of medications in the home, hospital, or ambulatory settings, when administered according to the approved biologic or drug product labeling for the capacity for infusion of high flow rates including human plasma-derived immunoglobulins when used according to the FDA approved biologic labeling ; for: Hizentra®, Immune Globulin Subcutaneous (Human) 20% Liquid (manufactured by CSL Behring); and Cuvitru™ Immune Globulin Infusion (Human) 20% (manufactured by Shire).

Comparison to Predicate Device:

The subject device utilizes the same fundamental scientific technology as the predicate device. The purpose for this submission is to introduce a design modification/combination of the needle gauge and tubing diameter. Bench testing has been conducted to verify that the product performance of the subject device and predicate device are substantially equivalent. The table below gives a comparison of both devices.

FeatureSubject Device:HlgH-FloSuper26™ Sub-Q Needle SetsPredicate Device:Integrated Freedom Syringe Driver Infusion System
510(k) NumberK180843K162613
ManufacturerSame as PredicateRepro Med Systems, Inc.,dba RMS Medical Products
Product CodeSame as PredicateFPA
Regulation NumberSame as Predicate880.5440
Regulation NameSame as PredicateIntravascular Administration Set
Intended UseRMS High-FLO Super26™Subcutaneous Needle Sets areindicated for subcutaneous infusionof medications in the home,hospital, or ambulatory settingswhen administered according to theapproved biologic or drug productlabeling for the capacity forinfusion of high flow ratesincluding human plasma-derivedimmunoglobulins when usedaccording to the FDA approvedbiologic labeling for: Hizentra®,Immune Globulin Subcutaneous(Human) 20% Liquid(manufactured by CSL Behring);and Cuvitru™ Immune GlobulinInfusion (Human) 20%(manufactured by Shire).The Integrated Catch-Up FreedomSyringe Driver Infusion System(ICFSDIS), which includes theFREEDOM60® and FreedomEdge®syringe pumps, is indicated for theintravenous or subcutaneous infusionof medications and fluids in the home,hospital, or ambulatory settings whenadministered according to the approvedbiologic or drug product labeling. TheICFSDIS is specifically indicated forthe subcutaneous infusion of thefollowing human plasma-derivedimmunoglobulins when used accordingto the FDA approved biologic labeling:Hizentra, Immune GlobulinSubcutaneous (Human) 20% Liquid(manufactured by CSL Behring);Gammagard Liquid, Immune GlobulinInfusion (Human) 10% (manufacturedby Shire); and Cuvitru ImmuneGlobulin Infusion (Human) 20%(manufactured by Shire). The ICFSDISis specifically indicated for theintravenous infusion of the following

{5}------------------------------------------------

antibiotics when used according to theFDA approved drug product labeling:meropenem, ertapenem, oxacillin, andtobramycin.
System componentsSyringe Infusion System plus Needle Set
Needle Insertion MethodManual
Angle of Insertion90 degrees
Needle MaterialStainless Steel
Needle Gauge26
Needle Length (mm)4, 6, 9, 12, 14
Needle UsageSingle Use
Needle Set ConfigurationsAvailable as a single-needle set, as well as 2-needle, 3-needle, 4- needle sets; through use of a Y-connector, 7-needle and 8-needle sets may also be assembled.
Needle Safety FeatureYes
Tubing Length (inches)20
Tubing Diameter (inches)0.019
Tubing MaterialMedical Grade PVC Plastic
Tubing Connection TypeLuer Tip
Provided SterileYes
Sterilization MethodGamma SAL 10-6
Shelf Life3 years
PackagingSterile Tubing and Needle Set
Indications for UseDelivery of medication to the subcutaneous tissue

Discussion of differences:

Tubing Diameter: the diameter of the tubing used in the subject device (HlgH-FloSuper26™ Sub-Q Needle Sets) with 26G needles is 0.033 inches, which is different from the predicate's 0.019 inches.

Needle Set Configurations: The subject device contains 5 and 6 needle sets used without the Y connector. These configurations are not available in the predicate.

{6}------------------------------------------------

These differences do not raise different questions of safety and effectiveness as compared to the predicate. Also, performance testing has been conducted to ensure these differences do not impact device safety and effectiveness and demonstrate the device performs as intended.

Biocompatibility Studies:

Biocompatibility testing had been conducted on the predicate device in accordance with ISO 10993 series standards. This testing included Modified ASTM Hemolysis (Direct Contact Method) testing was conducted, concluding that the difference between the hemolytic indexes of the test article, RMS Subcutaneous Needle Sets: 8-Needle Set Configuration [(2) 4-Needle Set Configuration connected via (1) RMS Y-Connector] and the negative control was 0.68 percent. This places the test article in a non-hemolytic range. The subject device and predicate device are manufactured utilizing identical materials and composition. Based on the identical materials and manufacturing processes between the predicate and subject device. RMS concludes that the performance test data on the predicate device demonstrates that HlgH-Flo Super26™ Subcutaneous Needle Set meets the biocompatibility requirements of ISO 10993.

Bench Performance Studies Included The Following Test Methods:

The subject device has the same technological characteristics as the predicate device which was cleared under K162613. The verification testing was limited to the following tests.

Flow Rate Testing:

Achievable Flow Rates with Super26™ and Specific Medications/Indications

NOTE: The tables below indicate the estimated maximum achievable flow rates with RMS HIgH-Flo Super26™ Subcutaneous Needle Sets when used in combination with RMS Precision Flow Rate TubingTM and RMS Freedom Syringe Drivers.

Hizentra - FI With Super 20 - Max Flow Rate Per Site (ml/hr/site)
F45F60F120F180F275F420F500F600F900F1200F2400
1 needle4.55.810.613.419.5
2 needles2.33.05.67.210.917.017.320.9
3 needles1.52.03.84.97.612.112.315.120.8
4 needles1.21.52.93.75.89.49.511.816.522.5
5 needles0.91.22.33.04.77.67.89.613.718.9
6 needles0.81.01.92.53.96.56.68.211.716.3
7 needles0.70.91.72.23.45.65.77.110.214.3
8 needles0.60.81.51.93.04.95.06.39.112.823.5

Exceeds drug manufacturer's maximum indicated flow rate.

Subsequent infusions after 1st infusion only.

{7}------------------------------------------------

Hizentra® CIDP with Super26™ - Max Flow Rate Per Site (ml/hr/site)
F45F60F120F180F275F420F500F600F900F1200F2400
1 needle4.55.810.613.419.528.929.334.343.4
2 needles2.33.05.67.210.917.017.320.928.236.4
3 needles1.52.03.84.97.612.112.315.120.827.844.3
4 needles1.21.52.93.75.89.49.511.816.522.537.6
5 needles0.91.22.33.04.77.67.89.613.718.932.7
6 needles0.81.01.92.53.96.56.68.211.716.328.9
7 needles0.70.91.72.23.45.65.77.110.214.325.9
8 needles0.60.81.51.93.04.95.06.39.112.823.5

.............................................................................................................................................................................. Site (ml/br/cito) OGTM NA

Exceeds drug manufacturer's maximum indicated flow rate.

Subsequent infusions after 1st infusion only.

Cuvitru™ Pl with Super26™ - Max Flow Rate Per Site (ml/hr/site)

F45F60F120F180F275F420F500F600F900F1200F2400
1 needle4.4*5.7*10.313.119.128.328.733.642.551.5
2 needles2.2*2.9*5.5*7.1*10.716.717.020.527.635.652.8
3 needles1.5*2.0*3.7*4.8*7.4*11.812.014.820.427.243.4
4 needles1.1*1.5*2.8*3.7*5.7*9.2*9.3*11.516.222.036.9

Exceeds drug manufacturer's maximum indicated flow rate. Subsequent infusions after 1st two infusions only.

*Flow rate per site is lower then what is recommended on the biologic labe NOTE: Drug manufacturer indicates maximum of up to four infusion sites

Conclusion:

The device performs as intended and is substantially equivalent to the predicate device.

§ 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.