K Number
K182146
Device Name
Sol-M Blood Collection Needles, Sol-Care Safety Blood Collection Needles, Sol-Care Safety Blood Collection Needle with Holders, Sol-M Blood Collection Set
Date Cleared
2018-12-03

(117 days)

Product Code
Regulation Number
880.5570
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Sol-M Blood Collection Needle is intended to be used with vacuum blood collection tube for the collection of venous blood. The Sol-Care Safety Blood Collection Needle is intended to be used with vacuum blood collection tube for the collection of venous blood. The safety shield is intended to aid in the protection against accidental needle stick injury. The Sol-Care Safety Blood Collection Needle with Holder is intended to be used with vacuum blood collection tube for the collection of venous blood. The safety shield is intended to aid in the protection against accidental needle stick injury. The Sol-M Blood Collecting Set is intended to be used with vacuum blood collection tube for the collection of venous blood.
Device Description
The proposed devices are blood collection devices form a channel between patient's vein and the vacuum blood collection tube intended for collection of blood. The proposed devices are divided into several types, the configuration for each type of proposed device are provided as follows: Blood Collection Needle – one piece, Blood Collection Needle – Direct, Blood Collection Needle – Multi piece, Safety Blood Collection Needle – Direct, Safety Blood Collection Needle – Multi piece, Safety Blood Collection Needle w/Holder – One piece, Safety Blood Collection Needle w/Holder - Direct. In addition, the proposed devices are divided into several types and available in different specifications.
More Information

Not Found

No
The device description and performance studies focus on the physical characteristics and safety features of blood collection needles, with no mention of AI or ML.

No
The device is described as a blood collection device for collecting venous blood, which is a diagnostic procedure, not a therapeutic one.

No
The device is a blood collection needle, which is used to collect venous blood. Blood collection itself is not a diagnostic act, although the collected blood may later be used for diagnostic testing. The device's function is purely for collection, not analysis or diagnosis.

No

The device description clearly states it is a physical blood collection needle and associated components, not software.

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

Here's why:

  • Intended Use: The intended use is solely for the collection of venous blood. It does not mention any subsequent testing or analysis of the collected blood for diagnostic purposes.
  • Device Description: The device description focuses on the physical components and function of creating a channel for blood collection. It does not describe any reagents, test strips, or analytical components typically associated with IVDs.
  • Performance Studies: The performance studies described are related to the physical and safety aspects of the blood collection device (standards for needles, sharps injury prevention, etc.). There are no studies related to the accuracy or performance of a diagnostic test.
  • Lack of IVD-related terms: The text does not contain any terms commonly associated with IVDs, such as "assay," "reagent," "analyte," "diagnosis," "testing," or "in vitro."

The device is a tool for obtaining a biological sample (blood), which may then be used in an IVD test, but the device itself is not performing the diagnostic function.

N/A

Intended Use / Indications for Use

The Sol-M Blood Collection Needle is intended to be used with vacuum blood collection tube for the collection of venous blood.

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

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

The Sol-M Blood Collecting Set is intended to be used with vacuum blood collection tube for the collection of venous blood.

Product codes (comma separated list FDA assigned to the subject device)

FMI

Device Description

The proposed devices are blood collection devices form a channel between patient's vein and the vacuum blood collection tube intended for collection of blood. The proposed devices are divided into several types, the configuration for each type of proposed device are provided as follows

Product nameRef No.Patient-End NeedleNon-Patient End NeedleIntegrated NeedleFlexible TubeNeedle HolderSafety FeatureVisible Flashback
Blood Collection Needle – one piece04-11XXXN.A.N.A.N.A.N.A.
Blood Collection Needle – Direct04-13XXXN.A.N.A.N.A.X
Blood Collection Needle – Multi piece04-31XXN.A.N.A.N.A.N.A.X
Safety Blood Collection Needle – Direct04-12XXXN.A.N.A.XN.A.
Safety Blood Collection Needle – Multi piece04-32XXN.A.N.A.N.A.XX
Safety Blood Collection Needle w/Holder – One piece04-15XXXN.A.XXN.A.
Safety Blood Collection Needle w/Holder - Direct04-34XXN.A.N.A.XXX

In addition, the proposed devices are divided into several types and available in different specifications as follows:

Device NameRef No.Needle GaugeNeedle Length
Blood Collection Needle04-1118G-23G1", 1-1/4", 1-1/2"
Blood Collection Needle04-1318G-23G1", 1-1/4", 1-1/2"
Blood Collection Needle04-3119G, 25G5/8", 3/4", 1", 1-1/4", 1-1/2", 1-3/4", 2"
Safety Blood Collection Needle04-1218G-23G1", 1-1/4", 1-1/2"
Safety Blood Collection Needle04-3219G, 25G5/8", 3/4", 1", 1-1/4", 1-1/2", 1-3/4", 2"
Safety Blood Collection Needle with Holder04-1518G-23G1", 1-1/4", 1-1/2"
04-3419G, 25G5/8", 3/4", 1", 1-1/4", 1-1/2", 1-3/4", 2"
Blood Collection Set04-2119G, 25G5/8", 3/4", 1"
Safety Blood Collection Set04-2219G, 25G5/8", 3/4",1"
Blood Collection Set with Holder04-2319G, 25G5/8", 3/4", 1"
Safety Blood Collecting Set with Holder04-2419G, 25G5/8", 3/4", 1"

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Venous blood collection

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 applicable sections of the following standards:

  • ISO 9626:2016 Stainless steel needle tubing for the manufacture of medical devices; Sample needles from Safety blood collection Sets with a Holder were tested as follows per the requirements of ISO 9626: Material verification, surface finish and visual appearance, cleanliness, limits for acidity and alkalinity, size designation, dimensional inspection, stiffness, resistance to breakage and resistance to corrosion.
  • ISO 7864:2016 Sterile hypodermic needles for single use - Requirements and test methods. Sample needles from Safety blood collection Sets with a Holder were tested as follows per the requirements of ISO7864: Cleanliness, limits for acidity and alkalinity, limits for extractable metals, tubular needle designation, color coding, conical fitting, color of hub, needle cap, tolerance on length, freedom from defects, lubricant, needle point, bond between hub and needle tube and patency of lumen.
  • ISO 10993-7:2008 Biological evaluation of medical devices- Part 7: Ethylene oxide sterilization residuals; EO and ECH Residuals Resting of sterilized product
  • ASTM F 88/F88M-09 Standard test method for seal strength of flexible barrier materials; Seal Peel Testing of package seals
  • ASTM F1140/F1140M-13 Standard test methods for internal pressurization failure resistance of unrestrained packages; Burst and Creep Testing of package
  • USP38-NF33 Bacterial Endotoxins Test. Bacterial Endotoxin Testing of device
  • ISO 10993-1:2009 Biological evaluation of medical devices- Part 1: Evaluation and testing within a risk management process. Risk management report
  • ISO 10993-5:2009 Biological evaluation of medical devices-Part 5: Tests for In Vitro Cytotoxicity - Biocompatibility In Vitro Cytotoxicity Test
  • ISO 10993-10:2010 Biological evaluation of medical devices- Part 10: Test for irritation and delayed-type hypersensitivity. Intracutaneous reactivity test and Skin Sensitization test
  • ISO 10993-11:2006 Biological evaluation of medical devices- Part 11: Tests for systemic toxicity. Acute systemic toxicity test, Pyrogen test
  • ASTM F 756-13 Standard practice for assessment of hemolytic properties of materials. Testing for Hemolytic properties of devices
  • Guidance for Industry and FDA Staff, Medical Devices with Sharps Injury Prevention Features Document Issued on: August 9, 2005. A Simulated Use Study was conducted per the requirements of the FDA's Guidance for Industry and FDA Staff Medical Devices with Sharps Injury Prevention Features, Document Issued on: August 9, 2005
  • Clinical tests: Not applicable.

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

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

K172763

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found

§ 880.5570 Hypodermic single lumen needle.

(a)
Identification. A hypodermic single lumen needle is a device intended to inject fluids into, or withdraw fluids from, parts of the body below the surface of the skin. The device consists of a metal tube that is sharpened at one end and at the other end joined to a female connector (hub) designed to mate with a male connector (nozzle) of a piston syringe or an intravascular administration set.(b)
Classification. Class II (performance standards).

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.

December 3, 2018

Sol-Millennium Medical, Inc. James Barley Director of RA 1735 North Brown Road, Suite 120 Lawrenceville, Georgia 30043

Re: K182146

Trade/Device Name: Sol-M Blood Collection Needles, Sol-Care Safety Blood Collection Needles, Sol-Care Safety Blood Collection Needle with Holder, Sol-M Blood Collection Set Regulation Number: 21 CFR 880.5570 Regulation Name: Hypodermic Single Lumen Needle Regulatory Class: Class II Product Code: FMI Dated: July 18, 2018 Received: August 8, 2018

Dear James Barley:

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, 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

1

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) 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, 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 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,

Sarah B. Mollo -S

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

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Indications for Use

510(k) Number (if known) K182146

Device Name

Sol-M Blood Collection Needle Sol-Care Safety Blood Collection Needle Sol-Care Safety Blood Collection Needle with Holder and Sol-M Blood Collecting Set

Indications for Use (Describe)

The Sol-M Blood Collection Needle is intended to be used with vacuum blood collection tube for the collection of venous blood.

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

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

The Sol-M Blood Collecting Set is intended to be used with vacuum blood collection tube for the collection of venous blood.

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 (As required by 21 CFR 807.92(a)) K182146

Summary of for the Sol-M Blood Collection Needle, Sol-Care Safety Blood Collection Needle and Sol-M Blood Collection Set

Date Prepared: November 30, 2018

A. Applicant and Correspondent

Name:Sol-Millennium Medical, Inc.
Address:1735 North Brown Road, Suite 120
Lawrenceville, GA 30043
Contact Person:James Barley
Director of RA
Phone:(404) 433-3058

Manufacturer

Zhejiang kindly medical devices Co., Ltd.

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

B. Name of Device

Trade/Proprietary/Model Name:Sol-M Blood Collection Needle
OSol-Care Safety Blood Collection Needle
OSol-M Blood Collection Set
Common Name of Devices:Blood Collection Needle
OSafety Blood Collection Needle
OBlood Collection Set
Panel:General Hospital
Classification Number:21 CFR 880.5570
Classification Name:Needle, Hypodermic, Single Lumen
Regulatory Class:II
Product Code:FMI

Device to Which New Device is Substantially Equivalent

Device Name:Blood Collecting Devices
Manufacturer:Zhejiang Kindly Medical Devices Co., Ltd.
Classification Number:21 CFR 880.5570
Classification Name:Needle, Hypodermic, Single Lumen
Regulatory Class:II
Product Code:FMI
Reference:K172763

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C. Device Description

The proposed devices are blood collection devices form a channel between patient's vein and the vacuum blood collection tube intended for collection of blood. The proposed devices are divided into several types, the configuration for each type of proposed device are provided as follows

| Product name | Ref No. | Patient-End
Needle | Non-Patient
End Needle | Integrated
Needle | Flexible
Tube | Needle
Holder | Safety
Feature | Visible
Flashback |
|--------------------------------------------------------------|---------|-----------------------|---------------------------|----------------------|------------------|------------------|-------------------|----------------------|
| Blood Collection
Needle – one
piece | 04-11 | X | X | X | N.A. | N.A. | N.A. | N.A. |
| Blood Collection
Needle – Direct | 04-13 | X | X | X | N.A. | N.A. | N.A. | X |
| Blood Collection
Needle – Multi
piece | 04-31 | X | X | N.A. | N.A. | N.A. | N.A. | X |
| Safety Blood
Collection
Needle – Direct | 04-12 | X | X | X | N.A. | N.A. | X | N.A. |
| Safety Blood
Collection
Needle – Multi
piece | 04-32 | X | X | N.A. | N.A. | N.A. | X | X |
| Safety Blood
Collection Needle
w/Holder – One
piece | 04-15 | X | X | X | N.A. | X | X | N.A. |
| Safety Blood
Collection Needle
w/Holder - Direct | 04-34 | X | X | N.A. | N.A. | X | X | X |

In addition, the proposed devices are divided into several types and available in different specifications as follows:

Device NameRef No.Needle GaugeNeedle Length
Blood Collection Needle04-1118G-23G1", 1-1/4", 1-1/2"
Blood Collection Needle04-1318G-23G1", 1-1/4", 1-1/2"
Blood Collection Needle04-3119G, 25G5/8", 3/4", 1", 1-1/4", 1-1/2", 1-3/4", 2"
Safety Blood Collection Needle04-1218G-23G1", 1-1/4", 1-1/2"
Safety Blood Collection Needle04-3219G, 25G5/8", 3/4", 1", 1-1/4", 1-1/2", 1-3/4", 2"
Safety Blood Collection Needle with04-1518G-23G1", 1-1/4", 1-1/2"
Holder04-3419G, 25G5/8", 3/4", 1", 1-1/4", 1-1/2", 1-3/4", 2"
Blood Collection Set04-2119G, 25G5/8", 3/4", 1"
Safety Blood Collection Set04-2219G, 25G5/8", 3/4",1"
Blood Collection 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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D. Statement of Indications for Use

  • The Sol-M Blood Collection Needle is intended to be used with vacuum blood collection tube for the collection of venous blood.
  • The Sol-Care Safety Blood Collection Needle is intended to be used with vacuum blood collection tube for the collection of venous blood. The safety shield is intended to aid in the protection against accidental needle stick injury.
  • The Sol-Care Safety Blood Collection Needle with Holder is intended to be used with . vacuum blood collection tube for the collection of venous blood. The safety shield is intended to aid in the protection against accidental needle stick injury.
  • The Sol-M Blood Collecting Set is intended to be used with vacuum blood collection tube for the collection of venous

E. 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 applicable sections of the following standards:

  • A ISO 9626:2016 Stainless steel needle tubing for the manufacture of medical devices; > Sample needles from Safety blood collection Sets with a Holder were tested as follows per the requirements of ISO 9626: Material verification, surface finish and visual appearance, cleanliness, limits for acidity and alkalinity, size designation, dimensional inspection, stiffness, resistance to breakage and resistance to corrosion.
  • ISO 7864:2016 Sterile hypodermic needles for single use - Requirements and test methods

Sample needles from Safety blood collection Sets with a Holder were tested as follows per the requirements of ISO7864: Cleanliness, limits for acidity and alkalinity, limits for extractable metals, tubular needle designation, color coding, conical fitting, color of hub, needle cap, tolerance on length, freedom from defects, lubricant, needle point, bond between hub and needle tube and patency of lumen.

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

EO and ECH Residuals Resting of sterilized product

  • ASTM F 88/F88M-09 Standard test method for seal strength of flexible barrier materials; > Seal Peel Testing of package seals

  • A ASTM F1140/F1140M-13 Standard test methods for internal pressurization failure resistance of unrestrained packages;

Burst and Creep Testing of package

  • USP38-NF33 Bacterial Endotoxins Test. > Bacterial Endotoxin Testing of device

  • ♪ ISO 10993-1:2009 Biological evaluation of medical devices- Part 1: Evaluation and testing within a risk management process.

Risk management report

  • ISO 10993-5:2009 Biological evaluation of medical devices-Part 5: Tests for In Vitro Cytotoxicity >
    • Biocompatibility In Vitro Cytotoxicity Test A

6

  • ISO 10993-10:2010 Biological evaluation of medical devices- Part 10: Test for irritation and delayed-type hypersensitivity

Intracutaneous reactivity test and Skin Sensitization test

  • ISO 10993-11:2006 Biological evaluation of medical devices- Part 11: Tests for systemic toxicity A > Acute systemic toxicity test > Pyrogen test
  • ASTM F 756-13 Standard practice for assessment of hemolytic properties of materials A

Testing for Hemolytic properties of devices

  • A Guidance for Industry and FDA Staff, Medical Devices with Sharps Injury Prevention Features Document Issued on: August 9, 2005

A Simulated Use Study was conducted per the requirements of the FDA's Guidance for Industry and FDA Staff Medical Devices with Sharps Injury Prevention Features, Document Issued on: August 9, 2005

  • F. Brief discussion of clinical tests submitted, referenced, or relied on in the premarket notification submission for a determination of substantial equivalence. Not applicable.

| ITEM | Predicate Device
K172763 | Proposed Devices | Remark |
|---------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------|
| Class | II | II | Same |
| Intended use | The Blood Collecting Needle
is intended to be used with
vacuum blood collection tube
for the collection of venous
blood. The Safety Blood Collecting
Needle is intended to be used
with vacuum blood collection
tube for the 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 the collection of
venous blood | The Sol-M Blood Collection Needle is
intended to be used with vacuum blood
collection tube for the collection of venous
blood. The Sol-Care Safety Blood Collection
Needle is intended to be used with vacuum
blood collection tube for the collection of
venous blood. The safety shield is intended
to aid in the protection against accidental
needle stick injury. The Sol-Care Safety Blood Collection
Needle with Holder is intended to be used
with vacuum blood collection tube for the
collection of venous blood. The safety
shield is intended to aid in the protection
against accidental needle stick injury. The Sol-M Blood Collecting Set is
intended to be used with vacuum blood
collection tube for the collection of venous | Same |
| ITEM | Predicate Device
K172763 | Proposed Devices | Remark |
| Configuration | Patient-end Needle
Protective Cover of
Patient-end Needle
Patient-end Needle
Hub
Non-patient
end Needle
Hub
Non-patient end Needle
Rubber Sleeve
Protective Cover of Non-patient
end Needle
Double Wing
Flexible Tube
Conical
Fitting
Connector
Conical
Fitting
Needle Holder | Patient-end Needle
Protective Cover of Patient-end
Needle
Patient-end Needle Hub
Non-patient end Needle
Hub
Non-patient end Needle Rubber Sleeve
Protective Cover of Non-patient end Needle
Double Wing
Flexible Tube
Conical Fitting Connector Conical
fitting
Needle Holder
Safety Shield | Same |
| ITEM | Predicate Device
K172763 | Proposed Devices | Remark |
| Operational
mode | Manual | Manual | Same |
| Specifications | 18G, 19G, 20G, 21G, 22G, 23G,
25G
5/8", ¾",1", 1-1/4", 1-1/2", 1-
3/4", 2" | 18G, 19G, 20G, 21G, 22G, 23G, 25G
5/8", ¾", 1", 1-1/4", 1-1/2", 1-3/4", 2" | Same |
| Safety
mechanism | The safety shield is intended to
prevent needle sticks. | The safety shield is intended to prevent needle
sticks. | Same |
| Labeling | Conforms to Part 801 | Conforms to Part 801 | Same |
| Single use | Yes | Yes | Same |
| ITEM | Predicate Device
K172763 | Proposed Devices | Remark |
| Patient-contact material | | | |
| Needle Tube | Stainless Steel | Stainless Steel | |
| Lubricant | Silicone Oil | Silicone Oil | Same |
| Adhesive | Epoxy Resin | Epoxy Resin | |
| Biocompatibility | | | |
| In Vitro Cytotoxicity | Conform with ISO 10993 | Conform with ISO 10993 | Same |
| Skin Sensitization | | | |
| Intracutaneous Reactivity | | | |
| Acute Systemic Toxicity | | | |
| Hemolytic Properties | | | |
| Sterilization | | | |
| Method | EO sterilized | EO sterilized | |
| SAL | 10-6 | 10-6 | Same |
| Endotoxin Limit | 20 EU per device | 20 EU per device | |

G. Substantially Equivalent (SE) Comparison

Comparison of Technology for Substantial Equivalence

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The proposed devices, Blood Collecting Needle, Safety Blood Collecting Needle, Blood Collecting Needle with Holder, Safety Blood Collecting Needle with Holder are the same to the predicate device K172763 in device design, Indications for use, manufacturing materials and processes, sterilization, method of operation and technological characteristics. Therefore, the proposed devices can be determined substantially equivalence to predicatedevices.

H. 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.