K Number
K182589
Device Name
BD Plastipak Syringe
Date Cleared
2019-03-14

(175 days)

Product Code
Regulation Number
880.5860
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
The BD Plastipak ™ Syringe is intended for single use by health care professionals for general purpose fluid aspiration/injection.
Device Description
The 3mL and 20mL BD Plastipak™ Syringe is a three-piece, single use, sterile or bulk non-sterile (BNS) hypodermic syringe with Luer Slip or male 6% (Luer Lock) connection, which are connectable to a compatible female 6% (Luer) connector. The syringe assemblies consist of a lubricated polypropylene barrel with a graduated scale, a lubricated thermoplastic elastomer stopper and a polypropylene plunger rod. The plunger rod is pulled back to aspirate fluids or depressed to inject or expel fluids. The barrel scale of the BD Plastipak™ Syringe incorporates a scale graduated in units of milliliters. The BD Plastipak™ Syringe is provided sterile by Irradiation or Ethylene Oxide Gas (EtO) sterilization methods in a syringe only configuration or with a BD Hypodermic Needle, BD SafetyGlide™ Hypodermic Needle or BD Eclipse™ Hypodermic Needle. The BD Plastipak™ Syringe is also provided in a bulk nonsterile, syringe only configuration.
More Information

Not Found

No
The device description and performance metrics relate to the physical properties and functionality of a standard syringe, with no mention of AI or ML.

No.
The device description and intended use state that it is for "general purpose fluid aspiration/injection," which describes a delivery or collection tool, not a device that itself provides therapy.

No

Explanation: The device, a syringe, is intended for general purpose fluid aspiration/injection. Its function is to facilitate the transport of fluids, not to analyze, detect, or monitor a disease or condition.

No

The device description clearly outlines physical components made of polypropylene and thermoplastic elastomer, indicating it is a hardware device, not software-only.

Based on the provided information, the BD Plastipak™ Syringe is not an In Vitro Diagnostic (IVD) device.

Here's why:

  • Intended Use: The intended use is "for general purpose fluid aspiration/injection." This describes a device used for physically moving fluids into or out of the body, not for examining specimens in vitro (outside the body) to obtain diagnostic information.
  • Device Description: The description details the physical components and function of a syringe for aspiration and injection. It does not mention any components or processes related to analyzing biological samples.
  • Lack of IVD Characteristics: The document does not mention any of the typical characteristics of an IVD, such as:
    • Testing of biological specimens (blood, urine, tissue, etc.)
    • Reagents or assays
    • Measurement of analytes
    • Providing diagnostic information

The performance studies and key metrics listed are all related to the physical and functional performance of the syringe itself (volumetric accuracy, leakage, forces, sterility, biocompatibility), not to the accuracy or reliability of a diagnostic test.

N/A

Intended Use / Indications for Use

The BD Plastipak TM Syringe is intended for single use by health care professionals for general purpose fluid aspiration/injection.

Product codes

FMF

Device Description

The 3mL and 20mL BD Plastipak™ Syringe is a three-piece, single use, sterile or bulk non-sterile (BNS) hypodermic syringe with Luer Slip or male 6% (Luer Lock) connection, which are connectable to a compatible female 6% (Luer) connector. The syringe assemblies consist of a lubricated polypropylene barrel with a graduated scale, a lubricated thermoplastic elastomer stopper and a polypropylene plunger rod. The plunger rod is pulled back to aspirate fluids or depressed to inject or expel fluids. The barrel scale of the BD Plastipak™ Syringe incorporates a scale graduated in units of milliliters. The BD Plastipak™ Syringe is provided sterile by Irradiation or Ethylene Oxide Gas (EtO) sterilization methods in a syringe only configuration or with a BD Hypodermic Needle, BD SafetyGlide™ Hypodermic Needle or BD Eclipse™ Hypodermic Needle. The BD Plastipak™ Syringe is also provided in a bulk nonsterile, syringe only configuration.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

Indicated Patient Age Range

Not Found

Intended User / Care Setting

health care professionals

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 Performance Data: Non-clinical/design verification testing, including shelf life testing, was performed. The subject device met pre-established acceptance criteria for various performance characteristics based on ISO standards (ISO7886-1, ISO7886-2, ISO 11135, ISO 11137, PH Eur. 5.0).
Tests included: Startup Time, Volumetric Accuracy, Sterility Product, Stopper Separation from plunger, Liquid leakage past stopper under pressure (back rib and front rib), Air Leakage past Stopper in aspiration, Dead space, Maximum Usable Capacity, Fiducial Line, Hard Height, Short-Term Flow Rate Accuracy (incl Stiction), Overall Percentage Error, Max Variation in Flow Rate, Plunger Movement Forces (Pump), Syringe Compliance, Uniform Stopper Appearance, Scale (Graduation Line Intervals, Unit of measure, Lines, Numbering, Length, Position), Marking - Syringe Barrel, Air leakage past stopper in aspiration (vacuum), Stopper separation from plunger.
Sterilization Tests:
Irradiation: Met acceptance criteria per ISO 11137-1 and ISO 11137-2.
Ethylene Oxide (EtO): Met acceptance criteria per ISO 11135 and ISO 10993-7.
Biocompatibility Tests:
Cytotoxicity: Non-cytotoxic per ISO 10993-5 and 10993-12, USP .
Hemolysis: Non-hemolytic per ISO 10993-4 and 10993-12.
Acute Systemic Toxicity: Non-toxic per ISO 10993-11 and 10993-12.
Intracutaneous Reactivity: Non-Irritant per ISO 10993-10 and 10993-12, USP .
Sensitization: Non-Sensitizer per ISO 10993-10.
Pyrogenicity: Non-Pyrogenic per ISO 10993-11, 10993-12 and USP 151.
Elastomeric Closures for Injections: Met Type I and II closures per USP .
ISO 7886-1: Acidity/Alkalinity and Extractable Metals: Pass.
Extractables/Leachables Assessment: Pass per ISO 10993-17 and 18.
Particulate Matter: Pass per USP .
Endotoxin LAL: Pass per USP .
Key results: The results demonstrate that the BD Plastipak™ Syringe performs as intended and as well as the legally marketed predicate devices for the same intended use.

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

Not Found

Predicate Device(s):

K980987

Reference Device(s):

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 880.5860 Piston syringe.

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

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Image /page/0/Picture/0 description: The image contains the logos of the Department of Health & Human Services and the Food and 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 includes the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text.

March 14, 2019

Becton, Dickinson and Company % Mark Job Responsible Third Party Official Regulatory Technology Services, LLC 1394 25th Street. Nw Buffalo, Minnesota 55313

Re: K182589

Trade/Device Name: BD Plastipak Syringe Regulation Number: 21 CFR 880.5860 Regulation Name: Piston syringe Regulatory Class: Class II Product Code: FMF Dated: February 14, 2019 Received: February 15, 2019

Dear Mark Job:

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,

Alan M.
Stevens -S

Tina Kiang, Ph.D. for 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

Form Approved: OMB No. 0910-0120DEPARTMENT OF HEALTH AND HUMAN SERVICES
Expiration Date: 06/30/2020Food and Drug Administration
See PRA Statement below.Indications for Use
510(k) Number (if known)K182589
Device NameBD Plastipak TM Syringe
Indications for Use (Describe)The BD Plastipak TM Syringe is intended for single use by health care professionals for general purpose fluid aspiration/injection.
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.

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and review the collection of information. Send comments regarding this burden estimate or any other aspect
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0881 to 48 app 1

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bd.com

Image /page/3/Picture/2 description: The image shows the BD logo. The logo consists of an orange circle with a white starburst-like design inside it. To the right of the circle are the letters "BD" in blue. The letters are in a bold, sans-serif font.

510(k) Summary (21 CFR §807.92) BD Plastipak™ Syringe

| Submitter: | Leslie Robinson-Frye
Staff Regulatory Affairs Specialist
Becton, Dickinson and Company
1 Becton Drive
Franklin Lakes, NJ 07417
Phone: (201) 847-6891
Fax: (201) 847-4306 | |
|-----------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------|
| Contact Person:
Date Prepared: | Leslie Robinson-Frye
March 13, 2019 | |
| Subject Devices: | Name of Device:
Common Name:
Classification Name:
Regulatory Class:
Product Code: | BD Plastipak™ Syringe
Piston Syringe
Piston Syringe, (21 CFR §880.5860)
II
FMF |
| Predicate Devices: | Name of Device:
510(k) Reference:
Common Name:
Classification:
Product Code: | Becton Dickinson Single Use Hypodermic Syringes
K980987
Piston Syringe
Piston Syringe, (21 CFR §880.5860, Class II device)
FMF |

This predicate has not been subject to a design-related recall.

Reason for Submission

The purpose of this submission is to modify the stopper material, barrel/stopper lubricant, stopper dimensions, stopper manufacturing location, product name, and label statements (pump claim and do not re-sterilize) of the predicate Becton Dickinson Single Use Hypodermic Syringes.

Device Description

The 3mL and 20mL BD Plastipak™ Syringe is a three-piece, single use, sterile or bulk non-sterile (BNS) hypodermic syringe with Luer Slip or male 6% (Luer Lock) connection, which are connectable to a compatible female 6% (Luer) connector. The syringe assemblies consist of a lubricated polypropylene barrel with a graduated scale, a lubricated thermoplastic elastomer stopper and a polypropylene plunger rod. The plunger rod is pulled back to aspirate fluids or depressed to inject or expel fluids. The barrel scale of the BD Plastipak™ Syringe incorporates a scale graduated in units of milliliters.

4

Image /page/4/Picture/2 description: The image contains the logo for BD, a global medical technology company. The logo consists of two parts: a stylized sun-like symbol in orange on the left and the letters "BD" in blue on the right. The sun-like symbol has a central circle with radiating lines, and the letters "BD" are in a bold, sans-serif font.

The BD Plastipak™ Syringe is provided sterile by Irradiation or Ethylene Oxide Gas (EtO) sterilization methods in a syringe only configuration or with a BD Hypodermic Needle, BD SafetyGlide™ Hypodermic Needle or BD Eclipse™ Hypodermic Needle. The BD Plastipak™ Syringe is also provided in a bulk nonsterile, syringe only configuration.

Intended Use

The BD Plastipak™ Syringe is intended for single use by health care professionals for general purpose fluid aspiration/injection.

Comparison of Technological Characteristics

The subject BD Plastipak ™ Syringe is equivalent to that of the predicate BD Hypodermic Syringe in intended use, materials and performance characteristics.

The stopper material, lubricant and dimensions are different between the subject and predicate devices However, the above differences are not critical in the safety and effectiveness of the device when used as labeled as demonstrated through functional testing.

Element of ComparisonSubject DevicePredicate Device
Indications for Use/Intended UseThe BD Plastipak™ Syringe is intended for single use by health care professionals for general purpose fluid aspiration/injection.These syringes are intended for use by health care professionals for general purpose fluid aspiration/injection.
Syringe MaterialsPlungerPolypropylenePolypropylene
BarrelPolypropylenePolypropylene
Barrel SiliconeSiliconeSilicone
StopperThermo Plastic Elastomer (TPE) CopolymerPolyisoprene Rubber
Stopper SiliconeSiliconeSilicone
Syringe DimensionsStopper- Stopper Outer Diameter
-Stopper Inner Diameter- Stopper Outer Diameter
-Stopper Inner Diameter
Sterilization MethodsEtO
IrradiationEtO
Irradiation
SAL10-610-6
Shelf Life5 Years5 Years
Functional Testing:
Startup TimeISO7886-2ISO7886-2
Volumetric Accuracy
(Manual Use, tolerance on graduated capacity)ISO7886-1 and ISO 7886-2ISO7886-1 and ISO 7886-2
Sterility Product
(N/A* for BNS)ISO 11135 , ISO 11137 and
PH Eur. 5.0ISO 11135 , ISO 11137 and
PH Eur. 5.0
Not Manufactured with BPAManufacturing process does not
include BPAManufacturing process does
not include BPA
Not made with natural rubber latexNot made with natural rubber
latexNot made with natural
rubber latex
Stopper Separation from plungerISO7886-1ISO7886-1
Liquid leakage past stopper under
pressure (back rib)ISO7886-1 and ISO7886-2ISO7886-1 and ISO7886-2
Liquid leakage past stopper under
pressure (front rib)ISO7886-1 and ISO7886-2ISO7886-1 and ISO7886-2
Air Leakage past Stopper in
aspirationISO7886-1 and ISO7886-2ISO7886-1 and ISO7886-2
Dead spaceISO7886-1 and ISO7886-2ISO7886-1 and ISO7886-2
Maximum Usable CapacityISO7886-1ISO7886-1
Fiducial LineISO7886-1ISO7886-1
Hard HeightISO7886-2ISO7886-2
Short-Term Flow Rate Accuracy
(incl Stiction)ISO 7886-2ISO 7886-2
Overall Percentage ErrorISO7886-2ISO7886-2
Max Variation in Flow RateISO7886-2ISO7886-2
Plunger Movement Forces (Pump)ISO7886-2ISO7886-2
Syringe ComplianceISO7886-2ISO7886-2
Uniform Stopper AppearanceISO7886-1 and ISO7886-2ISO7886-1 and ISO7886-2
Scale -
Graduation Line IntervalsISO7886-1 and ISO7886-2ISO7886-1 and ISO7886-2
Scale -
Unit of measureISO7886-1 and ISO7886-2ISO7886-1 and ISO7886-2
Scale LinesISO7886-1 and ISO7886-2ISO7886-1 and ISO7886-2
Scale NumberingISO7886-1 and ISO7886-2ISO7886-1 and ISO7886-2
Scale LengthISO7886-1 and ISO7886-2ISO7886-1 and ISO7886-2
Scale PositionISO7886-1 and ISO7886-2ISO7886-1 and ISO7886-2
Marking - Syringe BarrelISO7886-1 and ISO7886-2ISO7886-1 and ISO7886-2
Air leakage past stopper in
aspiration (vacuum)ISO7886-1ISO 7886-1
Stopper separation from plungerISO7886-1ISO 7886-1
Biocompatibility Testing:
CytotoxicityISO 10993-5, 10993-12 and
USPISO 10993-5, 10993-12 and
USP
HemolysisPer ISO 10993-4 and 10993-12Per ISO 10993-4 and 10993-12
Acute Systemic ToxicityPer ISO 10993-11 and 10993-12Per ISO 10993-11 and 10993-12
Intracutaneous ReactivityPer ISO 10993-10, 10993-12 USP
andPer ISO 10993-10, 10993-12
USP and
SensitizationPer ISO 10993-10Per ISO 10993-10
PyrogenicityPer ISO 10993-11, 10993-12 and
USP 151Per ISO 10993-11, 10993-12
and USP 151
Elastomeric Closures for InjectionsUSPUSP
ISO 7886-1: Acidity/Alkalinity and
Extractable MetalsISO 7886-1ISO 7886-1
Extractables/Leachables AssessmentISO 10993-17 and ISO 10993-18ISO 10993-17 and
ISO 10993-18
Particulate MatterUSPUSP
Endotoxin, LALUSPUSP

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Image /page/5/Picture/2 description: The image shows the BD logo. The logo consists of an orange circle with white rays emanating from the center, next to the letters "BD" in blue. The letters are bold and sans-serif.

6

Image /page/6/Picture/2 description: The image shows the BD logo. The logo consists of two parts: a stylized orange sun-like symbol on the left and the letters "BD" in blue on the right. The sun-like symbol is a circle with rays emanating from it, and the letters "BD" are in a bold, sans-serif font.

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Image /page/7/Picture/2 description: The image shows the BD logo. The logo consists of an orange circle with a white starburst inside, followed by the letters "BD" in blue. The starburst has 10 points, and the letters "BD" are in a bold, sans-serif font.

Non-Clinical Performance Data

BD has performed the following non-clinical/design verification testing, including shelf life testing and the results of these tests demonstrate that the BD Plastipak™ Syringe performed in an equivalent manner to the predicate devices. As there are no packaging changes occurring as part of this submission, all packaging data was leveraged from predicate devices. Labeling requiremented for BNS sterilization instructions.

| | Startup Time | Subject device met the pre-established acceptance criteria per
ISO7886-2. |
|----------------------------------------------------|--------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------|
| Syringe Performance | Volumetric Accuracy
(Manual Use, tolerance on
graduated capacity) | Subject device met the pre-established acceptance criteria per
ISO7886-1 and ISO7886-2. |
| | Sterility Product
(N/A* for BNS) | Subject device met the pre-established acceptance criteria per
ISO 11135, ISO 11137 and PH Eur. 5.0 |
| | Stopper Separation from
plunger | Subject device met the pre-established acceptance criteria per
ISO7886-1. |
| | Liquid leakage past stopper
under pressure (back rib) | Subject device met the pre-established acceptance criteria per
ISO7886-1 and ISO7886-2. |
| | Liquid leakage past stopper
under pressure (front rib) | Subject device met the pre-established acceptance criteria per
ISO7886-1 and ISO7886-2. |
| | Air Leakage past Stopper in
aspiration | Subject device met the pre-established acceptance criteria per
ISO7886-1 and ISO7886-2. |
| | Dead space | Subject device met the pre-established acceptance criteria per
ISO7886-1 and ISO7886-2. |
| | Maximum Usable Capacity | Subject device met the pre-established acceptance criteria per
ISO7886-1. |
| | Fiducial Line | Subject device met the pre-established acceptance criteria per
ISO7886-1 |
| | Hard Height | Subject device met the pre-established acceptance criteria per
ISO7886-2. |
| Short-Term Flow Rate
Accuracy (incl Stiction) | Subject device met the pre-established acceptance criteria per
ISO7886-2. | |
| Overall Percentage Error | Subject device met the pre-established acceptance criteria per
ISO7886-2. | |
| Max Variation in Flow Rate | Subject device met the pre-established acceptance criteria per
ISO7886-2. | |
| Plunger Movement
Forces (Pump) | Subject device met the pre-established acceptance criteria per
ISO7886-2. | |
| Syringe Compliance | Subject device met the pre-established acceptance criteria per
ISO7886-2. | |
| Uniform
Stopper
Appearance | Subject device met the pre-established acceptance criteria per
ISO7886-1 and ISO7886-2. | |
| Scale - Graduation
Line Intervals | Subject device met the pre-established acceptance criteria per
ISO7886-1 and ISO7886-2. | |
| Scale - Unit of measure | Subject device met the pre-established acceptance criteria per
ISO7886-1 and ISO7886-2. | |
| Scale Lines | Subject device met the pre-established acceptance criteria per
ISO7886-1 and ISO7886-2. | |
| Scale Numbering | Subject device met the pre-established acceptance criteria per
ISO7886-1 and ISO7886-2. | |
| Scale Length | Subject device met the pre-established acceptance criteria per
ISO7886-1 and ISO7886-2. | |
| Scale Position | Subject device met the pre-established acceptance criteria per
ISO7886-1 and ISO7886-2. | |
| Marking - Syringe Barrel | Subject device met the pre-established acceptance criteria per
ISO7886-1 and ISO7886-2. | |
| Air leakage past stopper in
aspiration (vacuum) | Subject device met the pre-established acceptance criteria per
ISO7886-1 | |
| Stopper separation
from plunger | Subject device met the pre-established acceptance criteria per
ISO7886-1 | |

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Image /page/8/Picture/2 description: The image shows the logo for BD, a global medical technology company. The logo consists of two parts: a circular orange symbol with white rays emanating from the center, and the letters "BD" in blue. The symbol is on the left, and the letters are on the right. The logo is simple and modern, and it is easily recognizable.

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Image /page/9/Picture/2 description: The image shows the logo for BD, a global medical technology company. The logo consists of two parts: a circular symbol on the left and the letters "BD" on the right. The circular symbol is orange and features a stylized sun-like design with rays emanating from a central point. The letters "BD" are in blue and have a rounded, sans-serif font.

| Sterilization Test | Irradiation | Subject device met the pre-established acceptance criteria
per ISO 11137-1 and ISO 11137-2 |
|-----------------------|----------------------------------------------|-----------------------------------------------------------------------------------------------|
| | Ethylene Oxide (Eto) | Subject device met the pre-established acceptance criteria
per ISO 11135 and ISO 10993-7 |
| Biocompatibility Test | Cytotoxicity | Per ISO 10993-5 and 10993-12, USP
Non-cytotoxic |
| | Hemolysis | Per ISO 10993-4 and 10993-12,
Non-hemolytic |
| | Acute Systemic Toxicity | Per ISO 10993-11 and 10993-12,
Non-toxic |
| | Intracutaneous Reactivity | Per ISO 10993-10 and 10993-12, USP
Non-Irritant |
| | Sensitization | Per ISO 10993-10,
Non-Sensitizer |
| | Pyrogenicity | Per ISO 10993-11, 10993-12 and USP 151,
Non-Pyrogenic |
| | Elastomeric Closures for
Injections | USP
Met Type I and II closures |
| | ISO 7886-1: | ISO 7886-1 |
| | Acidity/Alkalinity and
Extractable Metals | Pass |
| | Extractables/Leachables
Assessment | ISO 10993-17 and 18
Pass |
| | Particulate Matter | USP Pass |
| | Endotoxin LAL | USP Pass |

Clinical Testing

Clinical testing was not required for this submission.

Substantial Equivalence

The BD Plastipak™ Syringe is substantially equivalent to the predicate devices in intended use, operating principle, technology, design, materials and performance.

Conclusion

The BD Plastipak™ Syringe has been verified to meet the established performance criteria above. The results of the non-clinical/design verification testing demonstrate that the BD Plastipak™ Syringe perform as intended and perform as well as the legally marketed predicate devices for the same intended use. Therefore the devices are substantially equivalent.