K Number
K183665
Device Name
Safety Needles, Sterile Syringe, Sterile Syringe with Safety Needle, Sterile Syringe with Needle, Hypodermic Needle for Single Use
Date Cleared
2019-09-06

(253 days)

Product Code
Regulation Number
880.5860
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Safety Needles: The safety needles are intended to be used with a luer slip or luer lock syringe for aspiration and injection of fluids for medical purpose. After withdrawal of the needle from the body, the attached needle safety shield can be manually activated to cover the needle immediately after use to minimize risk of accidental needlestick. Sterile Syringe: The sterile syringe is a sterile luer slip syringe which is intended to be used with a hypodermic needle for the aspiration and injection of fluids for medical purpose. Sterile Syringe with Safety Needle: The sterile syringe with safety needle is intended for use in the aspiration of fluids for medical purpose. After withdrawal of the needle from the body, the attached needle safety shield can be manually activated to cover the needle immediately after use to minimize risk of accidental needle sticks. Sterile Syringe with Needle: The sterile syringe with needle is intended for use the aspiration of fluids for medical purpose. Hypodermic Needles for Single Use: The hypodermic needle is intended to be used with a luer slip or luer lock syringe for aspiration of fluids for medical purpose.
Device Description
(1)Safety Needles: The Safety Needles are intended for manual and single use only. They consist of a needle cap, needle tube and hub with protector. The proposed device is compatible for use with a luer slip or luer lock syringe. The safety sheath will be manually activated to cover the needle immediately after use to minimize risk of accidental needle sticks. (2)Sterile Syringe: The Sterile Syringe is intended for manual and single use only. It consists of a Barrel, Plunger, and Piston. The syringes are available with luer slip and luer lock connector types and are available in different sizes. They are intended to be connected to a safety/hypodermic needle. (3)Sterile Syringe with Safety Needle: This product is intended for manual and single use only. The Sterile Syringe with Safety Needle consists of a hypodermic needle with a safety sheath attached to the needle hub and a luer slip or luer lock syringe. The proposed device is available in a variety of syringe and needle sizes. The safety sheath will be manually activated to cover the needle immediately after use to minimize risk of accidental needle sticks. (4)Sterile Syringe with Needle: The Sterile Syringe with Needle is intended for manual and single use only. It consists of a hypodermic needle and a luer slip or luer lock syringe. The proposed device is available in a variety of syringe and needle sizes. (5)Hypodermic Needles for Single Use: The Hypodermic Needle is intended for manual and single use only. It consists of a hub, needle tube, needle cap. The proposed device is compatible for use with a luer slip or luer lock syringe.
More Information

Not Found

No
The device description and performance testing focus on mechanical and material properties of syringes and needles, with no mention of AI or ML.

No
The devices are intended for aspiration and injection of fluids, and needle safety. They are not described as providing therapy or treatment.

No.

The devices described are syringes and needles used for aspiration and injection of fluids, which are fluid delivery devices, not diagnostic devices.

No

The device description and performance studies clearly indicate that this submission is for physical medical devices (needles and syringes) and not software.

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

Here's why:

  • Intended Use: The intended use of all the listed devices (safety needles, sterile syringes, sterile syringes with safety needles, sterile syringes with needles, and hypodermic needles) is for the aspiration and injection of fluids for medical purposes. This involves introducing or withdrawing substances from the body, which is a direct medical procedure performed on a patient.
  • IVD Definition: In vitro diagnostics are tests performed on samples taken from the human body, such as blood, urine, or tissue, to detect diseases, conditions, or infections. They are used outside the body (in vitro) to provide information about a patient's health.
  • Device Description: The device descriptions detail the physical components and function of needles and syringes, which are tools for administering or collecting substances from the body, not for analyzing samples in a laboratory setting.
  • Performance Studies: The performance studies focus on the physical and biological properties of the needles and syringes (biocompatibility, dimensions, strength, leakage, etc.) and the functionality of the safety features. These are relevant to the safe and effective use of these devices for aspiration and injection, not for diagnostic testing.
  • Lack of Diagnostic Elements: There is no mention of any components, reagents, or processes related to analyzing biological samples for diagnostic purposes.

In summary, the devices described are medical devices used for direct patient care (aspiration and injection), not for in vitro diagnostic testing of biological samples.

N/A

Intended Use / Indications for Use

Safety Needles

The safety needles are intended to be used with a luer slip or luer lock syringe for aspiration and injection of fluids for medical purpose. After withdrawal of the needle from the body, the attached needle safety shield can be manually activated to cover the needle immediately after use to minimize risk of accidental needlestick.

Sterile Syringe

The sterile syringe is a sterile luer slip syringe which is intended to be used with a hypodermic needle for the aspiration and injection of fluids for medical purpose.

Sterile Syringe with Safety Needle

The sterile syringe with safety needle is intended for use in the aspiration of fluids for medical purpose. After withdrawal of the needle from the body, the attached needle safety shield can be manually activated to cover the needle immediately after use to minimize risk of accidental needle sticks.

Sterile Syringe with Needle

The sterile syringe with needle is intended for use the aspiration of fluids for medical purpose.

Hypodermic Needles for Single Use

The hypodermic needle is intended to be used with a luer slip or luer lock syringe for aspiration of fluids for medical purpose.

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

MEG, FMF, FMI

Device Description

(1)Safety Needles
The Safety Needles are intended for manual and single use only. They consist of a needle cap, needle tube and hub with protector. The proposed device is compatible for use with a luer slip or luer lock syringe. The safety sheath will be manually activated to cover the needle immediately after use to minimize risk of accidental needle sticks.

(2)Sterile Syringe
The Sterile Syringe is intended for manual and single use only. It consists of a Barrel, Plunger, and Piston. The syringes are available with luer slip and luer lock connector types and are available in different sizes. They are intended to be connected to a safety/hypodermic needle.

(3)Sterile Syringe with Safety Needle
This product is intended for manual and single use only. The Sterile Syringe with Safety Needle consists of a hypodermic needle with a safety sheath attached to the needle hub and a luer slip or luer lock syringe. The proposed device is available in a variety of syringe and needle sizes. The safety sheath will be manually activated to cover the needle immediately after use to minimize risk of accidental needle sticks.

(4)Sterile Syringe with Needle
The Sterile Syringe with Needle is intended for manual and single use only. It consists of a hypodermic needle and a luer slip or luer lock syringe. The proposed device is available in a variety of syringe and needle sizes.

(5)Hypodermic Needles for Single Use
The Hypodermic Needle is intended for manual and single use only. It consists of a hub, needle tube, needle cap. The proposed device is compatible for use with a luer slip or luer lock syringe.

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

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)

The subject device was tested/analyzed according to the following standards in order to ensure its effectiveness and safety:

  1. Biocompatibility:
    Needle: Externally communicating, blood path indirect with limited patient contact
    Syringe: Externally communicating, blood path indirect with prolonged patient contact
    Testing according to:
  • ANSI AAMI ISO 10993-5:2009/(R)2014, Biological Evaluation Of Medical Devices Part ● 5: Tests For In Vitro Cytotoxicity;
  • ANSI AAMI ISO 10993-10:2010/(R)2014. Biological Evaluation Of Medical Devices Part ● 10: Tests For Irritation And Skin Sensitization;
  • ANSI AAMI ISO 10993-11:2006/(R)2010, Biological Evaluation Of Medical Devices Part ● 11: Tests For Systemic Toxicity;
  • . ISO 10993-4:Third Edition 2017-04, Biological Evaluation Of Medical Devices--Part 4: Selection Of Tests For Interactions With Blood;
  • ASTM F756-17, Standard Practice For Assessment Of Hemolytic Properties Of Materials.
  1. Performance testing according to ISO 7864 Fourth Edition 2016-08-01, Sterile Hypodermic Needles For Single Use - Requirements And Test Methods:
  • Cleanliness ●
  • Limits for acidity or alkalinity ●
  • Limits for extractable metals ●
  • Color coding ●
  • Conical fitting ●
  • Color of hub
  • Needle cap ●
  • Tolerances on length
  • Freedom from defects
  • Lubricant ●
  • Needle point ●
  • Bond between hub and needle tube
  • Patency of lumen
  • Sharps injury protection
  1. Performance testing according to ISO 7886-1 Second Edition 2017-05, Sterile Hypodermic Syringes For Single Use - Part 1: Syringes For Manual Use:
  • Limits for acidity or alkalinity .
  • Limits for extractable metals ●
  • Lubricant ●
  • Tolerance on graduated capacity ●
  • Scale ●
  • Numbering of scales
  • Overall length of scale to nominal capacity line ●
  • . Position of scale
  • Barrel flanges
  • Minimum length between barrel flanges and plunger push-button
  • Conical fitting
  • Position of nozzle on end of barrel
  • Nozzle lumen
  • Dead space
  • Freedom from air and liquid leakage past plunger stopper
  • Force to operate the position
  • Fit of plunger stopper/plunger in barrel ●
  1. Performance testing according to ISO 80369-7 First Edition 2016-10-15, Small-Bore Connectors For Liquids And Gases In Healthcare Applications - Part 7: Connectors For Intravascular Or Hypodermic Applications:
  • Leakage by pressure decay
  • Positive pressure liquid leakage ●
  • Sub-atmospheric pressure air leakage ●
  • Stress cracking
  • Resistance to separation from axial load ●
  • Resistance to unscrewing ●
  • Resistance to overriding
  1. Performance testing according to ISO 9626 Second Edition 2016-08-01, Stainless Steel Needle Tubing For The Manufacture Of Medical Devices - Requirements And Test Methods:
  • . Dimensions
  • Stiffness ●
  • Resistance to breakage ●
  • Resistance to corrosion ●
  1. Additional Performance testing for the Safety Needles/ Sterile Syringe/Sterile Syringe with Safety Needle/Sterile Syringe with Needle/Hypodermic Needle for Single Use:
  • Conical fitting to ISO 80369-7 ●
  • Sharps Injury Protection Test Report to ISO 23908:2011 ●
  • Particulate Testing per USP

The subject and predicate device have similar technological characteristics, are provided sterile, and are intended for single use. Differences in configurations and sizes have been evaluated by non-clinical bench testing per ISO 7864, ISO 9626, ISO 7886 and ISO 80369-7. Furthermore, both devices were tested for biocompatibility per ISO 10993-1. Hence, we conclude that the subject device was demonstrated to be substantially equivalent to the predicate device.

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.

K170651

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

§ 880.5860 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).

0

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.

September 6, 2019

Jiangsu Micsafe Medical Technology Co., Ltd. Tony Yang General Manager Xituan Industrial Park, Dafeng District Yancheng, 224125 Cn

Re: K183665

Trade/Device Name: Safety Needles, Sterile Syringe, Sterile Syringe with Safety Needle, Sterile Syringe with Needle, Hypodermic Needle for Single Use Regulation Number: 21 CFR 880.5860 Regulation Name: Piston Syringe Regulatory Class: Class II Product Code: MEG, FMF, FMF, FMI Dated: July 30, 2019 Received: July 30, 2019

Dear Tony Yang:

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.

1

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) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (OS) 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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

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/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). 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 (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-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 CAPT Alan M. Stevens Assistant Director DHT3C: Division of Drug Delivery and General Hospital Devices, and Human Factors OHT3: Office of Gastrorenal, ObGyn, General Hospital and Urology Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K183665

Device Name

Safety Needles, Sterile Syringe with Safety Needle, Sterile Syringe with Needle, Hypodermic Needle for Single Use

Indications for Use (Describe)

Safety Needles

The safety needles are intended to be used with a luer slip or luer lock syringe for aspiration and injection of fluids for medical purpose. After withdrawal of the needle from the body, the attached needle safety shield can be manually activated to cover the needle immediately after use to minimize risk of accidental needlestick.

Sterile Syringe

The sterile syringe is a sterile luer slip syringe which is intended to be used with a hypodermic needle for the aspiration and injection of fluids for medical purpose.

Sterile Syringe with Safety Needle

The sterile syringe with safety needle is intended for use in the aspiration of fluids for medical purpose. After withdrawal of the needle from the body, the attached needle safety shield can be manually activated to cover the needle immediately after use to minimize risk of accidental needle sticks.

Sterile Syringe with Needle

The sterile syringe with needle is intended for use the aspiration of fluids for medical purpose.

Hypodermic Needles for Single Use

The hypodermic needle is intended to be used with a luer slip or luer lock syringe for aspiration of fluids for medical purpose.

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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Image /page/3/Picture/1 description: The image contains the logo for Micsafe med. The logo consists of a red and blue square symbol to the left of the text "Micsafe" in a bold, sans-serif font. Below "Micsafe" is the word "med" in a smaller font size.

510(k) Summary (K183665)

Submitter Information

Company: Jiangsu Micsafe Medical Technology Co., Ltd. Address: Xituan Industrial Park, Dafeng District, Yancheng City, Jiangsu Province, 224125, China Phone: 086-13651929266 Contact: Tony Yang, General Manager Date: Sept 3, 2018

Device Information

Trade/Device Name: Safety Needles Sterile Syringe Sterile Syringe with Safety Needle Sterile Syringe with Needle Hypodermic Needle for Single Use

Classification: Class II Regulation Number: 880.5860 Regulation Name: Piston syringe Product Code(s): MEG, FMF, FMI

Common Name(s):Syringe, Antistick Syringe, Piston Needle, Hypodermic, Single Lumen

Type of use: Prescription use only

Predicate Device: Sterile Disposable Syringe With Safety Needle, Sterile Disposable Syringe With Needle, Sterile Disposable Syringe, Sterile Disposable Safety Needle, Sterile Disposable Needle (K170651)

Device Description

(1)Safety Needles

The Safety Needles are intended for manual and single use only. They consist of a needle cap, needle tube and hub with protector. The proposed device is compatible for use with a luer slip or luer lock syringe. The safety sheath will be manually activated to cover the needle immediately after use to minimize risk of accidental needle sticks.

4

Image /page/4/Picture/1 description: The image shows the logo for "Micsafe med". The logo consists of a red and blue square design on the left, followed by the word "Micsafe" in black, and the word "med" in smaller black font below the "safe" portion of the word. The red and blue square design is made up of four squares, with the top two squares being red and the bottom two squares being blue.

(2)Sterile Syringe

The Sterile Syringe is intended for manual and single use only. It consists of a Barrel, Plunger, and Piston. The syringes are available with luer slip and luer lock connector types and are available in different sizes. They are intended to be connected to a safety/hypodermic needle.

(3)Sterile Syringe with Safety Needle

This product is intended for manual and single use only. The Sterile Syringe with Safety Needle consists of a hypodermic needle with a safety sheath attached to the needle hub and a luer slip or luer lock syringe. The proposed device is available in a variety of syringe and needle sizes. The safety sheath will be manually activated to cover the needle immediately after use to minimize risk of accidental needle sticks.

(4)Sterile Syringe with Needle

The Sterile Syringe with Needle is intended for manual and single use only. It consists of a hypodermic needle and a luer slip or luer lock syringe. The proposed device is available in a variety of syringe and needle sizes.

(5)Hypodermic Needles for Single Use

The Hypodermic Needle is intended for manual and single use only. It consists of a hub, needle tube, needle cap. The proposed device is compatible for use with a luer slip or luer lock syringe.

(1)Safety Needles
18G; 20G; 21G; 22G; 23G; 25G; 26G
(2)Sterile Syringe
Luer Slip1ml, 3ml, 5ml, 10ml, 20ml, 30ml, 50ml, 60ml
Luer Slip Eccentric20ml, 30ml, 50ml
Luer Lock1ml, 3ml, 5ml, 10ml, 20ml, 30ml, 50ml, 60ml
(3)Sterile Syringe with Safety Needle
Luer Slip1ml, 3ml, 5ml, 10ml, 20ml, 30ml, 50ml, 60ml
Luer Slip Eccentric20ml, 30ml, 50ml
Luer Lock1ml, 3ml, 5ml, 10ml, 20ml, 30ml, 50ml, 60ml
Needle Size:18G; 20G; 21G; 22G; 23G; 25G; 26G
(4)Sterile Syringe with Needle
Luer Slip1ml, 3ml, 5ml, 10ml, 20ml, 30ml, 50ml, 60ml
Luer Slip Eccentric20ml, 30ml, 50ml
Luer Lock1ml, 3ml, 5ml, 10ml, 20ml, 30ml, 50ml, 60ml
Needle Size:18G ; 19G; 20G; 21G; 22G; 23G; 24G; 25G; 26G; 27G; 28G;
29G; 30G; 31G

Configurations and Sizes

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Image /page/5/Picture/1 description: The image shows the logo for MicSafe med. The logo consists of a square divided into four smaller squares, with the top two squares in red and the bottom two squares in blue. To the right of the square is the text "MicSafe" in black, with a red dot over the "i". Below "MicSafe" is the text "med" in black.

(5)Hypodermic Needles for Single Use

18G; 19G; 20G; 21G; 22G; 23G; 24G; 25G; 26G; 27G; 28G; 29G; 30G; 31G

Needle lengths

Safety Needle
1/2"3/4"1"1 1/4"1 1/2"2"
18G
20G
21G
22G
23G
25G
26G
Hypodermic Needles for Single Use
1/2"5/8"3/4"1"1 1/4"1 1/2"2"
18G
19G
20G
21G
22G
23G
24G
25G
26G
27G
28G
29G
30G
31G

Indications for Use

(1)Safety Needles

The safety needles are intended to be used with a luer slip or luer lock syringe for aspiration and injection of fluids for medical purpose. After withdrawal of the needle from the body, the attached needle safety shield can be manually activated to cover the needle immediately after use to minimize risk of accidental needlestick.

(2)Sterile Syringe

The sterile syringe is a sterile luer lock or luer slip syringe which is intended to be used with a

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Image /page/6/Picture/1 description: The image contains the logo for "Micsafe med". The logo consists of a red and blue square design on the left, followed by the word "Micsafe" in bold, black letters. Below "Micsafe" is the word "med" in a smaller font size, also in black.

hypodermic needle for the aspiration and injection of fluids for medical purpose.

(3)Sterile Syringe with Safety Needle

The sterile syringe with safety needle is intended for use in the aspiration and injection of fluids for medical purpose. After withdrawal of the needle from the body, the attached needle safety shield can be manually activated to cover the needle immediately after use to minimize risk of accidental needle sticks.

(4)Sterile Syringe with Needle

The sterile syringe with needle is intended for use the aspiration and injection of fluids for medical purpose.

(5)Hypodermic Needles for Single Use

The hypodermic needle is intended to be used with a luer slip or luer lock syringe for aspiration and injection of fluids for medical purpose.

| Comparison

ItemsSubject Device (K183665)Predicate Device (K170651)
IdentificationSafety needle for single useThe sterile disposable safety needle-
K170651
ClassificationProduct Code: FMI Class: 2Product Code: MEG,FMF,FMI
Class: 2
Intended UseThe safety needles are intended to be used with a luer slip or luer lock syringe for aspiration and injection of fluids for medical purpose. After withdrawal of the needle from the body, the attached needle safety shield can be manually activated to cover the needle immediately after use to minimize risk of accidental needlestick.The sterile disposable safety needle is intended to be used with a luer slip or luer lock syringe for aspiration and injection of fluids for medical purpose. After withdrawal of the needle from the body, the attached needle safety shield can be manually activated to cover the needle immediately after use to minimize risk of accidental needestick.
Configurations
and MaterialsNeedle cap (Polypropylene)
Needle tube (SUS304)Needle cap(Polypropylene)
Needle tube (SUS304)
Comparison
ItemsSubject Device (K183665)Predicate Device (K170651)
Hub with protector
(Polypropylene)Needle hub with safety
sheath(Polypropylene)
Size18G, 20G, 21G, 22G, 23G, 25G,
and 26G
Needle length:
1/2"-2"16G, 18G, 19G, 20G, 21G, 22G, 23G,
24G, 25G, 26G, 27G, 28G, 29G, and 30G
Needle length:
5/16"-1 1/2"
SterileYes (EO)Yes (EO)
Single UseYesYes
BiocompatibilityConforms to the requirement of
ISO 10993 series Standards
No Cytotoxicity
No Irritation to Skin
No significant evidence of
sensitization
No systemic toxicity
No Hemolysis
Non pyrogenicConforms to the requirement of ISO
10993 series Standards
No Cytotoxicity
No Irritation to Skin
No significant evidence of sensitization
No systemic toxicity
No Hemolysis
Non pyrogenic
Performance
safety &
effectivenessConforms with the requirements
of ISO 7864 and ISO 9626.
Needle Safety Feature: Testing
conducted per ISO 23908:2011.
Force to activate safety mode:
NMT 10N
Force to disengage safety mode:
NLT 20N
Force to separate safety feature
from needle hub: NLT 50NConforms with the requirements of ISO
7864 and ISO 9626.
Needle Safety Feature: Specifications
not provided.

Comparison of Indications for Use and Technological Characteristics

(1)Safety Needles

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Image /page/7/Picture/1 description: The image shows the logo for "Micsafe med". The logo consists of a square made up of four smaller squares, with the top two squares being red and the bottom two squares being blue. To the right of the square is the word "Micsafe" in bold, black letters. Below "Micsafe" is the word "med" in smaller, black letters.

The indications for use statement for the subject device is identical to the predicate. Differences in needle lengths and gauges were addressed through ISO 7864 and ISO 9626 testing. Differences in needle safety specifications were addressed through simulated needle safety activation and verification of the specifications. The differences identified do not raise different questions of safety and effectiveness.

(2) Sterile Syringe

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Image /page/8/Picture/0 description: The image shows the text "MICSAFE MEDICAL GROUP" in a bold, sans-serif font. The text is arranged on a single line and is centered horizontally. The words are all capitalized and evenly spaced.

Image /page/8/Picture/1 description: The image shows the logo for "Micsafe med". The logo consists of a red and blue square symbol on the left, followed by the text "Micsafe" in bold, black font. Below "Micsafe" is the word "med" in a smaller, black font.

| Comparison

ItemsSubject Device (K183665)Predicate Device (K170651)
IdentificationSterile SyringeThe sterile disposable syringe-
K170651
ClassificationProduct Code: FMF
Class: 2Product Code: MEG,FMF,FMI
Class: 2
Intended UseThe sterile syringe is a sterile luer
lock or luer slip syringe which is
intended to be used with a
hypodermic needle for the
aspiration and injection of fluids for
medical purpose.The sterile disposable syringe is a
sterile luer lock or luer slip syringe
which is intended to be used with a
hypodermic needle for the aspiration
and injection of fluids for medical
purpose.
Configurations
and MaterialsBarrel (Polypropylene)
Plunger (Polypropylene)
Stopper (Polyisoprene)Barrel (Polypropylene)
Plunger (Polypropylene)
Stopper (Polyisoprene)
Size1ml, 3ml, 5ml, 10ml, 20ml, 30ml,
50ml, and 60ml
Luer Lock/Luer Slip/Luer slip
Eccentric1ml, 2ml, 3ml, 5ml, 10ml, 20ml,
30ml, 50ml, and 60ml
Luer Lock/Luer Slip
SterileYes (EO)Yes (EO)
Single UseYesYes
BiocompatibilityConforms to the requirement of ISO
10993 series Standards
No Cytotoxicity
No Irritation to Skin
No significant evidence of
sensitization
No systemic toxicity
No Hemolysis
Non pyrogenicConforms to the requirement of ISO
10993 series Standards
No Cytotoxicity
No Irritation to Skin
No significant evidence of
sensitization
No systemic toxicity
No Hemolysis
Non pyrogenic
Performance
safety &
effectivenessConforms with the requirements of
ISO 7886 and ISO 80369-7.Conforms with the requirements of
ISO 7886 and ISO 594-1/-2.
Comparison
ItemsSubject Device (K183665)Predicate Device (K170651)
IdentificationSterile syringe with safety needlesThe sterile disposable syringe with
safety needle- K170651
ClassificationProduct Code: MEG,FMF,FMI
Class: 2Product Code: MEG,FMF,FMI
Class: 2
Intended UseThe sterile syringe with safety
needle is intended for use in the
aspiration and injection of fluids for
medical purpose. After withdrawal
of the needle from the body, the
attached needle safety shield can be
manually activated to cover the
needle immediately after use to
minimize risk of accidental needle
sticks.The sterile disposable syringes with
Safety Needle is intended for use in
the aspiration and injection of fluids
for medical purpose. After
withdrawal of the needle from the
body, the attached needle safety
shield can be manually activated to
cover the needle immediately after
use to minimize risk of accidental
needle sticks.
Configurations
and MaterialsBarrel (Polypropylene)
Plunger (Polypropylene)
Stopper (Polyisoprene)
Needle cap (Polypropylene)
Needle tube (SUS304)
Hub with protector (Polypropylene)Barrel (Polypropylene)
Plunger (Polypropylene)
Stopper (Polyisoprene)
Needle cap (Polypropylene)
Needle tube (SUS304)
Needle hub with safety sheath
(Polypropylene)
Size1ml, 3ml, 5ml, 10ml, 20ml, 30ml,
50ml, and 60ml
Luer Lock/Luer Slip/Luer slip
Eccentric
18G, 20G, 21G, 22G, 23G, 25G, and
26G
Needle length:
1/2"-2"1ml, 2ml, 3ml, 5ml, 10ml, 20ml,
30ml, 50ml, and 60ml
Luer Lock/Luer Slip 16G, 18G, 19G,
20G, 21G, 22G, 23G, 24G, 25G, 26G,
27G, 28G, 29G, and 30G
Needle length:
5/16"-1 1/2"
SterileYes (EO)Yes (EO)
Comparison
ItemsSubject Device (K183665)Predicate Device (K170651)
BiocompatibilityConforms to the requirement of ISO
10993 series Standards
No Cytotoxicity
No Irritation to Skin
No significant evidence of
sensitization
No systemic toxicity
No Hemolysis
Non pyrogenicConforms to the requirement of ISO
10993 series Standards
No Cytotoxicity
No Irritation to Skin
No significant evidence of
sensitization
No systemic toxicity
No Hemolysis
Non pyrogenic
Performance
safety &
effectivenessConforms with the requirements of
ISO 7864, ISO 9626, ISO 7886, and
ISO 80369-7.
Needle Safety Feature: Testing
conducted per ISO 23908:2011.
Force to activate safety mode: NMT
10N
Force to disengage safety mode:
NLT 20N
Force to separate safety feature from
needle hub: NLT 50NConforms with the requirements of
ISO 7864, ISO 9626, ISO 7886, and
ISO 594-1/-2.
Needle Safety Feature: Specifications
not provided.

The indications for use statement for the subject device is identical to the predicate. Differences

9

Image /page/9/Picture/0 description: The image shows the text "MICSAFE MEDICAL GROUP" in a bold, serif font. The text is centered and appears to be the name of a medical organization. The words are all capitalized and evenly spaced, giving the image a professional and clean look. The background is plain white, which makes the text stand out.

Image /page/9/Picture/1 description: The image shows the logo for "Micsafe med". The logo consists of two parts: a symbol on the left and the text on the right. The symbol is made up of four squares, with the top two squares in red and the bottom two squares in blue. The text "Micsafe" is in bold, black letters, with a small red square above the "i". Below "Micsafe" is the word "med" in smaller, black letters.

in connections (i.e., addition of eccentric luer slip models) were addressed through ISO 7886 and ISO 80369 testing. The technological differences do not raise different questions of safety and effectiveness.

(3) Sterile Syringe with Safety Needle

10

Image /page/10/Picture/0 description: The image shows the text "MICSAFE MEDICAL GROUP" in all caps. The text is in a bold, serif font. The words are arranged in a single line, with the word "MICSAFE" appearing first, followed by "MEDICAL" and then "GROUP".

Image /page/10/Picture/1 description: The image shows the logo for Micsafe med. The logo consists of a square made up of four smaller squares, with the top two squares being red and the bottom two squares being blue. To the right of the square is the text "Micsafe" in bold, black letters, with the word "med" in smaller, gray letters below it. The logo is simple and modern, and the colors are bright and eye-catching.

The indications for use statement for the subject device is identical to the predicate. Differences in needle gauges, needle lengths and addition of eccentric luer slip models were addressed through ISO 7864, ISO 9626, ISO 7886, and ISO 80369-7 testing. Differences in needle safety specifications were addressed through simulated needle safety activation and verification of the specifications. The differences identified do not raise different questions of safety and effectiveness.

(4)Sterile Syringe with Needle

Comparison ItemsSubject Device (K183665)Predicate Device (K170651)
IdentificationSterile syringe with needlesThe sterile disposable syringe with
needle- K170651
ClassificationProduct Code: MEG,FMF,FMIProduct Code: MEG,FMF,FMI
Comparison ItemsSubject Device (K183665)Predicate Device (K170651)
Class: 2Class: 2
Intended UseThe sterile syringe with needle is
intended for use the aspiration and
injection of fluids for medical
purpose.The sterile disposable syringe with
needle is intended for use in the
aspiration and injection of fluids for
medical purpose.
Configurations and
MaterialsBarrel (Polypropylene)
Plunger (Polypropylene)
Stopper (Polyisoprene)
Needle cap (Polypropylene)
Needle tube (SUS304)
Needle hub (Polypropylene)Barrel (Polypropylene)
Plunger (Polypropylene)
Stopper (Polyisoprene)
Needle cap (Polypropylene)
Needle tube (SUS304)
Needle hub (Polypropylene)
Size1ml, 3ml, 5ml, 10ml, 20ml, 30ml,
50ml, and 60ml
Luer Lock/Luer Slip/Luer slip
Eccentric
18G, 19G, 20G, 21G, 22G, 23G,
24G, 25G, 26G, 27G, 28G, 29G,
30G, and 31G
Needle length:
1/2"-2"1ml, 2ml, 3ml, 5ml, 10ml, 20ml,
30ml, 50ml, and 60ml
Luer Lock/Luer Slip 16G, 18G, 19G,
20G, 21G, 22G, 23G, 24G, 25G, 26G,
27G, 28G, 29G, and 30G
Needle length:
5/16"-1 1/2"
SterileYes (EO)Yes (EO)
Single UseYesYes
BiocompatibilityConforms to the requirement of
ISO 10993 series Standards
No Cytotoxicity
No Irritation to Skin
No significant evidence of
sensitization
No systemic toxicity
No Hemolysis
Non pyrogenicConforms to the requirement of ISO
10993 series Standards
No Cytotoxicity
No Irritation to Skin
No significant evidence of
sensitization
No systemic toxicity
No Hemolysis
Non pyrogenic
Performance safety
& effectivenessConforms with the requirements of
ISO 7864, ISO 9626, ISO 7886,
and ISO 80369-7Conforms with the requirements of
ISO 7864, ISO 9626, ISO 7886, and
ISO 594-1/-2
Comparison
ItemsSubject Device (K183665)Predicate Device (K170651)
IdentificationHypodermic needle for single useThe sterile disposable needle-
K170651
ClassificationProduct Code: FMI Class: 2Product Code: MEG,FMF,FMI,
Class: 2
Intended UseThe hypodermic needle is intended
to be used with a luer slip or luer
lock syringe for aspiration and
injection of fluids for medical
purpose.The sterile disposable needle is
intended to be used with a luer slip
or luer lock syringe for aspiration
and injection of fluids for medical
purpose.
ConfigurationNeedle cap (Polypropylene)
Needle tube (SUS304)
Needle hub (Polypropylene)Needle cap (Polypropylene)
Needle tube (SUS304)
Needle hub (Polypropylene)
Size18G, 19G, 20G, 21G, 22G, 23G, 24G,
25G, 26G, 27G, 28G, 29G, 30G, and
31G Needle length:
1/2"-2"16G, 18G, 19G, 20G, 21G, 22G, 23G,
24G, 25G, 26G, 27G, 28G, 29G, and
30G Needle length:
5/16"-1 1/2"
SterileYes (EO)Yes (EO)
Single UseYesYes
BiocompatibilityConforms to the requirement of
ISO 10993 series Standards
No Cytotoxicity
No Irritation to Skin
No significant evidence of
sensitization
No systemic toxicity
No Hemolysis
Non pyrogenicConforms to the requirement of ISO
10993 series Standards
No Cytotoxicity
No Irritation to Skin
No significant evidence of
sensitization
No systemic toxicity
No Hemolysis
Non pyrogenic

11

Image /page/11/Picture/0 description: The image shows the text "MICSAFE MEDICAL GROUP" in a bold, sans-serif font. The text is arranged on a single line and is centered horizontally. The words are all capitalized and evenly spaced.

Image /page/11/Picture/1 description: The image shows the logo for "Micsafe med". The logo consists of a red and blue square symbol on the left, followed by the word "Micsafe" in bold, black letters. Below "Micsafe" is the word "med" in smaller, lighter letters.

12

Image /page/12/Picture/1 description: The image shows the logo for "Micsafe med". The logo has two red squares on the top row and two blue squares on the bottom row. To the right of the squares is the text "Micsafe" in bold black font, with the "i" in "Micsafe" being red. Below "Micsafe" is the text "med" in a smaller black font.

The indications for use statement for the subject device is identical to the predicate. Differences in luer connection (i.e., addition of luer slip Eccentric), needle gauges and needle lengths were addressed through ISO 7864, ISO 9626, ISO 7886, and ISO 80369 testing. The differences identified do not raise different questions of safety and effectiveness.

(5)Hypodermic Needles for Single Use

13

Image /page/13/Picture/0 description: The image shows the text "MICSAFE MEDICAL GROUP" in a serif font. To the right of the text is a logo consisting of two stacked rectangles, the top one red and the bottom one blue. The rectangles are angled slightly to the right, creating a sense of forward motion.

Image: red and blue squaresMicsafe
med

| Comparison

ItemsSubject Device (K183665)Predicate Device (K170651)
& effectivenessISO 7864 and ISO 9626.ISO 7864 and ISO 9626.

The indications for use statement for the subject device is identical to the predicate. Differences in needle gauges and lengths were addressed through ISO 7864 and ISO 9626 testing. The differences identified do not raise different questions of safety and effectiveness.

Performance Testing

The subject device was tested/analyzed according to the following standards in order to ensure its effectiveness and safety:

  1. Biocompatibility:

Needle: Externally communicating, blood path indirect with limited patient contact Syringe: Externally communicating, blood path indirect with prolonged patient contact Testing according to:

  • ANSI AAMI ISO 10993-5:2009/(R)2014, Biological Evaluation Of Medical Devices Part ● 5: Tests For In Vitro Cytotoxicity;
  • ANSI AAMI ISO 10993-10:2010/(R)2014. Biological Evaluation Of Medical Devices Part ● 10: Tests For Irritation And Skin Sensitization;
  • ANSI AAMI ISO 10993-11:2006/(R)2010, Biological Evaluation Of Medical Devices Part ● 11: Tests For Systemic Toxicity;
  • . ISO 10993-4:Third Edition 2017-04, Biological Evaluation Of Medical Devices--Part 4: Selection Of Tests For Interactions With Blood;
  • ASTM F756-17, Standard Practice For Assessment Of Hemolytic Properties Of Materials.
  1. Performance testing according to ISO 7864 Fourth Edition 2016-08-01, Sterile Hypodermic Needles For Single Use - Requirements And Test Methods:
  • Cleanliness ●
  • Limits for acidity or alkalinity ●
  • Limits for extractable metals ●
  • Color coding ●
  • Conical fitting ●
  • Color of hub
  • Needle cap ●
  • Tolerances on length
  • Freedom from defects
  • Lubricant ●
  • Needle point ●
  • Bond between hub and needle tube

14

Image /page/14/Picture/1 description: The image shows the logo for Micsafe med. The logo consists of a red and blue square symbol on the left, followed by the text "Micsafe" in black, and "med" in smaller black font below the "safe" portion of the name. The red and blue square symbol is made up of four smaller squares, with the top two squares being red and the bottom two squares being blue.

  • Patency of lumen
  • Sharps injury protection
  1. Performance testing according to ISO 7886-1 Second Edition 2017-05, Sterile Hypodermic Syringes For Single Use - Part 1: Syringes For Manual Use:
  • Limits for acidity or alkalinity .
  • Limits for extractable metals ●
  • Lubricant ●
  • Tolerance on graduated capacity ●
  • Scale ●
  • Numbering of scales
  • Overall length of scale to nominal capacity line ●
  • . Position of scale
  • Barrel flanges
  • Minimum length between barrel flanges and plunger push-button
  • Conical fitting
  • Position of nozzle on end of barrel
  • Nozzle lumen
  • Dead space
  • Freedom from air and liquid leakage past plunger stopper
  • Force to operate the position
  • Fit of plunger stopper/plunger in barrel ●
  1. Performance testing according to ISO 80369-7 First Edition 2016-10-15, Small-Bore Connectors For Liquids And Gases In Healthcare Applications - Part 7: Connectors For Intravascular Or Hypodermic Applications:
  • Leakage by pressure decay
  • Positive pressure liquid leakage ●
  • Sub-atmospheric pressure air leakage ●
  • Stress cracking
  • Resistance to separation from axial load ●
  • Resistance to separation from unscrewing ●
  • Resistance to overriding
  1. Performance testing according to ISO 9626 Second Edition 2016-08-01, Stainless Steel Needle Tubing For The Manufacture Of Medical Devices - Requirements And Test Methods:
  • . Dimensions
  • Stiffness ●
  • Resistance to breakage ●
  • Resistance to corrosion ●

15

Image /page/15/Picture/1 description: The image shows the logo for Micsafe med. The logo consists of a red and blue square symbol on the left, followed by the text "Micsafe" in bold, black letters. Below "Micsafe" is the word "med" in a smaller, lighter font.

  1. Additional Performance testing for the Safety Needles/ Sterile Syringe/Sterile Syringe with Safety Needle/Sterile Syringe with Needle/Hypodermic Needle for Single Use:
  • Conical fitting to ISO 80369-7 ●
  • Sharps Injury Protection Test Report to ISO 23908:2011 ●
  • Particulate Testing per USP

Clinical Testing

Not applicable

Conclusion

The subject and predicate device have similar technological characteristics, are provided sterile, and are intended for single use. Differences in configurations and sizes have been evaluated by non-clinical bench testing per ISO 7864, ISO 9626, ISO 7886 and ISO 80369-7. Furthermore, both devices were tested for biocompatibility per ISO 10993-1. Hence, we conclude that the subject device was demonstrated to be substantially equivalent to the predicate device.