(88 days)
Sure-Fine Insulin Syringes are hypodermic insulin syringes for subcutaneous injection of U100 insulin.
Sure-fine Insulin syringes are designed for the subcutaneous injection of a desired dose of insulin. The syringe has a graduated barrel, a plunger rod, needle cap, protective end cap and needle permanently affixed to the tip of the syringe with epoxy. The syringes are available in the following sizes and cap color. The modified Sure-Fine Insulin syringe is substantially equivalent to the predicate device (Sure-Fine Insulin Syringes, K152879). The biggest difference between the modified device and predicate device is the addition of needle gauge (27G) and the addition of needle length (1/4"). The devices operate in the principles of a piston syringe fluid path is sterile (EO gas sterilization), Non-toxic, Non-pyrogenic and single use disposable.
This document is a 510(k) Pre-market Notification for "Sure-Fine Insulin Syringes." It focuses on demonstrating substantial equivalence to a previously cleared predicate device (K152879) rather than presenting a standalone study with acceptance criteria and device performance metrics in the typical sense of AI/software device evaluation.
The changes in the current device (K191531) compared to the predicate device (K152879) are primarily the addition of a new needle gauge (27G) and a new needle length (1/4").
Therefore, the "acceptance criteria" and "study" described in the document are about demonstrating that these new configurations and the overall modified device continue to meet established standards for insulin syringes.
Here's an analysis based on the provided document:
1. Table of Acceptance Criteria and Reported Device Performance
The document doesn't provide a typical "acceptance criteria" table with specific quantitative thresholds. Instead, it refers to compliance with recognized international standards for medical devices, which inherently contain the acceptance criteria for various tests. The "reported device performance" is essentially the finding that the device complies with these standards.
| Acceptance Criteria Category/Standard | Reported Device Performance |
|---|---|
| ISO 7864: Sterile hypodermic needles for single use – Requirements and test methods | Complies with ISO 7864 (for the added needle gauge/length) |
| ISO 9626: Stainless steel needle tubing for the manufacture of medical devices – Requirements and test methods | Complies with ISO 9626 (for the added needle gauge/length) |
| ISO 8537: Sterile single-use syringes, with or without needle, for insulin | Complies with ISO 8537 (for the overall device) |
| Biocompatibility (Conform ISO 10993-1) | Conforms to ISO 10993-1 |
| Sterilization method and S.A.L (Sterilized by ethylene oxide gas SAL = 10$^{-6}$) | Sterilized by ethylene oxide gas SAL = 10$^{-6}$ |
| Indications for Use | Substantially equivalent to the predicate device |
| Technological Characteristics | Substantially equivalent to the predicate device |
| Materials | Identical or substantially equivalent to predicate device |
| Design (Syringe and Needle) | Design features and sizing compared, found substantially equivalent, with additions of 27G needle gauge and 1/4" needle length. |
Note: The document states "appropriate testing was completed to demonstrate that the syringes comply with the following FDA recognized standards". It does not provide the raw data or specific test results for each of these standards in this summary. The "reported performance" is the claim of compliance.
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size: The document does not specify the sample sizes used for the testing conducted against the ISO standards. This information would typically be found in the full test reports, not in the 510(k) summary.
- Data Provenance: The document doesn't explicitly state the country of origin for the testing data itself, but the manufacturer is SHINA MED CORPORATION in South Korea (Rep. of Korea). The testing would presumably be conducted by or for the manufacturer, either in Korea or by a certified testing lab. The study is prospective in the sense that the testing was performed to support this specific submission for the modified device.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
- This question is not applicable to this type of device submission. Insulin syringes are physical medical devices, and their performance is evaluated through engineering and biological testing against established international standards (like ISO standards), not by human expert interpretation or ground truth labeling in the way an AI/software device would be.
4. Adjudication Method for the Test Set
- This question is not applicable. There is no "test set" that requires adjudication by human experts. Device performance is determined by objective measurements against specified physical and chemical properties and functional requirements outlined in the ISO standards.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
- This question is not applicable. This submission is for an insulin syringe, which is a physical medical device, not an AI/software device that involves human readers or AI assistance.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
- This question is not applicable. This is not an algorithm or AI device.
7. The Type of Ground Truth Used
- The "ground truth" for this device's performance is defined by the requirements and test methods specified in the referenced international standards (ISO 7864, ISO 9626, ISO 8537, ISO 10993-1). Compliance with these standards serves as the "ground truth" that the device is safe and effective for its intended use. For example, a needle's sharpness or a syringe's dose accuracy would be measured against specific, quantifiable criteria in these standards.
8. The Sample Size for the Training Set
- This question is not applicable. There is no "training set" as this is a physical medical device, not a machine learning model.
9. How the Ground Truth for the Training Set Was Established
- This question is not applicable. As there is no training set for a physical device.
In summary: The acceptance criteria and "study" for this device are based on demonstrating compliance with recognized international standards for medical devices, particularly those related to sterile hypodermic needles and insulin syringes. The document asserts that "appropriate testing was completed" to show this compliance, thereby proving the device meets the acceptance criteria for substantial equivalence to its predicate for its intended use, including the newly added specifications.
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September 6, 2019
Shina Med Corporation Park Sung-Soon Manager 455-30 Bogaewonsam-ro, Bogae-myun Anseong-si, 456-871 KOREA
Re: K191531
Trade/Device Name: Sure-Fine Insulin Syringes Regulation Number: 21 CFR 880.5860 Regulation Name: Piston syringe Regulatory Class: Class II Product Code: FMF Dated: August 6, 2019 Received: August 9, 2019
Dear Park Sung-Soon:
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 statutes and regulations administered by other Federal agencies. You must comply with all the Act's
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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 mediation-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,
Alan 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 Ouality Center for Devices and Radiological Health
Enclosure
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Indications for Use
510(k) Number (if known) K191531
Device Name Sure-Fine Insulin Syringes
Indications for Use (Describe)
Sure-fine Insulin Syringes are hypodermic insulin syringes for subcutaneous injection of U100 insulin.
Type of Use (Select one or both, as applicable)
| Prescription Use (Part 21 CFR 801 Subpart D)
|X | Over-The-Counter Use (21 CFR 801 Subpart C)
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Image /page/3/Picture/1 description: The image shows the logo for SHINA MED CORPORATION. The logo consists of a stylized circle with a wavy line at the bottom left, followed by the company name in bold, sans-serif font. The text is all capitalized and the logo is in black and white.
510(K) SUMMARY - K191531 September 6, 2019
1. Submitted by :
Sung-soon, Park / Quality Management Representative
SHINA MED CORPORATION
455-30, Bogaewonsam-ro Bogae-myeon, Anseong-si, Gyeonggi-do, 17509, Rep. of Korea
Phone : +82 31 8057 2125 Fax : + 82 31 8057 2150
2. Device Name :
| - Trade Name | : | Sure-Fine Insulin Syringes |
|---|---|---|
| - Classification | : | Class II |
| - Classification Name | : | Piston syringe |
| - Product Code | : | FMF |
| - Regulation Number | : | 21 CFR 880.5860 |
| - Review Panel | : | General Hospital |
3. 510(k) Premarket Notification: K152879
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Image /page/4/Picture/1 description: The image shows the logo for SHINA MED CORPORATION. The logo consists of a stylized graphic to the left of the company name. The graphic appears to be a circle with a wavy line at the bottom. The company name is written in a bold, sans-serif font.
510(k) Premarket Notification
| CFR Title 21 Radiation-Emitting Products X-Ray Assembler Medsun Reports CLIA TPLC | |||
|---|---|---|---|
| New Search | Back To Search Results | ||
| Device Classification Name | Syringe, Piston | ||
| 510(K) Number | K152879 | ||
| Device Name | Sure-Fine Insulin Syringes | ||
| Applicant | SHINA MED CORPORATION455-30, BOGAWONSAM-RO BOGAE-MYUNAnseong-Si, KR 456-871 | ||
| Applicant Contact | Sung-Soon Park | ||
| Correspondent | LK CONSULTING GROUP USA, INC.2651 E CHAPMAN AVE STE 110Fullerton, CA 92831 | ||
| Correspondent Contact | Priscilla Chung | ||
| Regulation Number | 880.5860 | ||
| Classification Product Code | FMF | ||
| Date Received | 09/30/2015 | ||
| Decision Date | 09/09/2016 | ||
| Decision | Substantially Equivalent (SESE) | ||
| Regulation Medical Specialty | General Hospital | ||
| 510k Review Panel | General Hospital | ||
| Summary | Summary | ||
| Type | Traditional | ||
| Reviewed By Third Party | No |
Device Description: 4
4.1 Predicate Device Description(K152879)
Sure-fine Insulin syringes are designed for the subcutaneous injection of a desired dose of insulin.
The syringe has a graduated barrel, a plunger rod, needle cap, protective end cap and needle permanently affixed to the tip of the syringe with epoxy. The syringes are available in the following sizes and cap color.
| Category | Insulin syringe | Needle Gauge | Needle Length | Cap color | |
|---|---|---|---|---|---|
| Needle cap | Protective cap | ||||
| U-100 | 1/2cc and 1cc | 28Gauge | 1/2" | Orange | Orange or white |
| 3/10cc, 1/2cc and 1cc | 29Gauge | 1/2" | Orange | Orange or white | |
| 3/10cc, 1/2cc and 1cc | 30Gauge | 1/2" | Orange | Orange or white |
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Image /page/5/Picture/1 description: The image shows the logo for SHINA MED CORPORATION. The logo consists of a circle with a wavy line at the bottom left, followed by the text "SHINA MED CORPORATION" in bold, sans-serif font. The logo is simple and professional, and the text is easy to read.
| 3/10cc, 1/2cc and 1cc | 30Gauge | 5/16" | Orange | Orange or white |
|---|---|---|---|---|
| 3/10cc, 1/2cc and 1cc | 31Gauge | 5/16" | Orange | Orange or white |
4.2 Device description for Special 510(k), K191531
The modified Sure-Fine Insulin syringe is substantially equivalent to the predicate device (Sure-Fine Insulin Syringes, K152879). The biggest difference between the modified device and predicate device is the addition of needle gauge (27G) and the addition of needle length (1/4").
The design features and sizing of the components were compared and the Sure-Fine Insulin Syringe is found to be substantially equivalent to the predicate device. The similarity in design between modified Sure-Fine Insulin Syringes and the previous device supports the substantial equivalence of Sure-Fine Insulin Syringe for the indicated use.
Therefore, modified Sure-Fine Insulin Syringe is substantially equivalent to the previous device in terms of indications, compositions, material, design, safety and effectiveness. The syringes are available in the following sizes and cap color.
| Category | Insulin syringe | NeedleGauge | NeedleLength | Cap color | |
|---|---|---|---|---|---|
| Needle cap | Protective cap | ||||
| U-100 | 3/10cc and 1/2cc | 30Gauge | 1/4" | Orange | Orange or white |
| U-100 | 3/10cc and 1/2cc | 31Gauge | 1/4" | Orange | Orange or white |
| U-100 | 1cc | 27Gauge | 1/2" | Orange | Orange or white |
The devices operate in the principles of a piston syringe fluid path is sterile (EO gas sterilization), Non-toxic, Non-pyrogenic and single use disposable.
4.3 Substantial Equivalence Discussion
Modified Sure-Fine Insulin syringe is substantially equivalent to the predicate Sure-Fine Insulin Syringes device(K152879).
The design features and sizing of the components were also compared and the Sure-Fine
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Insulin Syringe is substantially the same as the predicate device product. The similarity in design between modified Sure-Fine Insulin Syringes and the previous device supports the safety and effectiveness of Sure-Fine Insulin Syringe for the indicated use. The biggest difference between modified device and previous device is the addition of needle gauge (27G) and the addition of needle length (1/4").
Therefore, modified Sure-Fine Insulin Syringe is substantially equivalent to the previous device in terms of indications, compositions, material, design, safety and effectiveness.
| Device Name | Subject Device(Special 510(k)) | Predicate Device#1(Existing Traditional510(k)) | |
|---|---|---|---|
| Manufacturer | SHINA MED CORPORATION | SHINA MEDCORPORATION | |
| 510(k) Number | N/A | K152879 | |
| Product Code | FMF | FMF | |
| Intended Use | Sure-Fine Insulin Syringes arehypodermic insulin syringes forsubcutaneous injection of U100insulin. | Sure-Fine InsulinSyringes are hypodermicinsulin syringes forsubcutaneous injection ofU100 insulin. | |
| Design (Syringe) | Needle/ Barrel | Image: Needle / Barrel | Image: Needle / Barrel |
| Gasket/ Plunger | Image: Gasket / Plunger | Image: Gasket / Plunger | |
| NeedleCap | Image: Needle Cap | Image: Needle Cap | |
| Protectiveendcap | Image: Protective end cap | Image: Protective end cap | |
| Volume | 0.3cc, 0.5cc, 1.0cc | 0.3cc, 0.5cc, 1.0cc | |
| Design(Needle) | NeedleTipshape | Image: Needle Tip shape | Image: Needle Tip shape |
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Image /page/7/Picture/0 description: The image shows the logo for SHINA MED CORPORATION. The logo consists of a stylized graphic to the left of the company name. The company name is written in a bold, sans-serif font. The logo is simple and professional.
Special 510(K) Submission
| Gauge | 27, 30, 31 Gauge | 28, 29, 30,31Gauge | |
|---|---|---|---|
| Length | 1/2", 1/4" | 1/2", 5/16" | |
| Materials | Needle | STS304 | STS304 |
| Barrel | Polypropylene | Polypropylene | |
| Plunger | Polypropylene | Polypropylene | |
| Piston | Isoprene Rubber | Isoprene Rubber | |
| NeedleCap | Polyethylene | Polyethylene | |
| Protective end cap | Polyethylene | Polyethylene | |
| Silicon | Polydimethylsiloxane | Polydimethylsiloxane | |
| Biocompatibility | Conform ISO10993 -1 | Conform ISO10993-1 | Conform ISO10993-1 |
| Sterilization method and S.A.L | Sterilized by ethylene oxide gas SAL = $10^{-6}$ | Sterilized by ethylene oxide gas SAL = $10^{-6}$ | Sterilized by ethylene oxide gas SAL = $10^{-6}$ |
ട് Indication for Use :
Sure-Fine Insulin Syringes are hypodermic insulin syringes for subcutaneous injection of U100 insulin.
( The indication for use is substantially equivalent to the predicate device.)
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Special 510(K) Submission
Image /page/8/Picture/1 description: The image shows the logo for SHINA MED CORPORATION. The logo consists of a circle with a wavy line at the bottom left, followed by the text "SHINA MED CORPORATION" in bold, sans-serif font. The logo is simple and professional, and it is likely used to represent the company's brand.
6. Technological Characteristics :
Sure-fine insulin syringe and predicate device have the substantially equivalent technological characteristics and perform as piston syringes. Risks associated with the changes were identified and appropriate design controls implemented to mitigate the risks.
Based on the change assessment, it is concluded that the risks are associated with the mechanical performance of the needle. To mitigate these risks, appropriate testing was completed to demonstrate that the syringes comply with the following FDA recognized standards:
- ISO7864 Sterile hypodermic needles for single use Requirements and test methods ●
- . ISO9626 - Stainless steel needle tubing for the manufacture of medical devices -Requirements and test methods
- ISO8537 Sterile single-use syringes, with or without needle, for insulin .
8. Conclusion
Based on the information provided in this special 510(k), the Sure-fine insulin syringes are substantially equivalent to the previous devices (K152879).
§ 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).