(80 days)
Not Found
No
The summary describes a mechanical infusion set with automatic needle retraction, and there is no mention of AI or ML capabilities.
No.
This device is an infusion set designed to deliver medication, not to treat a disease or condition itself. Therapeutic devices actively treat or mitigate a disease.
No
Explanation: The device is an infusion set used for administering medication, not for diagnosing medical conditions. Its function is to facilitate the delivery of substances into the body, not to detect or identify diseases or conditions.
No
The device description clearly states it is a sterile, non-pyrogenic, single use subcutaneous infusion set with a soft cannula and insertion device, indicating it is a physical hardware device.
Based on the provided information, this device is not an IVD (In Vitro Diagnostic).
Here's why:
- Intended Use: The intended use is for "subcutaneous infusion of medication administered by an external pump." This describes a device used to deliver substances into the body, not to test samples taken from the body.
- Device Description: The description details a sterile, single-use infusion set with a cannula and insertion mechanism. This aligns with a device for administering medication, not for performing diagnostic tests on biological samples.
- Lack of IVD Characteristics: The document does not mention any of the typical characteristics of an IVD, such as:
- Analyzing biological samples (blood, urine, tissue, etc.)
- Detecting or measuring substances in biological samples
- Providing information for diagnosis, monitoring, or treatment decisions based on sample analysis.
The device is clearly intended for the delivery of medication, which falls under the category of therapeutic or drug delivery devices, not in vitro diagnostics.
N/A
Intended Use / Indications for Use
The neria™ guard Infusion Set is indicated for subcutaneous infusion of medication administered by an external pump.
Product codes (comma separated list FDA assigned to the subject device)
FPA
Device Description
The neria™ guard Infusion Set manufactured by Unomedical is a sterile, non-pyrogenic, single use subcutaneous infusion set which includes a 90-degree soft cannula. It is delivered ready to use in a preloaded insertion device with automatic needle retraction. The product is indicated for subcutaneous infusion of medication.
The insertion needle and soft cannula of the neria™ guard Infusion Set are hidden from the user before, during and after insertion of the soft cannula. This feature helps prevents needle stick injuries as the device does not require loading with the needle is then automatically retracted after use.
Mentions image processing
Not Found
Mentions AI, DNN, or ML
Not Found
Input Imaging Modality
Not Found
Anatomical Site
Standard recommended sites for subcutaneous infusion of medication i.e. subcutaneous sites are selected based on the presence of adequate adipose tissue. The choice of insertion site depends on treatment and patient specific factors as recommended by HCP. Preference is given to sites that do not affect the patient's mobility, the insertion site has to be free of skin irritation and inflammation such as redness, scar tissue and bleeding. Site selection: the abdomen, in a roughly semicircular area around and below the umbilicus is preferred as an application site. Other insertion sites include the upper leg, upper buttocks, hips, upper arms and lower back and occasionally the chest when others sites have edema.
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)
As part of demonstrating safety and effectiveness of neria™ guard Infusion Set and in showing substantial equivalence to the predicate device, Unomedical completed a number of non-clinical performance tests. The neria™ guard Infusion Set meets all the requirements for overall design, sterilization, biocompatibility and usability confirming that the design inputs and specifications for the device.
The neria™ guard Infusion Set has met the requirements for testing in accordance with internal requirements, national standards, and international standards shown below to support substantial equivalence of the subject device:
- Sterilization Testing: The sterility of the neria™ guard Infusion Set is assured by using a validated sterilization method qualified in accordance with ISO 11135:2014.
- Biocompatibility testing: The biological safety of the neria™ guard Infusion Set was demonstrated by testing in accordance with ISO 10993-1:2009 and guidance document entitled Use of International Standard ISO-10993-1, "Biological Evaluation of Medical Devices: Part 1: Evaluation and Testing within a Risk Management Process" dated 16 June 2016. The battery of testing included the following tests: Cytotoxicity, Sensitization, Intracutaneous Reactivity/Irritation, Acute and 14-day Systemic toxicity, Material Mediated Pyrogenicity, Hemolysis, Particulate Testing, Chemical Characterization, Genotoxicity (AMES and MLA).
- Shelf Life Determination: A maximum shelf life of 3 years was determined based on an assessment of the seal integrity of the sterile barrier packaging and functional testing of the device in accordance with ASTM F1980:2011.
- Functional Testing: Placement Introducer Needle before and after activation, Tensile Test Base-Connector, Functional Test Adhesive Liner, Contents in Blister Package, Functional Test Serter, Tensile Test Needle Hub, Tensile Test Soft Cannula, Tensile Test Base-Adhesive Patch Peel Test, Packaging Disassemble fluid part from base, Disassemble base from cylinder, Serter Activation Force, Leak Test, Flow Test, Distance Introducer Needle bevel to Soft Cannula tip, Distance Soft Cannula tip to bottom fluid part, Visual Test of IFU, Blister Lid and Inner and Outer box label, Disassemble Cylinder from Cover, Drug Compatibility Testing, Tensile Strength Packaging and Labelling tests.
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.
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
§ 880.5440 Intravascular administration set.
(a)
Identification. An intravascular administration set is a device used to administer fluids from a container to a patient's vascular system through a needle or catheter inserted into a vein. The device may include the needle or catheter, tubing, a flow regulator, a drip chamber, an infusion line filter, an I.V. set stopcock, fluid delivery tubing, connectors between parts of the set, a side tube with a cap to serve as an injection site, and a hollow spike to penetrate and connect the tubing to an I.V. bag or other infusion fluid container.(b)
Classification. Class II (special controls). The special control for pharmacy compounding systems within this classification is the FDA guidance document entitled “Class II Special Controls Guidance Document: Pharmacy Compounding Systems; Final Guidance for Industry and FDA Reviewers.” Pharmacy compounding systems classified within the intravascular administration set are exempt from the premarket notification procedures in subpart E of this part and subject to the limitations in § 880.9.
0
Image /page/0/Picture/0 description: The image contains the logos of the Department of Health and Human Services and the Food and Drug Administration (FDA). The Department of Health and 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.
December 13, 2019
Unomedical a/s % Deirdre Barrow Senior Consultant. Regulatory Emergo Global Consulting, LLC 2500 Bee Cave Road, Building 1, Suite 300 Austin, Texas 78746
Re: K192647
Trade/Device Name: neria™ guard Infusion Set Regulation Number: 21 CFR 880.5440 Regulation Name: Intravascular Administration Set Regulatory Class: Class II Product Code: FPA Dated: September 23, 2019 Received: September 24, 2019
Dear Deirdre Barrow:
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
1
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 Geeta Pamidimukkala Acting 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
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Indications for Use
510(k) Number (if known) K192647
Device Name neria™ guard infusion set
Indications for Use (Describe)
The neria™ guard infusion set is indicated for subcutaneous infusion of medication administered by an external pump.
Type of Use (Select one or both, as applicable)
Z Prescription Use (Part 21 CFR 801 Subpart D)
[ ] Over-The-Counter Use (21 CFR 801 Subpart C)
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510(k)Summary
K192647
1. Submission Sponsor
Unomedical a/s
Aaholmvej 1-3, Osted
DK-4320 Lejre,
Denmark
Contact: Mette Henningsen
Title: Regulatory Affairs Specialist
2. Submission Correspondent
Emergo Global Consulting, LLC
2500 Bee Cave Road
Building 1, Suite 300
Austin, TX 78746
Office Phone: (512) 327.9997
Contact: Deirdre Barrow
Title: Senior Consultant, RA
3. Date Prepared
Dec-11-2019
4. Device Identification
Trade/Proprietary Name: neria™ guard Infusion Set
Common/Usual Name: Set, Administration, Intravascular
4
Classification Name: | Intravascular administration set |
---|---|
Regulation Number: | 880.5440 |
Product Code: | FPA, Intravascular administration set |
Device Class: | Class II |
Classification Panel: | General Hospital |
5. Legally Marketed Predicate Device(s)
Table 5A: Legally Marketed Predicate Device
| Device
Name | 510(k) No. | Product Code | Classification
Regulation | Classification
Name | Sponsor |
|---------------------------------------------------------------------------------------------------------------------------|------------|--------------|------------------------------|----------------------------------------|------------|
| Unomedical
Inset™
Subcutaneous
Infusion Set
(formerly
known asthe
Unomedical
Monica
Infusion Set) | K032854 | FPA | 880.5440 | Intravascular
administration
set | Unomedical |
6. Indication for Use Statement
The neria™ guard Infusion Set is indicated for subcutaneous infusion of medication administered by an external pump.
7. Device Description
The neria™ guard Infusion Set manufactured by Unomedical is a sterile, non-pyrogenic, single use subcutaneous infusion set which includes a 90-degree soft cannula. It is delivered ready to use in a preloaded insertion device with automatic needle retraction. The product is indicated for subcutaneous infusion of medication.
The insertion needle and soft cannula of the neria™ guard Infusion Set are hidden from the user before, during and after insertion of the soft cannula. This feature helps prevents needle stick injuries as the device does not require loading with the needle is then automatically retracted after use.
8. Substantial Equivalence Discussion
The following table compares the neria™ guard Infusion Set to the predicate device with respect to indications for use, principles of operation, technological characteristics, materials, and performance testing.
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It should be noted that the cannula from the subject device and the predicate are identical (same materials from the same suppliers, same manufacturing process, same intended use). Differences between the subject device and predicate device include difference in the insertion method, needle retraction mechanism, additional available lengths, and material differences.
6
Manufacturer | Unomedical | Unomedical | Device Comparison |
---|---|---|---|
Trade Name | neriaTM guard Infusion Set | Unomedical InsetTM Subcutaneous | |
Infusion Sets (formerly known as The | |||
Unomedical Monica Infusion Set) | |||
510(k) Number | K192647 | K032854 | N/A |
Product Code | FPA | FPA | Same |
Regulation Number | 880.5440 | 880.5440 | Same |
Regulation Name | Intravascular Administration Set | Intravascular Administration Set | Same |
Indications for Use | The neriaTM guard Infusion Set is | ||
indicated for subcutaneous infusion of | |||
medication administered by an | |||
external pump. | The Unomedical InsetTM Subcutaneous | ||
Infusion Sets are indicated for the | |||
subcutaneous infusion of medication | |||
from an external pump. | Similar- Difference in the name of the | ||
subject device. Does not impact safety | |||
or effectiveness | |||
Mechanism of Action | The neriaTM guard Infusion Set is an | ||
infusion administration set, connecting | |||
to a reservoir/infusion pump and | |||
inserted in the subcutaneous tissue of | |||
a user. | The Unomedical InsetTM Subcutaneous | ||
Infusion Set is an infusion | |||
administration set, connecting to a | |||
reservoir/infusion pump and inserted | |||
in the subcutaneous tissue of a user. | Same | ||
Technology | |||
Overview | Serter: | ||
• Subcutaneous insertion of soft | |||
cannula by introducer needle | |||
situated inside soft cannula at a 90° | |||
insertion angle. | Serter: | ||
• Subcutaneous insertion of soft | |||
cannula by introducer needle | |||
situated inside soft cannula at a 90° | |||
insertion angle. | Serter: | ||
• Same angle of insertion and use | |||
of introducer needle and cannula | |||
Manufacturer | Unomedical | Unomedical | Device Comparison |
Trade Name | neria™ guard Infusion Set | Unomedical Inset™ Subcutaneous | |
Infusion Sets (formerly known as The | |||
Unomedical Monica Infusion Set) | |||
• insertion of soft cannula: 2 user | |||
steps for insertion: remove | |||
protective cap for base and press | |||
release button | • insertion of soft cannula: 3 manual | ||
user steps for insertion: loading, | |||
inserting and retraction. | • Both devices use an insertion | ||
device to insert the soft cannula, | |||
the proposed device has an | |||
insertion mechanism preloaded | |||
and ready for insertion by simply | |||
pressing the activation button | |||
after removing the safeguard. This | |||
technical difference is not | |||
clinically significant as while this | |||
additional safety feature does | |||
have a minor impact upon the | |||
method of operation of the device | |||
it does not introduce any new | |||
questions of safety or | |||
effectiveness. | |||
• The Base Set in neria™ guard | |||
Infusion Set is made of two | |||
components, the Fluid Part and the | |||
Base Part | • The Base Set used in Unomedical | ||
inset™ is moulded as one | • The fluid part of the neria™ guard | ||
Infusion Set assembly is inserted | |||
into the base assembly (on body). | |||
This step is not required for the | |||
Unomedical inset™ Infusion Set. | |||
This technical difference is not | |||
clinically significant as the | |||
additional required step for the | |||
proposed device does not | |||
significantly impact the method of | |||
Manufacturer | Unomedical | Unomedical | Device Comparison |
Trade Name | neria™ guard Infusion Set | Unomedical Inset™ Subcutaneous | |
Infusion Sets (formerly known as The | |||
Unomedical Monica Infusion Set) | |||
• The neria™ guard Infusion Set is | |||
delivered ready to use in a pre- | |||
loaded insertion device with | |||
automatic needle retraction. The | |||
newly developed mechanism allows | |||
the needle to be hidden from the | |||
user and/or caregiver before and | |||
after insertion. | • The Unomedical Inset™ | ||
Subcutaneous Infusion Set does not | |||
have a mechanism for automatic | |||
needle retraction and the needle is | |||
visible to the user. | • The insertion needle and soft | ||
cannula of neria™ guard Infusion | |||
Set are hidden from the user | |||
before, during and after insertion | |||
of the soft cannula. This feature | |||
helps prevent needle stick injuries. | |||
This technical difference does not | |||
introduce any new questions | |||
regarding safety and effectiveness | |||
of the device. The additional | |||
safety feature does not impact the | |||
method of operation of the | |||
device. | |||
Administration Set: | |||
The administration set attaches to the | |||
reservoir by means of a "tubing | |||
connector", and subcutaneously in to | |||
the user through an indwelling | |||
catheter made of | |||
polytetrafluoroethylene (PTFE). The | |||
tubing is made of two layers: the inner | |||
layer is polyethylene; the outer is | |||
polyurethane. The indwelling catheter | |||
is introduced into the subcutaneous | Administration Set: | ||
The administration set attaches to the | |||
reservoir by means of a "tubing | |||
connector", and subcutaneously in to | |||
the user through an indwelling | |||
catheter made of | |||
polytetrafluoroethylene (PTFE). The | |||
tubing is made of two layers: the inner | |||
layer is polyethylene; the outer is | |||
polyurethane. The indwelling catheter | |||
is introduced into the subcutaneous | Same technology used in both | ||
devices for the administration set. It | |||
should be noted that the cannula | |||
from the subject device and the | |||
predicate are identical (same | |||
materials from the same suppliers, | |||
same manufacturing process, same | |||
sterilization, same intended use). | |||
Manufacturer | Unomedical | Unomedical | Device Comparison |
Trade Name | neriaTM guard Infusion Set | Unomedical InsetTM Subcutaneous | |
Infusion Sets (formerly known as The | |||
Unomedical Monica Infusion Set) | |||
tissue by a removable 27 gauge | |||
introducer needle (cannula) made of | |||
AISI 304 stainless steel. | tissue by a removable 27 gauge | ||
introducer needle (cannula) made of | |||
AISI 304 stainless steel. | |||
Anatomical Location | Standard recommended sites for | ||
subcutaneous infusion of medication | |||
i.e. subcutaneous sites are selected | |||
based on the presence of adequate | |||
adipose tissue. The choice of insertion | |||
site depends on treatment and patient | |||
specific factors as recommended by | |||
HCP. Preference is given to sites that | |||
do not affect the patient's mobility, | |||
the insertion site has to be free of skin | |||
irritation and inflammation such as | |||
redness, scar tissue and bleeding. | |||
Site selection: the abdomen, in a | |||
roughly semicircular area around and | |||
below the umbilicus is preferred as an | |||
application site. Other insertion sites | |||
include the upper leg, upper buttocks, | |||
hips, upper arms and lower back and | |||
occasionally the chest when others | |||
sites have edema. | Standard recommended sites for | ||
subcutaneous infusion of medication | |||
i.e. subcutaneous sites are selected | |||
based on the presence of adequate | |||
adipose tissue. The choice of insertion | |||
site depends on treatment and patient | |||
specific factors as recommended by | |||
HCP. Preference is given to sites that | |||
do not affect the patient's mobility, | |||
the insertion site has to be free of skin | |||
irritation and inflammation such as | |||
redness, scar tissue and bleeding. | |||
Site selection: the abdomen, in a | |||
roughly semicircular area around and | |||
below the umbilicus is preferred as an | |||
application site. Other insertion sites | |||
include the upper leg, upper buttocks, | |||
hips, upper arms and lower back and | |||
occasionally the chest when others | |||
sites have edema. | Same | ||
Manufacturer | Unomedical | Unomedical | Device Comparison |
Trade Name | neria™ guard Infusion Set | Unomedical Inset™ Subcutaneous | |
Infusion Sets (formerly known as The | |||
Unomedical Monica Infusion Set) | |||
particularly important in patients with | |||
many years use, since the overuse of | |||
skin sites has an influence on | |||
absorption variability. | particularly important in patients with | ||
many years use, since the overuse of | |||
skin sites has an influence on | |||
absorption variability. | |||
Material | Materials include: | ||
Polypropylene, polyoxymethylene, | |||
stainless steel, | |||
polytetraflouroethylene, nonwoven | |||
polyester/polyacrylate, | |||
polyethylene, silicone, Methyl | |||
Methacrylate Acrylonitrile Butadiene | |||
Styrene(MABS), Terlux 2802 HD, | |||
transp., medical grade paper, | |||
polycarbonate | Materials include: | ||
Polypropylene, Stainless Steel, | |||
Polyethylene, Polyurethane, Silicone, | |||
Polycarbonate, | |||
Polytetrafluoroethylene, Methyl | |||
Methacrylate Acrylonitrile Butadiene | |||
Styrene(MABS), Terlux 2802 HD, | |||
transp., Medical Grade Paper, UV- | |||
cured Glue, Colour Pigments | Differences in material were | ||
evaluated with the appropriate | |||
biocompatibility testing per ISO | |||
10993-1. | |||
Sterile | Yes – EO – SAL 10-6 | Yes – EO – SAL 10-6 | Same |
Single-Use | Yes | Yes | Same |
Shelf Life | 3 years | 3 years | Same |
Complies with ISO | |||
10993-1 | Yes | Yes | Same |
Soft Cannula Length | 6 and 9mm | 6 and 9mm | Same |
Tubing: | |||
ID | |||
OD | 0.385 mm, | ||
1.50 mm | 0.385 mm, | ||
1.50 mm | Same | ||
Soft Cannula OD | 0.68 mm | 0.68 mm | Same |
Manufacturer | Unomedical | Unomedical | Device Comparison |
Trade Name | neriaTM guard Infusion Set | Unomedical InsetTM Subcutaneous | |
Infusion Sets (formerly known as The | |||
Unomedical Monica Infusion Set) | |||
Needle Gauge | 27 gauge | 27 gauge | Same |
Tubing Length | 12 cm, 30 cm, 60 cm, 80 cm and 110 | ||
cm | 60 and 110 cm | Additional tubing lengths of 12, 30 | |
and 80 cm have been made available | |||
for the proposed device. Does not | |||
impact safety or effectiveness. | |||
Angle of Insertion | 90 degrees, perpendicular | 90 degrees, perpendicular | Same |
Insertion Method | Pre—loaded insertion device with | ||
automatic needle retraction. The | |||
insertion needle and soft cannula are | |||
hidden from the user before, during | |||
and after insertion of the soft cannula. | Insertion device, which enables the | ||
user not to place the soft cannula in | |||
the tissue manually | Similar in that both devices allow for | ||
the patient to not have to insert the | |||
device in the tissue manually - the | |||
proposed device includes an | |||
additional mechanism so that the | |||
patient does not need to see the | |||
needle or cannula at any stage of the | |||
process and has an automatic needle | |||
retraction to help ensure needle | |||
safety | |||
Time of Use | Up to 72 hours | Up to 72 hours | Same |
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8
9
10
11
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Non-Clinical Performance Data 9.
As part of demonstrating safety and effectiveness of neria™ guard Infusion Set and in showing substantial equivalence to the predicate device, Unomedical completed a number of non-clinical performance tests. The neria™ guard Infusion Set meets all the requirements for overall design, sterilization, biocompatibility and usability confirming that the design inputs and specifications for the device.
The neria™ guard Infusion Set has met the requirements for testing in accordance with internal requirements, national standards, and international standards shown below to support substantial equivalence of the subject device:
• Sterilization Testing
The sterility of the neria™ guard Infusion Set is assured by using a validated sterilization method qualified in accordance with ISO 11135:2014.
Biocompatibility testing .
The biological safety of the neria™ guard Infusion Set was demonstrated by testing in accordance with ISO 10993-1:2009 and guidance document entitled Use of International Standard ISO-10993-1, "Biological Evaluation of Medical Devices: Part 1: Evaluation and Testing within a Risk Management Process" dated 16 June 2016.
The battery of testing included the following tests:
- . Cytotoxicity
- Sensitization ●
- Intracutaneous Reactivity/Irritation
- Acute and 14-day Systemic toxicity
- Material Mediated Pyrogenicity ●
- Hemolysis
- Particulate Testing
- Chemical Characterization ●
- Genotoxicity (AMES and MLA)
. Shelf Life Determination
A maximum shelf life of 3 years was determined based on an assessment of the seal integrity of the sterile barrier packaging and functional testing of the device in accordance with ASTM F1980:2011.
13
● Functional Testing
Placement Introducer Needle before and after activation Tensile Test Base-Connector Functional Test Adhesive Liner Contents in Blister Package Functional Test Serter Tensile Test Needle Hub Tensile Test Soft Cannula Tensile Test Base-Adhesive Patch Peel Test Packaging Disassemble fluid part from base Disassemble base from cylinder Serter Activation Force Leak Test Flow Test Distance Introducer Needle bevel to Soft Cannula tip Distance Soft Cannula tip to bottom fluid part Visual Test of IFU, Blister Lid and Inner and Outer box label Disassemble Cylinder from Cover Drug Compatibility Testing Tensile Strength Packaging and Labelling tests
Standards used:
ISO 11135:2014; Sterilization of health-care products -- Ethylene oxide -- Requirements for the development, validation and routine control of a sterilization process for medical devices ASTM F1980:2011; Standard Guide or Accelerated Aging of Sterile Barrier Systems for Medical Devices
ISO 11607-1:2009; Packaging for terminally sterilized medical devices - Part 1: Requirements for materials, sterile barrier systems and packaging systems
ISO 10993-1:2009; Biological evaluation of medical devices -- Part 1: Evaluation and testing within a risk management process
ISO 14971:2012; Medical devices. Application of risk management to medical devices
ISO 10993-11:2006; Biological evaluation of medical devices -- Part 11: Tests for systemic cytotoxicity
ISO 11607-2:2006; Packaging for terminally sterilized medical devices -- Part 2: Validation requirements for forming, sealing and assembly processes
ASTM D4169-16; Standard Practice for Performance Testing of Shipping Containers and Systems
10. Conclusion
The neria™ guard Infusion Set, as designed and manufactured, is determined to be substantially equivalent to the predicate device.