K Number
K192659
Date Cleared
2019-10-21

(26 days)

Product Code
Regulation Number
880.5725
Reference & Predicate Devices
N/A
Predicate For
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The Omnipod DASH Insulin Management System is intended for subcutaneous delivery of insulin at set and variable rates for the management of diabetes mellitus in persons requiring insulin.

Additionally, the Omnipod DASH System is interoperable with a compatible blood glucose meter to receive and display glucose measurements.

The Omnipod Insulin Management System is intended for subcutaneous delivery of insulin at set and variable rates for the management of diabetes mellitus in persons requiring insulin and for the quantitative measurement of glucose in fresh whole capillary blood (in vitro) from the finger.

The glucose measurements should not be used for the diagnosis of or screening for diabetes. The PDM glucose meter is intended for single-patient use and should not be shared.

Abbott FreeStyle test strips are used with the built-in FreeStyle meter for the quantitative measurement of blood glucose in fresh whole capillary blood from the finger, upper arm and palm. Abbott Freestyle Control Solutions are used to verify that the meter and test strips are working together properly and that the test is performed correctly.

Device Description

The subject devices provide for the management of insulin therapy by patients with diabetes mellitus. The devices are comprised of two primary components: the disposable insulin infusion pump (Pod) and an associated wireless remote controller referred to as the Personal Diabetes Manager (PDM). The PDMs incorporates a suggested bolus calculator which aids the user in determining the insulin bolus dosage needed based on carbohydrates ingested, most recent blood glucose reading, programmable correction factor, insulin to carbohydrate ratio, target blood glucose value, and Insulin on Board (IoB).

The Pod is a body-wearable insulin pump that affixes to the user on the back of the arm, the lower back or abdomen, the thigh area, or any site that has a layer of fatty tissue available. It is held in place by an adhesive pad and provides up to three days of insulin before it is removed and replaced with a new Pod. The PDM is a handheld device that controls the Pod. The user interfaces with the device system through the PDM, where they control basal and bolus delivery and various insulin program settings and calculations. The PDM also has a food library to assist with carbohydrate calculations, and it maintains several variables in a history log for the viewer to track their diabetes therapy. The Omnipod Insulin Management System PDM has an integrated blood glucose meter and communicates with the Pod using wirelessly using secure, low power, bi-directional radio frequency (RF) communications at 433.92MHz. The Omnipod DASH Insulin Management System PDM does not have an integrated blood glucose meter, but is interoperable with a compatible blood glucose meter to receive and display glucose measurements. The Omnipod DASH PDM communicates to the Pod and a compatible blood glucose meter using Bluetooth Low Energy.

The systems are for prescription use only.

AI/ML Overview

This document is a 510(k) premarket notification for the Omnipod Insulin Management System and Omnipod DASH Insulin Management System. It primarily discusses a labeling change to add Fiasp U100 insulin as compatible and asserts substantial equivalence to a previously cleared device (K182630). Therefore, the information typically found for acceptance criteria and a study proving device performance in a de novo or original 510(k) submission (which often includes specifics on a clinical trial or performance study with detailed metrics) is not present here.

Based on the provided document, I can extract the following relevant information regarding acceptance criteria and studies:

1. A table of acceptance criteria and the reported device performance

The document does not provide a table with specific quantitative acceptance criteria or detailed reported device performance metrics in the way a clinical study report would. Instead, it states that:

  • Acceptance Criteria Mentioned: "Verification activities, as required by the risk analysis, demonstrated that the predetermined acceptance criteria were met and the devices are safe for use." However, the specific criteria themselves are not listed.
  • Reported Device Performance:
    • "Drug Stability and Compatibility; In-use stability and leachables testing was conducted with Fiasp U100 insulin to verify and validate that the systems do not adversely affect the insulin."
    • "Fiasp stability testing in Omnipod Pods"
    • "Leachables study"

2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

The document does not specify the sample sizes for the stability and leachables testing, nor does it provide information about the provenance of the data (e.g., country of origin, retrospective or prospective nature).

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)

This information is not applicable to the type of testing described (drug stability and leachables) and is therefore not present in the document. These tests are laboratory-based and do not involve expert interpretation or ground truth establishment in the same way a diagnostic device might.

4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

This information is not applicable to the type of testing described (drug stability and leachables) and is therefore not present in the document.

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 information is not applicable. The device is an insulin management system, not an AI-assisted diagnostic tool requiring MRMC studies.

6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done

This information is not applicable in the context of the described modifications. The primary device function (insulin delivery) is not an algorithm-only standalone performance that would be assessed in this manner for the stated purpose of the submission. The "dose calculator" is mentioned within the context of the PDM, implying human interaction.

7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

For the stability and leachables testing, the "ground truth" would be established by scientific analytical methods (e.g., chemical assays, chromatography) to measure insulin degradation, chemical composition of leachates, and ensure the drug substance remains within predefined acceptable ranges, as per established pharmaceutical and medical device testing standards. The document does not explicitly detail these laboratory "ground truth" methods but refers to "Fiasp stability testing in Omnipod Pods" and a "Leachables study."

8. The sample size for the training set

The document describes a 510(k) submission for a modification (labeling change for compatible insulins) to existing devices. There is no mention of a "training set" as would be used for machine learning or AI algorithm development because that is not the nature of this submission. The testing described (stability, leachables) does not involve training sets.

9. How the ground truth for the training set was established

As there is no "training set" reported for this submission, this question is not applicable.

{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.

Insulet Corporation Julie Perkins Sr. Director, Regulatory Affairs/Quality Assurance 100 Nagog Park Acton, Massachusetts 01720

Re: K192659

Trade/Device Name: Omnipod Insulin Management System, Omnipod DASH Insulin Management System Regulation Number: 21 CFR 880.5725 Regulation Name: Infusion Pump Regulatory Class: Class II Product Code: LZG, NBW, NDC Dated: September 24, 2019 Received: September 25, 2019

Dear Julie Perkins:

We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.

Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal

{1}------------------------------------------------

statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to 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 CDR Nikhil Thakur 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

{2}------------------------------------------------

Indications for Use

510(k) Number (if known)

K192659

Device Name Omnipod DASH Insulin Management System

Indications for Use (Describe)

The Omnipod DASH Insulin Management System is intended for subcutaneous delivery of insulin at set and variable rates for the management of diabetes mellitus in persons requiring insulin.

Additionally, the Omnipod DASH System is interoperable with a compatible blood glucose meter to receive and display glucose measurements.

Type of Use (Select one or both, as applicable)
☒ Prescription Use (Part 21 CFR 801 Subpart D) □ Over-The-Counter Use (21 CFR 801 Subpart C)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

{3}------------------------------------------------

Indications for Use

510(k) Number (if known)

K192659

Device Name Omnipod Insulin Management System

Indications for Use (Describe)

The Omnipod Insulin Management System is intended for subcutaneous delivery of insulin at set and variable rates for the management of diabetes mellitus in persons requiring insulin and for the quantitative measurement of glucose in fresh whole capillary blood (in vitro) from the finger.

The glucose measurements should not be used for the diagnosis of or screening for diabetes. The PDM glucose meter is intended for single-patient use and should not be shared.

Abbott FreeStyle test strips are used with the built-in FreeStyle meter for the quantitative measurement of blood glucose in fresh whole capillary blood from the finger, upper arm and palm. Abbott Freestyle Control Solutions are used to verify that the meter and test strips are working together properly and that the test is performed correctly.

Type of Use (Select one or both, as applicable)
-------------------------------------------------

X Prescription Use (Part 21 CFR 801 Subpart D)

Over-The-Counter Use (21 CFR 801 Subpart C)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

{4}------------------------------------------------

Image /page/4/Picture/0 description: The image shows the logo for Omnipod Insulin Management System. The logo consists of a circular design made up of many small, evenly spaced lines, resembling a stylized sun or gear. Below the circular design, the word "omnipod" is written in lowercase letters, with the trademark symbol next to it, and below that, the words "INSULIN MANAGEMENT SYSTEM" are written in uppercase letters.

K192659 510(k) Summary

Date prepared:October 21, 2019
Submitter Name:Insulet Corporation
Submitter Address:FDA Establishment Owner/OperatorNumber:100 Nagog ParkActon, MA 017209056196
FDA Establishment RegistrationNumber:3014585508
Contact Person:Julie PerkinsSr. Director of Regulatory Affairs andQuality Assurance
Phone:(978) 600-7951(office)
Fax:(978) 600-0120
Device Trade / Proprietary Name:Omnipod® Insulin Management SystemOmnipod DASH™ Insulin ManagementSystem
Device Common Name:Regulation Description:Regulation Medical Specialty:Review Panel:Pump, Infusion, InsulinInfusion pumpGeneral HospitalGeneral Hospital
Product Code:LZG (Infusion Pump)NBW (System, Test, Blood Glucose,Over the Counter)NDC (Calculator, Drug Dose)
Submission Type:Regulation Number:Device Class:Device predicate:Traditional 510(k)880.5725Class IIK182630 Omnipod® InsulinManagement System,Omnipod DASH™ Insulin ManagementSystem

{5}------------------------------------------------

Image /page/5/Picture/0 description: The image shows the logo for Omnipod Insulin Management System. The logo consists of a circular design made up of many small, evenly spaced lines, resembling a stylized gear or ring. Below the circular design, the word "omnipod" is written in a lowercase, sans-serif font, with the trademark symbol "®" next to it. Underneath "omnipod", the words "INSULIN MANAGEMENT SYSTEM" are written in a smaller, sans-serif font.

Purpose of Submission:

Modification to K182630 Omnipod and Omnipod DASH Insulin Management Systems to address labeling change for compatible insulins.

Device Description:

The subject devices provide for the management of insulin therapy by patients with diabetes mellitus. The devices are comprised of two primary components: the disposable insulin infusion pump (Pod) and an associated wireless remote controller referred to as the Personal Diabetes Manager (PDM). The PDMs incorporates a suggested bolus calculator which aids the user in determining the insulin bolus dosage needed based on carbohydrates ingested, most recent blood glucose reading, programmable correction factor, insulin to carbohydrate ratio, target blood glucose value, and Insulin on Board (IoB).

The Pod is a body-wearable insulin pump that affixes to the user on the back of the arm, the lower back or abdomen, the thigh area, or any site that has a layer of fatty tissue available. It is held in place by an adhesive pad and provides up to three days of insulin before it is removed and replaced with a new Pod. The PDM is a handheld device that controls the Pod. The user interfaces with the device system through the PDM, where they control basal and bolus delivery and various insulin program settings and calculations. The PDM also has a food library to assist with carbohydrate calculations, and it maintains several variables in a history log for the viewer to track their diabetes therapy. The Omnipod Insulin Management System PDM has an integrated blood glucose meter and communicates with the Pod using wirelessly using secure, low power, bi-directional radio frequency (RF) communications at 433.92MHz. The Omnipod DASH Insulin Management System PDM does not have an integrated blood glucose meter, but is interoperable with a compatible blood glucose meter to receive and display glucose measurements. The Omnipod DASH PDM communicates to the Pod and a compatible blood glucose meter using Bluetooth Low Energy.

The systems are for prescription use only.

Indications for Use:

Omnipod Insulin Management System

{6}------------------------------------------------

Image /page/6/Picture/0 description: The image shows the Omnipod logo. The logo consists of a circular design made up of many small, vertical lines arranged in a ring. Below the circular design, the word "omnipod" is written in a lowercase, sans-serif font. Underneath "omnipod", the words "INSULIN MANAGEMENT SYSTEM" are written in a smaller, sans-serif font.

The Omnipod® Insulin Management System is intended for subcutaneous delivery of insulin at set and variable rates for the management of diabetes mellitus in persons requiring insulin and for the quantitative measurement of glucose in fresh whole capillary blood (in vitro) from the finger.

The glucose measurements should not be used for the diagnosis or screening for diabetes. The PDM glucose meter is intended for single patient use and should not be shared.

Abbott FreeStyle® test strips are used with the built-in FreeStyle meter for the quantitative measurement of blood glucose in fresh whole capillary blood from the finger, upper arm and palm. Abbott Freestyle Control Solutions are used to verify that the meter and test strips are working together properly and that the test is performed correctly.

Omnipod DASH Insulin Management System

The Omnipod DASH™ Insulin Management System is intended for subcutaneous delivery of insulin at set and variable rates for the management of diabetes mellitus in persons requiring insulin.

Additionally, the Omnipod DASH System is interoperable with a compatible blood glucose meter to receive and display glucose measurements.

Substantial Equivalence Discussion

Intended Use Comparison

The table below includes a comparison of the intended use between the new device and those of the predicate device:

CharacteristicPredicate DeviceDevice NameK182630Subject DeviceDevice NameK192659
Indications for UseOmnipod InsulinManagement SystemThe Omnipod® InsulinManagement System isintended for subcutaneousOmnipod InsulinManagement SystemThe Omnipod® InsulinManagement System isintended for subcutaneous
delivery of insulin at set andvariable rates for themanagement of diabetesmellitus in persons requiringinsulin and for thequantitative measurement ofglucose in fresh wholecapillary blood (in vitro)from the finger.delivery of insulin at set andvariable rates for themanagement of diabetesmellitus in persons requiringinsulin and for thequantitative measurement ofglucose in fresh wholecapillary blood (in vitro)from the finger.
The glucose measurementsshould not be used for thediagnosis or screening fordiabetes. The PDM glucosemeter is intended for singlepatient use and should not beshared.Abbott FreeStyle® test stripsare used with the built-inFreeStyle meter for thequantitative measurement ofblood glucose in fresh wholecapillary blood from thefinger, upper arm and palm.Abbott Freestyle ControlSolutions are used to verifythat the meter and test stripsare working togetherproperly and that the test isperformed correctly.The glucose measurementsshould not be used for thediagnosis or screening fordiabetes. The PDM glucosemeter is intended for singlepatient use and should not beshared.Abbott FreeStyle® test stripsare used with the built-inFreeStyle meter for thequantitative measurement ofblood glucose in fresh wholecapillary blood from thefinger, upper arm and palm.Abbott Freestyle ControlSolutions are used to verifythat the meter and test stripsare working togetherproperly and that the test isperformed correctly.
Omnipod DASH InsulinManagement SystemThe Omnipod DASH InsulinManagement System isintended for subcutaneousdelivery of insulin at set andvariable rates for theOmnipod DASH InsulinManagement SystemThe Omnipod DASH™Insulin Management Systemis intended for subcutaneousdelivery of insulin at set andvariable rates for the
mellitus in persons requiringinsulin.mellitus in persons requiringinsulin.
Additionally, the OmnipodDASH System isinteroperable with acompatible blood glucosemeter to receive and displayglucose measurements.Additionally, the OmnipodDASH System isinteroperable with acompatible blood glucosemeter to receive and displayglucose measurements.
Prescription OnlyorOver the CounterPrescription OnlyPrescription Only
IntendedPopulationGeneral UseGeneral Use
Environment ofUseHome UseHome Use

{7}------------------------------------------------

Image /page/7/Picture/0 description: The image shows the logo for Omnipod Insulin Management System. The logo features a circular design made up of many short, thick lines arranged in a ring shape. Below the circular design, the word "omnipod" is written in lowercase letters, with the registered trademark symbol next to it. Underneath "omnipod", the words "INSULIN MANAGEMENT SYSTEM" are written in smaller, uppercase letters.

{8}------------------------------------------------

Image /page/8/Picture/0 description: The image shows the Omnipod Insulin Management System logo. The logo features a circular design made of multiple lines, resembling a stylized ring or pod. Below the circular design, the word "omnipod" is written in a sans-serif font, with the registered trademark symbol next to it. Underneath "omnipod," the words "INSULIN MANAGEMENT SYSTEM" are written in smaller, sans-serif font.

Discussions of differences in Indications for Use statement The indications for use statement for the subject device is identical to the predicate device.

Discussions of differences in intended population

The intended population for the subject device is identical to the predicate device.

Discussions of differences in environment of use

The environment of use for the subject device is identical to the predicate device.

Summary of Technological Characteristics Compared to Predicate Devices:

The subject devices are identical to the predicate devices. The technological characteristics, design, energy source, principals of operation, and configuration of the Omnipod® and Omnipod DASH™ Insulin Management Systems have not changed from the devices cleared in K182630. The modification being proposed is to the labeling only to add Fiasp U100 as an insulin that has been tested for use with the Omnipod and Omnipod DASH Systems.

There have been no changes to the device materials, software, sterilization method, or packaging of the systems that is subject of this 510(k).

{9}------------------------------------------------

Image /page/9/Picture/0 description: The image shows the logo for Omnipod Insulin Management System. The logo consists of a circular design made up of many small, vertical lines arranged in a ring shape. Below the circular design, the word "omnipod" is written in lowercase letters, with a small "®" symbol next to it. Underneath "omnipod", the words "INSULIN MANAGEMENT SYSTEM" are written in smaller, uppercase letters.

Performance Data and Standards Compliance:

The following performance testing data were provided in support of the substantial equivalence determination.

  • . Drug Stability and Compatibility; In-use stability and leachables testing was conducted with Fiasp U100 insulin to verify and validate that the systems do not adversely affect the insulin.
  • Safety Assurance Case; An assurance case for each system was provided as recommended in the FDA Guidance: Infusion Pumps Total Product Life Cycle.

The stated goal of the Omnipod Insulin Management System safety assurance case is:

The Omnipod® Insulin Management System with blood glucose monitor and dose calculator is acceptably safe for the infusion of U100 insulin that is approved for use in pumps, for use in the home setting by people with diabetes mellitus who require insulin on a daily basis.

The stated goal of the Omnipod DASH Insulin Management System safety assurance case is:

The Omnipod DASH™ Insulin Management System with dose calculator is acceptably safe for the infusion of U100 insulin that is approved for use in pumps, for use in the home setting by people with diabetes mellitus who require insulin on a daily basis.

Additions to the safety assurance case from the predicate devices' cases include use of the device with Fiasp U100.

The following specific evidence was included within the assurance case to demonstrate that the subject device is verified and validated for its intended use and to demonstrate substantial equivalence to the predicate devices:

  • Fiasp stability testing in Omnipod Pods
  • Leachables study ●
  • Risk Management; was completed in accordance with ISO 14971:2007-● Medical Devices- Application of Risk Management to Medical Devices.

{10}------------------------------------------------

Image /page/10/Picture/0 description: The image shows the logo for Omnipod Insulin Management System. The logo consists of two parts: a circular design made of many short, parallel lines and the word "omnipod" in lowercase letters, with the trademark symbol next to it. Below the word "omnipod" is the text "INSULIN MANAGEMENT SYSTEM" in smaller, uppercase letters. The color of the logo is a dark blue.

Verification activities, as required by the risk analysis, demonstrated that the predetermined acceptance criteria were met and the devices are safe for use.

The Omnipod and Omnipod DASH Insulin Management Systems comply with the following standards as documented in the predicate devices (K182630) and in the applicable test reports provided in this 510(k) submission.

  • ISO 10993-1 (2009)- 4th Edition Biological Evaluation of Medical Devices- Part . 1: Evaluation and Testing within a Risk Management Process
  • ISO 14971 Second Edition 2007-03-01 Medical Devices- Application of Risk ● Management to Medical Devices

Substantial Equivalence Conclusion:

The subject Omnipod® and Omnipod DASH™ Insulin Management Systems use the same technology, modes of operation, and indications for use as the devices cleared in K182630. The differences between the predicate and the subject device do not raise any new or different questions of safety or effectiveness. The subject devices are substantially equivalent to the predicate devices with respect to the indications for use, target populations, treatment method, and technological characteristics.

§ 880.5725 Infusion pump.

(a)
Identification. An infusion pump is a device used in a health care facility to pump fluids into a patient in a controlled manner. The device may use a piston pump, a roller pump, or a peristaltic pump and may be powered electrically or mechanically. The device may also operate using a constant force to propel the fluid through a narrow tube which determines the flow rate. The device may include means to detect a fault condition, such as air in, or blockage of, the infusion line and to activate an alarm.(b)
Classification. Class II (performance standards).