(36 days)
It is intended for collection of capillary blood from the heel of newborn and premature babies. The lancet has equipped with safety protection features.
Promisemed Heel Blood Lancet is comprised of top upper cover, bottom cover, button, safety plug, slider, rod,holder, spring, blade.The spring provides an elastic force to puncture and ensure the blade can shrink back to the covers. The blade can be fired when the spring is under pressure. The safety plug is to protect the blade from triggering before use.
Promisemed Heel Blood Lancet is single use, sterile, medical devices designed to be used in collecting the blood sample. Heel Blood Lancet is intended to be used by professionals. They are offered in various lengths (0.65mm, 0.85mm, 1.50mm). The heel blood lancets are sterile (EO sterilization) and non-toxic. The product is intended for prescription (Rx) only.
The provided text describes a 510(k) premarket notification for a medical device called the "Promisemed Heel Blood Lancet." This document focuses on demonstrating substantial equivalence to an already legally marketed predicate device, rather than proving the device meets specific acceptance criteria through a clinical study with detailed performance metrics.
Therefore, the information you're requesting regarding acceptance criteria, a study that proves the device meets them, sample sizes, expert ground truth establishment, MRMC studies, standalone performance, and training set details are not explicitly present in this type of FDA submission for a Class I device seeking substantial equivalence.
Instead, the document details bench testing to show the new device performs comparably to the predicate device.
Here's a breakdown of what can be extracted and the limitations:
1. A table of acceptance criteria and the reported device performance:
No such table is provided. The acceptance criteria for Class I devices like this are generally based on meeting recognized consensus standards and performance characteristics comparable to predicates, primarily through bench testing.
The document lists performance characteristics tested:
- Material of blade
- Appearance
- Dimensions of product
- Blade corrosion resistance
- Bond between blade and shank
- Cutting width and depth
- Safety self-locking
- Safety plug pullout
- Shooting performance
- Sterility
- Limits acidity and alkalinity
- Total heavy Metal
- Accidental access to sharp once in safe mode
- Safety mechanism activation
- Safety overriding and unlocking force after activation
- Biocompatibility (based on ISO 10993)
The "reported device performance" is broadly stated as "the performance of the subject device is substantially equivalent in terms of critical performance characteristics to the predicate device" and that "Test results demonstrate that the subject device meets its intended use and performs as well as or better than the legally marketed predicate device." No quantitative results or comparative data are provided in this summary.
2. Sample sizes used for the test set and the data provenance:
- Sample Size for Test Set: Not specified. For bench testing, samples are usually a specific number of units, but this detail is not included in the summary.
- Data Provenance: The tests were "bench testing performed" internally or by a contracted lab. There is no mention of geographical data provenance (e.g., country of origin) or whether it was retrospective or prospective, as these are typically considerations for clinical data, not bench tests.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
This concept of "experts establishing ground truth" is not applicable here. Ground truth is typically established in clinical studies (e.g., for diagnostic AI where an expert's diagnosis is the truth). For a mechanical device like a lancet, the "truth" is whether it functions according to its specifications and relevant standards. This is evaluated through engineering and quality control tests, not by expert consensus on clinical findings.
4. Adjudication method for the test set:
Not applicable, as it's not a clinical study involving human interpretation.
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:
Not applicable. This device is a manual surgical instrument (a lancet), not an AI-powered diagnostic tool requiring human-in-the-loop studies.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
Not applicable, as it's not an AI algorithm.
7. The type of ground truth used:
The "ground truth" for this device would be its adherence to engineering specifications, performance standards, and regulatory requirements (e.g., sterility, precise dimensions, safety features functioning as intended). This is verified through objective measurements and validated test methods (bench testing).
8. The sample size for the training set:
Not applicable. This is not an AI/machine learning device.
9. How the ground truth for the training set was established:
Not applicable. This is not an AI/machine learning device.
In summary:
This 510(k) summary focuses on demonstrating that the Promisemed Heel Blood Lancet is substantially equivalent to a predicate device (K130132 BabyLance Heel Incision Device) based on shared technology, intended use, and materials, validated by bench testing for critical performance characteristics and biocompatibility. It does not present clinical trial data or performance metrics in the way one would for a novel diagnostic or AI-powered device.
§ 878.4850 Blood lancets.
(a)
Single use only blood lancet with an integral sharps injury prevention feature —(1)Identification. A disposable blood lancet intended for a single use that is comprised of a single use blade attached to a solid, non-reusable base (including an integral sharps injury prevention feature) that is used to puncture the skin to obtain a drop of blood for diagnostic purposes. The integral sharps injury prevention feature allows the device to be used once and then renders it inoperable and incapable of further use.(2)
Classification. Class II (special controls). The special controls are:(i) The design characteristics of the device must ensure that the structure and material composition are consistent with the intended use and must include a sharps injury prevention feature.
(ii) Mechanical performance testing must demonstrate that the device will withstand forces encountered during use and that the integral sharps injury prevention feature will irreversibly disable the device after one use.
(iii) The device must be demonstrated to be biocompatible.
(iv) Sterility testing must demonstrate the sterility of any device component that breaches the skin (
e.g., blade).(v) Labeling must include:
(A) Detailed descriptions, with illustrations, of the proper use of the device and its sharps injury prevention feature.
(B) Handwashing instructions for the user before and after use of the device.
(C) Instructions on preparation (
e.g., cleaning, disinfection) of the skin to be pierced.(D) Instructions for the safe disposal of the device.
(E) Labeling must be appropriate for the intended use environment.
(
1 ) For those devices intended for health care settings, labeling must address the health care facility use of these devices, including how these lancets are to be used with personal protective equipment, such as gloves.(
2 ) For those devices intended for use in the home, labeling must be written so that it is understandable to lay users.(vi) Labeling must also include the following statements, prominently placed:
(A) “For use only on a single patient. Discard the entire device after use.”
(B) “Warning: Not intended for more than one use. Do not use on more than one patient. Improper use of blood lancets can increase the risk of inadvertent transmission of bloodborne pathogens, particularly in settings where multiple patients are tested.”
(b)
Single use only blood lancet without an integral sharps injury prevention feature —(1)Identification. A disposable blood lancet intended for a single use that is comprised of a single use blade attached to a solid, non-reusable base that is used to puncture the skin to obtain a drop of blood for diagnostic purposes.(2)
Classification. Class II (special controls). The special controls are:(i) The design characteristics of the device must ensure that the structure and material composition are consistent with the intended use and address the risk of sharp object injuries and bloodborne pathogen transmissions.
(ii) Mechanical performance testing must demonstrate that the device will withstand forces encountered during use.
(iii) The device must be demonstrated to be biocompatible.
(iv) Sterility testing must demonstrate the sterility of any device component that breaches the skin (
e.g., blade).(v) Labeling must include:
(A) Detailed descriptions, with illustrations, of the proper use of the device.
(B) Handwashing instructions for the user before and after use of the device.
(C) Instructions on preparation (
e.g., cleaning, disinfection) of the skin to be pierced.(D) Instructions for the safe disposal of the device.
(E) Labeling must be appropriate for the intended use environment.
(
1 ) For those devices intended for health care settings, labeling must address the health care facility use of these devices, including how these lancets are to be used with personal protective equipment, such as gloves.(
2 ) For those devices intended for use in the home, labeling must be written so that it is understandable to lay users.(vi) Labeling must also include the following statements, prominently placed:
(A) “For use only on a single patient. Discard the entire device after use.”
(B) “Warning: Not intended for more than one use. Do not use on more than one patient. Improper use of blood lancets can increase the risk of inadvertent transmission of bloodborne pathogens, particularly in settings where multiple patients are tested.”
(c)
Multiple use blood lancet for single patient use only —(1)Identification. A multiple use capable blood lancet intended for use on a single patient that is comprised of a single use blade attached to a solid, reusable base that is used to puncture the skin to obtain a drop of blood for diagnostic purposes.(2)
Classification. Class II (special controls). The special controls are:(i) The design characteristics of the device must ensure that:
(A) The lancet blade can be changed with every use, either manually or by triggering a blade storage unit to discard the used blade and reload an unused blade into the reusable base; and
(B) The structure and material composition are consistent with the intended use and address the risk of sharp object injuries and bloodborne pathogen transmissions and allow for validated cleaning and disinfection.
(ii) Mechanical performance testing must demonstrate that the device will withstand forces encountered during use.
(iii) The device must be demonstrated to be biocompatible.
(iv) Sterility testing must demonstrate the sterility of any device component that breaches the skin (
e.g., blade).(v) Validation testing must demonstrate that the cleaning and disinfection instructions are adequate to ensure that the reusable lancet base can be cleaned and low level disinfected.
(vi) Labeling must include:
(A) Detailed descriptions, with illustrations, of the proper use of the device.
(B) The Environmental Protection Agency (EPA) registered disinfectant's contact time for disinfectant use.
(C) Handwashing instructions for the user before and after use of the device.
(D) Instructions on preparation (
e.g., cleaning, disinfection) of the skin to be pierced.(E) Instructions on the cleaning and disinfection of the device.
(F) Instructions for the safe disposal of the device.
(G) Instructions for use must address the safe storage of the reusable blood lancet base between uses to minimize contamination or damage and the safe storage and disposal of the refill lancet blades.
(H) Labeling must be appropriate for the intended use environment.
(
1 ) For those devices intended for health care settings, labeling must address the health care facility use of these devices, including how these lancets are to be used with personal protective equipment, such as gloves.(
2 ) For those devices intended for use in the home, labeling must be written so that it is understandable to lay users.(vii) Labeling must also include the following statements, prominently placed:
(A) “For use only on a single patient. Disinfect reusable components according to manufacturer's instructions between each use.”
(B) “Used lancet blades must be safely discarded after a single use.”
(C) “Warning: Do not use on more than one patient. Improper use of blood lancets can increase the risk of inadvertent transmission of bloodborne pathogens, particularly in settings where multiple patients are tested. The cleaning and disinfection instructions for this device are intended only to reduce the risk of local use site infection; they cannot render this device safe for use for more than one patient.”
(d)
Multiple use blood lancet for multiple patient use —(1)Identification. A multiple use capable blood lancet intended for use on multiple patients that is comprised of a single use blade attached to a solid, reusable base that is used to puncture the skin to obtain a drop of blood for diagnostic purposes.(2)
Classification. Class III (premarket approval).(3)
Date PMA or notice of completion of a PDP is required: A PMA or a notice of completion of a PDP is required to be filed with the Food and Drug Administration on or before May 22, 2024, for any multiple use blood lancet for multiple patient use described in paragraph (d)(1) of this section that was in commercial distribution before May 28, 1976, or that has, on or before May 22, 2024, been found to be substantially equivalent to a multiple use blood lancet for multiple patient use described in paragraph (d)(1) of this section that was in commercial distribution before May 28, 1976. Any other multiple use blood lancet for multiple patient use shall have an approved PMA or a declared completed PDP in effect before being placed in commercial distribution.