K Number
K202060
Device Name
Disposable IV catheter
Date Cleared
2021-07-23

(361 days)

Product Code
Regulation Number
880.5200
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Disposable IV catheter is intended to be inserted into a Patient's peripheral vascular system for short term use to sample blood, monitor blood pressure, or administer fluids. These devices may be used for any patient with consideration given to adequacy of vascular anatomy, procedure being performed, fluids being infused, and duration of therapy. The 22-18 GA devices are suitable for use with power injectors set to a maximum pressure of 300 psi when access ports not suitable for use with power injectors are removed.
Device Description
The Safety Straight IV Catheter System is a safety device designed to minimize blood exposure. It includes a passive needle-shielding mechanism designed to reduce accidental needle stick injury. The system consists of the following key parts: protector, needle, catheter, catheter hub, wedge, catheter hub wings, needle hub, vent fitting, safety clip, lid, valve tube, actuator, anti-reflux valve. Straight IV Catheter System is the same as The Safety Straight IV Catheter System except for the safety device designed to minimize blood exposure. Safety Closed IV Catheter System is a safety device designed to minimize blood exposure. It includes a passive needle-shielding mechanism designed to reduce accidental needlestick injury. The closed system is designed to keep blood contained within the device throughout the insertion process, which may prevent potential exposure for clinicians and patients. The system consists of the following key parts: protector, needle, catheter, catheter hub, wedge, catheter hub wings, septum, needle hub, safety clip, needle shield, extension tubing, pinch clamp, Luer adapter with single port, vent fitting, heparin plug, needleless connector, Luer adapter with dual port. Closed IV Catheter System is the same as Safety Closed IV Catheter System except for the safety device designed to minimize blood exposure. The 18-22 gauge catheter systems are capable of withstanding high pressure injection procedures. Needleless Safety Closed IV Catheter System is a safety device designed to minimize blood exposure. It includes a passive needle-shielding mechanism designed to reduce accidental needlestick injury. The closed system is designed to keep blood contained within the device throughout the insertion process, which may prevent potential exposure for clinicians and patients. The system consists of the following key parts: protector, needle, catheter hub, wedge, catheter hub wings, septum, needle hub, safety clip, needle shield, extension tubing, pinch clamp, Luer adapter with single port, vent fitting, needleless connector, Luer adapter with dual port. Needleless Closed IV Catheter System is the same as Needleless Safety Closed IV Catheter System except for the safety device designed to minimize blood exposure. The 18-22 gauge catheter systems are capable of withstanding high pressure injection procedures.
More Information

Not Found

No
The device description and performance studies focus on the mechanical and material properties of the IV catheter system, with no mention of AI or ML capabilities.

Yes
The device is used to administer fluids, which means it delivers a substance for treatment, thereby performing a therapeutic function.

No.
The device's intended uses are to sample blood, monitor blood pressure, or administer fluids, which are not diagnostic functions in themselves but rather procedures that may precede or accompany diagnostic processes or therapeutic interventions.

No

The device description clearly outlines multiple physical components (protector, needle, catheter, etc.) and the performance studies refer to testing against physical standards, indicating it is a hardware device.

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

Here's why:

  • Intended Use: The intended use clearly states the device is for insertion into a patient's peripheral vascular system for purposes like sampling blood, monitoring blood pressure, or administering fluids. These are direct interactions with the patient's body for therapeutic or monitoring purposes.
  • IVD Definition: In vitro diagnostics are devices used to examine specimens (like blood, urine, or tissue) taken from the human body to provide information for diagnosis, monitoring, or screening. This device does not perform such examinations on specimens outside the body.
  • Device Description: The description details the physical components of a catheter system designed for insertion into a blood vessel. It does not describe any components or functions related to analyzing biological samples.

Therefore, this device falls under the category of a medical device used for direct patient care, not an in vitro diagnostic device.

N/A

Intended Use / Indications for Use

Disposable IV catheter is intended to be inserted into a Patient's peripheral vascular system for short term use to sample blood, monitor blood pressure, or administer fluids. These devices may be used for any patient with consideration given to adequacy of vascular anatomy, procedure being performed, fluids being infused, and duration of therapy. The 22-18 GA devices are suitable for use with power injectors set to a maximum pressure of 300 psi when access ports not suitable for use with power injectors are removed.

Product codes

FOZ

Device Description

  • a. The Safety Straight IV Catheter System is a safety device designed to minimize blood exposure. It includes a passive needle-shielding mechanism designed to reduce accidental needle stick injury. The system consists of the following key parts: protector, needle, catheter, catheter hub, wedge, catheter hub wings, needle hub, vent fitting, safety clip, lid, valve tube, actuator, anti-reflux valve.
  • Straight IV Catheter System is the same as The Safety Straight IV Catheter System except b. for the safety device designed to minimize blood exposure.
  • c. Safety Closed IV Catheter System is a safety device designed to minimize blood exposure. It includes a passive needle-shielding mechanism designed to reduce accidental needlestick injury. The closed system is designed to keep blood contained within the device throughout the insertion process, which may prevent potential exposure for clinicians and patients. The system consists of the following key parts: protector, needle, catheter, catheter hub, wedge, catheter hub wings, septum, needle hub, safety clip, needle shield, extension tubing, pinch clamp, Luer adapter with single port, vent fitting, heparin plug, needleless connector, Luer adapter with dual port.
  • Closed IV Catheter System is the same as Safety Closed IV Catheter System except for the d. safety device designed to minimize blood exposure. The 18-22 gauge catheter systems are capable of withstanding high pressure injection procedures.
  • e. Needleless Safety Closed IV Catheter System is a safety device designed to minimize blood exposure. It includes a passive needle-shielding mechanism designed to reduce accidental needlestick injury. The closed system is designed to keep blood contained within the device throughout the insertion process, which may prevent potential exposure for clinicians and patients. The system consists of the following key parts: protector, needle, catheter hub, wedge, catheter hub wings, septum, needle hub, safety clip, needle shield, extension tubing, pinch clamp, Luer adapter with single port, vent fitting, needleless connector, Luer adapter with dual port.
  • f. Needleless Closed IV Catheter System is the same as Needleless Safety Closed IV Catheter System except for the safety device designed to minimize blood exposure. The 18-22 gauge catheter systems are capable of withstanding high pressure injection procedures.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

peripheral vascular system

Indicated Patient Age Range

any patient population

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)

Non-clinical tests were conducted to verify that the proposed device met all design specifications as was Substantially Equivalent (SE) to the predicate device. The test results demonstrated that the proposed device complies with the following standards:

  • ISO 594-1:1986: Conical fittings with a 6 % (Luer) taper for syringes, needles and certain other medical equipment - Part 1: General requirements.
  • ISO 594-2:1998: Conical fittings with 6 % (Luer) taper for syringes, needles and certain other medical equipment - Part 2: Lock fittings.
  • ISO 9626:2016: Stainless steel needle tubing for the manufacture of medical devices. Requirements and test methods
  • ISO 10555-1: 2013 Intravascular catheters - Sterile and single-use catheters - Part 1: General requirements
  • ISO 10555-5: 2013 Intravascular catheters - Sterile and single-use catheters - Part 5: Over-needle peripheral catheters
  • ISO23908: 2011 Sharps injury protection - Requirements and test methods - Sharps protection features for single-use hypodermic needles, introducers for catheters and needles used for blood sampling.
  • ISO 80369-7: 2016 Small-bore connectors for liquids and gases in healthcare applications -Part 7 : Connectors for intravascular or hypodermic applications
  • ASTM F1980-07 Standard guide for accelerated aging of sterile barrier systems for medical device.
  • ISO 10993-3:2014 Biological evaluation of medical devices - Part 3: Tests for genotoxicity, carcinogenicity, and reproductive toxicity
  • ISO 10993-4:2017 Biological evaluation of medical devices--Part 4: Selection of tests for interactions with blood
  • ISO 10993-5:2009 Biological Evaluation of Medical Devices - Part 5: Tests for In Vitro Cytotoxicity.
  • ISO 10993-6:2016 Biological evaluation of medical devices -- Part 6: Tests for local effects after implantation
  • ISO 10993-7:2009 Biological Evaluation of Medical Device Part 7: Ethylene Oxide Sterilization residuals.
  • ISO 10993-10:2010 Biological Evaluation of Medical Devices - Part 10: Tests for irritation and skin sensitization.
  • ISO 10993-11:2017 Biological evaluation of medical devices - Part 11: Tests for systemic toxicity

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s)

K183399

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 880.5200 Intravascular catheter.

(a)
Identification. An intravascular catheter is a device that consists of a slender tube and any necessary connecting fittings and that is inserted into the patient's vascular system for short term use (less than 30 days) to sample blood, monitor blood pressure, or administer fluids intravenously. The device may be constructed of metal, rubber, plastic, or a combination of these materials.(b)
Classification. Class II (performance standards).

0

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July 23, 2021

Shinva Ande Healthcare Apparatus Co., Ltd. % Ray Wang General Manager Beijing Believe-Med Technology Service Co., Ltd Rm.912, Building #15, XiYueHui, No.5, YiHe North Rd. FangShan District, BeiJing 102401 China

Re: K202060

Trade/Device Name: Disposable IV catheter Regulation Number: 21 CFR 880.5200 Regulation Name: Intravascular Catheter Regulatory Class: Class II Product Code: FOZ Dated: June 17, 2021 Received: June 22, 2021

Dear Ray Wang:

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 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,

Payal Patel 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

2

Indications for Use

510(k) Number (if known) K202060

Device Name Disposable IV catheter

Indications for Use (Describe)

Disposable IV catheter is intended to be inserted into a Patient's peripheral vascular system for short term use to sample blood, monitor blood pressure, or administer fluids. These devices may be used for any patient with consideration given to adequacy of vascular anatomy, procedure being performed, fluids being infused, and duration of therapy. The 22-18 GA devices are suitable for use with power injectors set to a maximum pressure of 300 psi when access ports not suitable for use with power injectors are removed.

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

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3

K202060 510(k) Summary

Date of Preparation: 7/19/2021

Sponsor Identification

Shinva Ande Healthcare Apparatus Co., Ltd.

No.77 Development Zone North Road, Zibo, Shandong 255086, China Contact Person: Liang wanjie Position: Registrar Tel: +86-533-3917816 Fax: +86-533-3917815 Email: liangwanjie@andemed.com

Designated Submission Correspondent

Mr. Ray Wang

Beijing Believe-Med Technology Service Co., Ltd.

Rm.912, Building #15, XiYueHui, No.5, YiHe North Rd., FangShan District, BeiJing, China 102401

Tel: +86-18910677558 Fax: +86-10-52214696 Email: ray.wang@believe-med.com

Subject Device

Trade Name:Disposable IV Catheter
Regulation Name:Catheter, Intravascular, Therapeutic, Short-term less than 30 day
Regulation Name:21 CFR 880.5200
Product Code:FOZ
Device Class:Class II

Predicate Device: K183399, Nexiva IV Catheter System

4

Device Description

  • a. The Safety Straight IV Catheter System is a safety device designed to minimize blood exposure. It includes a passive needle-shielding mechanism designed to reduce accidental needle stick injury. The system consists of the following key parts: protector, needle, catheter, catheter hub, wedge, catheter hub wings, needle hub, vent fitting, safety clip, lid, valve tube, actuator, anti-reflux valve.
  • Straight IV Catheter System is the same as The Safety Straight IV Catheter System except b. for the safety device designed to minimize blood exposure.
  • c. Safety Closed IV Catheter System is a safety device designed to minimize blood exposure. It includes a passive needle-shielding mechanism designed to reduce accidental needlestick injury. The closed system is designed to keep blood contained within the device throughout the insertion process, which may prevent potential exposure for clinicians and patients. The system consists of the following key parts: protector, needle, catheter, catheter hub, wedge, catheter hub wings, septum, needle hub, safety clip, needle shield, extension tubing, pinch clamp, Luer adapter with single port, vent fitting, heparin plug, needleless connector, Luer adapter with dual port.
  • Closed IV Catheter System is the same as Safety Closed IV Catheter System except for the d. safety device designed to minimize blood exposure. The 18-22 gauge catheter systems are capable of withstanding high pressure injection procedures.
  • e. Needleless Safety Closed IV Catheter System is a safety device designed to minimize blood exposure. It includes a passive needle-shielding mechanism designed to reduce accidental needlestick injury. The closed system is designed to keep blood contained within the device throughout the insertion process, which may prevent potential exposure for clinicians and patients. The system consists of the following key parts: protector, needle, catheter hub, wedge, catheter hub wings, septum, needle hub, safety clip, needle shield, extension tubing, pinch clamp, Luer adapter with single port, vent fitting, needleless connector, Luer adapter with dual port.
  • f. Needleless Closed IV Catheter System is the same as Needleless Safety Closed IV Catheter System except for the safety device designed to minimize blood exposure. The 18-22 gauge catheter systems are capable of withstanding high pressure injection procedures.
CategoriesModelModel mark
Straight IV Catheter SystemType with wings but without injection portIVC01
Type without wings and injection portIVC03
Type with wings and injection portIVC04
Pen typeIVC05
Safety Straight IV Catheter SystemSafety type with wings but without injection portIVC06
Safety type without wings and injection portIVC07
Safety type with wings and injection portIVC08

Model(s):

5

Safety pen typeIVC09
Safety anti-reflux typeIVC02
Closed IV Catheter SystemClosed type with single portIVC10
Closed type with dual portIVC11
Safety closed type with single portIVC12
Safety Closed IV Catheter
SystemSafety closed type with dual port for Heparin plug and
Needleless connectorIVC13
Safety closed type with dual port for two Heparin plugIVC14
Needleless Closed IV
Catheter SystemNeedleless closed type with single port
Needleless closed type with dual portIVC16
Needleless Safety Closed
IV Catheter SystemNeedleless safety closed type with single portIVC17
Needleless safety closed type with dual portIVC18

Indications for Use Statement:

Disposable IV catheter is intended to be inserted into a Patient's peripheral vascular system for short term use to sample blood, monitor blood pressure, or administer fluids. These devices may be used for any patient population with consideration given to adequacy of vascular anatomy, procedure being performed, fluids being infused, and duration of therapy. The 22-18 GA devices are suitable for use with power injectors set to a maximum pressure of 300 psi when access ports not suitable for use with power injectors are removed.

6

Substantially Equivalent (SE) Comparison

ITEMProposed DevicePredicate Device K183399Remark
Indications for
Use StatementDisposable IV catheter is intended to be
inserted into a Patient's peripheral vascular
system for short term use to sample blood,
monitor blood pressure, or administer fluids.
These devices may be used for any patient
population with consideration given to
adequacy of vascular anatomy, procedure
being performed, fluids being infused, and
duration of therapy. The 22-18 GA devices
are suitable for use with power injectors set
to a maximum pressure of 300 psi when
access ports not suitable for use with power
injectors are removed.BD Nexiva closed IV catheter systems are
intended to be inserted into a Patient's
peripheral vascular system for short term use
to sample blood, monitor blood pressure, or
administer fluids. These devices may be used
for any patient population with consideration
given to adequacy of vascular anatomy,
procedure being performed, fluids being
infused, and duration of therapy. The 22-18
GA (0.9-1.3 mm) devices are suitable for use
with power injectors set to a maximum
pressure of 300 psi (2068 kPa) when access
ports not suitable for use with power
injectors are removed.SAME
Classification21CFR § 880.5200
Class II
FOZ -Catheter, intravascular, therapeutic,
short-term less than 30 days21CFR § 880.5200
Class II
FOZ -Catheter, intravascular, therapeutic,
short-term less than 30 days (primary)SAME
gauge sizes14G,16G,18G,20G,22G, 24G,26G18G, 20G, 22G, 24G,Analysis
Use with Power
InjectorsYes(18G, 20G, 22G)Yes(18G, 20G, 22G)SAME
Flashback
visualizationYesYesSAME
PackagingBlisterBlisterSAME
Single Sterile
WrappedYesYesSAME
SterilizationEthylene oxideEthylene oxideSAME
Table 1 General Comparison Table
--------------------------------------------

Analysis

The proposed device is different than the predicate device in Gauge Size, the proposed device has more specification of gauge size available than predicate device (14G, 16G, 26G). The difference gauge sizes is used for different clinical situations and for more choices to the physician. We have conducted bench testing to each gauge size, and the tests results meet the requirements of the recognized standards. This difference does not raise concerns of safety and effectiveness.

ITEMProposed DevicePredicate Device K183399Remark
NeedleStainless SteelStainless SteelSAME
CatheterPolyurethanePolyurethaneSAME
Catheter hub
wingsTPE/PPTPEAnalysis
Pinch ClamPolyoxymethyleneAcetalAnalysis
Extension
TubingPVC/PolyurethanePolyurethaneAnalysis
Luer AdapterCopolyesterCopolyesterSAME

Table 2 Device Materials Comparison Table

7

| Needleless

connectorPolycarbonate/ Silicone elastomerPolycarbonate/ Silicone (Q-Syte/ MaxZero)SAME
Heparin plug
bodyCopolyesterN/AAnalysis
Heparin plug
Injection PortPolyisoprene rubber(Rubber pad)N/AAnalysis

Analysis

The proposed device and the predicate device have different materials used for the Catheter hub wings, Pinch Clam, Extension tubing, heparin plug body and heparin plug. This difference may cause a biological risk. We have conducted biological evaluation and testing with the final device, which included whole materials of proposed device, and the results shown that there is no biological risk. This difference does not raise concerns of safety and effectiveness than the predicate device.

ITEMProposed DevicePredicate Device K183399Remark
Needlestick
injury
prevention
featureSafety Straight IV Catheter SystemYesNAAnalysis
Safety Closed IV Catheter System
Needleless Safety Closed IV
Catheter System
Straight IV Catheter System
Closed IV Catheter SystemNANASAME
Needleless Closed IV Catheter
System
Extension
tubing (closed)Straight IV Catheter SystemNAYesAnalysis
Safety Straight IV Catheter System
Closed IV Catheter SystemYesYesSAME
Safety Closed IV Catheter System
Needleless Closed IV Catheter
System
Needleless Safety Closed IV
Catheter System
PortSafety closed type with single portSingle portSingle Port with MaxZeroSAME
Needleless closed type with single
port
Needleless safety closed type with
dual portDual PortDual Port with Q-SyteSAME
Safety closed type with dual port for
Heparin plug and Needleless
connector
Needleless closed type with dual
port
Safety closed type with dual port for
two Heparin plugY Connection
(dual port) with
two PRN
adaptersY Connection (dual port) with two
PRN adaptersSAME
Closed type with dual port
Safety closed type with single portSingle portSingle portSAME
Closed type with single port
Type with wings but without
injection portSingle portSingle portSAME
Type without wings and injection
portSingle portSingle portSAME
Type with wings and injection portSingle port +
Injection PortSingle portAnalysis
Pen typeSingle portSingle portSAME
Safety type with wings but withoutSingle portSingle portSAME

Table 3 Primary Device Components Comparison Table

8

injection port
Safety type without wings and
injection portSingle portSingle portSAME
Safety type with wings and
injection portSingle port +
Injection PortSingle portAnalysis
Safety pen typeSingle portSingle portSAME
Safety anti-reflux typeSingle port +
Injection PortSingle portAnalysis

Analysis

The proposed device has a slightly different passive Needlestick injury prevention feature than the predicate device. We have conducted bench testing per ISO 23908 and the tests results meet the requirements of the recognized standards. This difference does not raise concerns of safety and effectiveness.

The proposed device is different than the predicate device in that it is available with and without Extension tubing, it will not affect the normal use of the product and does not change the intended use. Testing has been conducted in accordance with ISO 10555-1:2013, and the test results meet the standard requirements, so this difference does not raise concerns of safety and effectiveness.

The proposed device has an Injection Port, the predicate device does not have Injection port, this port is used for dosing during infusion, it will provide more choices to the physician for different clinical situations. We have conducted bench tests to this port (ISO 10555-1, Leakage Test). This difference does not raise concerns of safety and effectiveness.

ITEMProposed DevicePredicate Device K183399Remark
BioAccordance with ISO 10993 -1:2009 and
referencing FDA guidance entitled "Use of
International Standard ISO 10993- 1,
Biological evaluation of medical devices -
Part 1: Evaluation and testing within a risk
management process".Accordance with ISO 10993 -1:2009 and
referencing FDA guidance entitled "Use of
International Standard ISO 10993- 1,
Biological evaluation of medical devices -
Part 1: Evaluation and testing within a risk
management process".SAME
Power injection
testCatheter burst pressure exceeds the peak
pressure present in the catheter at maximum
flow conditions when tested according to ISO
10555-1:2013No detail test informationAnalysis
Flow rate testThe flow rate through catheter meets allowable
limits when tested according to ISO
10555-1:2013No detail test informationAnalysis
Vent fitting test
for the needle
hubThe needle hub with the packing part is
impervious to liquid infiltration when
subjected to positive pressure in accordance
with ISO 10555 - 5: 2013.No detail test informationAnalysis
Ease of
assembly
performance
testing for the
plungerThe plunger passes through the check valve
when tested according to ISO 594-2:1998No detail test informationAnalysis

Table 4 Performance Comparison Table

Analysis

Information about testing of predicate device performance is not available, so these tests are considered as different. We have conducted bench tests (ISO 10555-5, ISO 594-2), and the tests results meet the requirements of the recognized standards. These differences do not raise concerns of safety and effectiveness.

9

Non-clinical tests were conducted to verify that the proposed device met all design specifications as was Substantially Equivalent (SE) to the predicate device. The test results demonstrated that the proposed device complies with the following standards:

  • ISO 594-1:1986: Conical fittings with a 6 % (Luer) taper for syringes, needles and certain other medical equipment - Part 1: General requirements.

  • A ISO 594-2:1998: Conical fittings with 6 % (Luer) taper for syringes, needles and certain other medical equipment - Part 2: Lock fittings.
  • ♪ ISO 9626:2016: Stainless steel needle tubing for the manufacture of medical devices. Requirements and test methods
  • ISO 10555-1: 2013 Intravascular catheters - Sterile and single-use catheters - Part 1: General requirements

  • A ISO 10555-5: 2013 Intravascular catheters - Sterile and single-use catheters - Part 5: Over-needle peripheral catheters
  • ISO23908: 2011 Sharps injury protection - Requirements and test methods - Sharps protection features for single-use hypodermic needles, introducers for catheters and needles used for blood sampling.

  • A ISO 80369-7: 2016 Small-bore connectors for liquids and gases in healthcare applications -Part 7 : Connectors for intravascular or hypodermic applications
  • ASTM F1980-07 Standard guide for accelerated aging of sterile barrier systems for medical device.

  • ISO 10993-3:2014 Biological evaluation of medical devices - Part 3: Tests for genotoxicity, carcinogenicity, and reproductive toxicity

  • ISO 10993-4:2017 Biological evaluation of medical devices--Part 4: Selection of tests for interactions with blood

  • A ISO 10993-5:2009 Biological Evaluation of Medical Devices - Part 5: Tests for In Vitro Cytotoxicity.
  • ISO 10993-6:2016 Biological evaluation of medical devices -- Part 6: Tests for local effects after implantation

  • ISO 10993-7:2009 Biological Evaluation of Medical Device Part 7: Ethylene Oxide > Sterilization residuals.
  • ISO 10993-10:2010 Biological Evaluation of Medical Devices - Part 10: Tests for irritation and skin sensitization.

  • ISO 10993-11:2017 Biological evaluation of medical devices - Part 11: Tests for systemic toxicity

Clinical Test Conclusion

No clinical study is included in this submission.

10

Substantially Equivalent (SE) Conclusion

Based on the comparison and analysis above, the proposed device is determined to be Substantially Equivalent (SE) to the predicate device.