K Number
K203410
Date Cleared
2021-06-28

(221 days)

Product Code
Regulation Number
876.5980
Panel
GU
Reference & Predicate Devices
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

Wealy ENFit® Disposable Enteral Syringe is indicated for use as a dispenser, a measuring device, and a fluid transfer device. It is used to deliver fluids into the gastrointestinal system of a patient who is physically unable to eat and swallow. The enteral syringes are intended to be used in clinical or home care setting by users ranging from laypersons (under the supervision of a clinician) to clinicians, in all age groups.

Device Description

The proposed device is a disposable enteral feeding syringe provided in a variety of sizes from 1ml~100ml. This device incorporates a female ENFit® connector for connection to an enteral access device with male ENFit® connector. The proposed syringe is sterilized by Ethylene Oxide Gas to achieve a SAL of 10 ° and supplied sterility maintenance package which could maintain the sterility of the device during the shelf life of three years.

AI/ML Overview

The provided document is a 510(k) summary for the ENFit® Disposable Enteral Syringe. It focuses on demonstrating substantial equivalence to a predicate device rather than presenting a de novo study with specific acceptance criteria and detailed performance of an AI-powered diagnostic device. Therefore, many of the requested categories (expert ground truth, MRMC study, training set details) are not applicable as this is a medical device for fluid delivery, not an AI diagnostic.

However, I can extract the relevant information regarding acceptance criteria and performance based on the non-clinical tests described.

Here's a breakdown of the information that can be extracted from the provided text:

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

The document lists various tests based on international standards (ISO, ASTM, USP). The reported performance is generally stated as "The testing demonstrates the proposed devices conform to the requirements" or "Conforms to the requirement of [standard]". Specific quantitative acceptance criteria are given by referencing clauses within these standards, implying that the device met those quantitative values.

Acceptance Criteria Category (Referenced Standard/Clause)Reported Device Performance
ISO 80369-3:2016 (Connectors for enteral applications) & ISO 80369-20:2015 (Common test methods):The testing demonstrates the proposed devices conform to the requirements of ISO80369-3:2016.
Fluid Leakage (Annex B)Conforms
Sub-atmospheric pressure Air Leakage (Annex D)Conforms
Stress Cracking (Annex E)Conforms
Resistance to separation from axial load (Annex F)Conforms
Resistance to separation from unscrewing (Annex G)Conforms
Resistance to overriding (Annex H)Conforms
Disconnection by unscrewing (Annex I)Conforms
ISO 7886-1:2017 (Sterile hypodermic syringe for single use):The testing demonstrates the proposed devices conform to the requirements of ISO 7886-1:2017.
Appearance (Clause 5)Conforms
Overall Length of Scale to Nominal Capacity Line (Clause 9.3)Conforms
Push-button Distance (Clause 11)Conforms
Force to Operate the Plunger (Clause 13.3)Conforms
Freedom from air and liquid leakage past piston (Clause 13.2)Conforms
Limits for Acidity or Alkalinity (Clause 6.2)Conforms
Limits for Extractable Metals (Clause 6.3)Conforms
Tolerance on graduated capacity (Clause 8)Conforms
Dead Space (Clause 13.1)Conforms
Lubricant (Clause 7)Conforms
Cleanliness (Clause 5)Conforms
Graduated Scale (Clause 9)Conforms (Implied, listed under ISO 7886-1:2017 tests)
Barrel (Clause 11)Conforms (Implied, listed under ISO 7886-1:2017 tests)
Piston/Plunger Assembly (Clause 13)Conforms (Implied, listed under ISO 7886-1:2017 tests)
Biocompatibility Standards (ISO 10993 series):Conforms to the requirement of ISO 10993 series Standards. No Cytotoxicity, No Irritation to Skin, No significant evidence of sensitization. Biocompatibility testing has demonstrated the biological safety.
ISO 10993-5:2009 (Vitro Cytotoxicity)Conforms
ISO 10993-10:2010 (Irritation and skin sensitization)Conforms
ISO 10993-7:2008 (Ethylene oxide sterilization residuals)Conforms
ISO 10993-11:2017 (Systemic toxicity)Conforms
Other Tests:
ASTM F 88/F88M-09 (Seal strength of flexible barrier materials)Conforms
USP38-NF33 (Bacterial Endotoxins Limit)Conforms
Product performance after Real-time Aging testEvaluated properties after aging in support of labeling.
Package Integrity after Accelerated Aging testEvaluated properties after aging in support of labeling.
Sterilization (Ethylene Oxide Gas)Achieves SAL of 10^-6^ (for 3-year shelf life)

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 explicitly state the sample sizes used for each specific test in the non-clinical performance testing. It also does not specify the country of origin of the data (beyond the manufacturer being in China) or whether it was retrospective or prospective, as these are non-clinical hardware tests.

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)

Not applicable. This device is an enteral syringe for fluid delivery, not a diagnostic device requiring expert interpretation for ground truth.

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

Not applicable. This is not a diagnostic device involving expert adjudication.

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 not an AI diagnostic or image analysis tool, so an MRMC study is irrelevant.

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

Not applicable. This device does not involve an algorithm or AI.

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

For a medical device like a syringe, "ground truth" is established by adherence to recognized international performance standards (ISO, ASTM, USP). For example, the "ground truth" for fluid leakage would be the acceptable limits defined in ISO 80369-3, and the device passing means it met those objective, standardized measures. For biocompatibility, the ground truth is defined by the toxicological profiles and testing methods in the ISO 10993 series.

8. The sample size for the training set

Not applicable. This device does not use machine learning or AI, and therefore does not have a "training set."

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

Not applicable, as there is no training set for this type of device.

§ 876.5980 Gastrointestinal tube and accessories.

(a)
Identification. A gastrointestinal tube and accessories is a device that consists of flexible or semi-rigid tubing used for instilling fluids into, withdrawing fluids from, splinting, or suppressing bleeding of the alimentary tract. This device may incorporate an integral inflatable balloon for retention or hemostasis. This generic type of device includes the hemostatic bag, irrigation and aspiration catheter (gastric, colonic, etc.), rectal catheter, sterile infant gavage set, gastrointestinal string and tubes to locate internal bleeding, double lumen tube for intestinal decompression or intubation, feeding tube, gastroenterostomy tube, Levine tube, nasogastric tube, single lumen tube with mercury weight balloon for intestinal intubation or decompression, and gastro-urological irrigation tray (for gastrological use).(b)
Classification. (1) Class II (special controls). The barium enema retention catheter and tip with or without a bag that is a gastrointestinal tube and accessory or a gastronomy tube holder accessory is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 876.9.(2) Class I (general controls) for the dissolvable nasogastric feed tube guide for the nasogastric tube. The class I device is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to § 876.9.