K Number
K210065
Device Name
Verifine Safety Type Insulin Pen Needle
Date Cleared
2021-04-22

(101 days)

Product Code
Regulation Number
880.5570
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
Verifine Safety Type Insulin Pen Needle is intended for use with pen injector device for subcutaneous injection of insulin. Additionally, after withdrawal of the Verifine Safety Type Insulin Pen Needle from the body, the attached needle safety shield automatically covers the needle to minimize the risk of accidental needlestick.
Device Description
Verifine Safety Type Insulin Pen Needle is manufactured by Promisemed Hangzhou Meditech Co., Ltd, which is designed for use with a pen injector for the subcutaneous injection of insulin. The Verifine Safety Type Insulin Pen Needle consists of needle tube, trigger shield, spring, fixer, needle hub, needle container, UV glue and silicone oil. UV glue is used to glue needle tube and needle hub and the silicone oil is used to needle tube lubrication. The user proceeds with inserting the needle into the skin manually. Verifine Safety Type Insulin Pen Needle is designed to reduce occurrence of accidental needle sticks from patient end of the needle by providing a shield that covers and locks the needle after use. As the user proceeds with inserting the needle into the skin the shield will retract. After the injection is completed and needle is removed from the skin, the shield will automatically extend to cover the needle and lock in place. Once the Safety Type Insulin Pen Needle is in the locked mode, it can no longer be used. Verifine Safety Type Insulin Pen Needle is sterile with a Sterility Assurance Level (SAL) of 10-6, non-pyrogenic and single-use devices. It is supplied with several models. Different models are distinguished by needle gauge and length.
More Information

Not Found

No
The device description focuses on mechanical components and automatic shielding based on physical interaction, with no mention of AI or ML.

No.
This device is an insulin pen needle, which is used for subcutaneous injection of insulin. It facilitates the delivery of medication but does not itself provide a therapeutic effect. Its primary function is to enable the administration of a therapeutic substance (insulin) and to minimize the risk of accidental needlestick.

No.
The device is an insulin pen needle, used for subcutaneous injection of insulin, and designed to minimize accidental needlesticks. It is not used to diagnose a medical condition.

No

The device description clearly outlines physical components like needle tube, trigger shield, spring, fixer, needle hub, needle container, UV glue, and silicone oil, indicating it is a hardware device.

No, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • IVD Definition: In vitro diagnostics are tests performed on samples taken from the human body, such as blood, urine, or tissue, to detect diseases, conditions, or infections. They are used to diagnose, monitor, or screen for health issues.
  • Device Function: The Verifine Safety Type Insulin Pen Needle is a device used for the subcutaneous injection of insulin. It is a delivery mechanism for a medication, not a test performed on a sample from the body.
  • Intended Use: The intended use clearly states "for subcutaneous injection of insulin" and focuses on the safety feature to prevent needlestick injuries. This is a therapeutic delivery function, not a diagnostic one.
  • Device Description: The description details the physical components and how the needle is used for injection and then safely covered. There is no mention of analyzing a biological sample.
  • Performance Studies: The performance studies focus on the physical characteristics of the needle and its safety features (ISO standards related to needles and sharps injury protection), as well as biocompatibility. These are relevant to a device used for injection, not for in vitro testing.

Therefore, based on the provided information, the Verifine Safety Type Insulin Pen Needle is a medical device used for drug delivery and safety, not an in vitro diagnostic device.

N/A

Intended Use / Indications for Use

Verifine Safety Type Insulin Pen Needle is intended for use with pen injector device for subcutaneous injection of insulin.

Additionally, after withdrawal of the Verifine Safety Type Insulin Pen Needle from the body, the attached needle safety shield automatically covers the needle to minimize the risk of accidental needlestick.

Product codes (comma separated list FDA assigned to the subject device)

FMI

Device Description

Verifine Safety Type Insulin Pen Needle is manufactured by Promisemed Hangzhou Meditech Co., Ltd, which is designed for use with a pen injector for the subcutaneous injection of insulin.

The Verifine Safety Type Insulin Pen Needle consists of needle tube, trigger shield, spring, fixer, needle hub, needle container, UV glue and silicone oil. UV glue is used to glue needle tube and needle hub and the silicone oil is used to needle tube lubrication.

The user proceeds with inserting the needle into the skin manually. Verifine Safety Type Insulin Pen Needle is designed to reduce occurrence of accidental needle sticks from patient end of the needle by providing a shield that covers and locks the needle after use. As the user proceeds with inserting the needle into the skin the shield will retract. After the injection is completed and needle is removed from the skin, the shield will automatically extend to cover the needle and lock in place. Once the Safety Type Insulin Pen Needle is in the locked mode, it can no longer be used.

Verifine Safety Type Insulin Pen Needle is sterile with a Sterility Assurance Level (SAL) of 10-6, non-pyrogenic and single-use devices. It is supplied with several models. Different models are distinguished by needle gauge and length.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

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)

The bench testing performed verifies that the performance of the subject device is substantially equivalent in terms of critical performance characteristics to the predicate device. These tests include:

  • ISO 9626: Stainless steel needle tubing for the manufacture of medical devices - Requirements and test methods
  • ISO11608-2: Needle-based injection systems for medical use Requirements and test methods - Part 2: Needles
  • ISO 7864: Sterile hypodermic needles for single use - Requirements and test methods
  • ISO 23908: Sharps injury protection Requirements and test methods Sharps protection features for single-use hypodermic needles, introducers for catheters and needles used for blood sampling
  • Biocompatibility
    a. ISO 10993-1:2009 Biological Evaluation of Medical Devices -- Part 1: Evaluation and testing within a risk management process
    b. ISO 10993-5:2009 Biological Evaluation of Medical Devices -- Part 5: Tests for in Vitro Cytotoxicity
    c. ISO 10993-10:2010 Biological Evaluation of Medical Devices -- Part 10: Tests for Irritation and Skin Sensitization
    d. ISO 10993-11:2006, Biological evaluation of medical devices Part 11: Tests for systemic toxicity-Acute systemic toxicity and pyrogen test
    f. ASTM F756-13 Standard Practice for Assessment of Hemolytic Properties of Materials

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.

K161950

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

§ 880.5570 Hypodermic single lumen needle.

(a)
Identification. A hypodermic single lumen needle is a device intended to inject fluids into, or withdraw fluids from, parts of the body below the surface of the skin. The device consists of a metal tube that is sharpened at one end and at the other end joined to a female connector (hub) designed to mate with a male connector (nozzle) of a piston syringe or an intravascular administration set.(b)
Classification. Class II (performance standards).

0

Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

April 22, 2021

Promisemed Hangzhou Meditech Co., Ltd. % Wei Hsu Regulatory Manager Vee Care (Asia) Limited 17th Chung Pont Commercial Building, 300 Hennessy Road Hong Kong, Hong Kong China

Re: K210065

Trade/Device Name: Verifine Safety Type Insulin Pen Needle Regulation Number: 21 CFR 880.5570 Regulation Name: Hypodermic Single Lumen Needle Regulatory Class: Class II Product Code: FMI Dated: March 23, 2021 Received: March 23, 2021

Dear Wei Hsu:

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 Rumi Young 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) K210065

Device Name Verifine Safety Type Insulin Pen Needle

Indications for Use (Describe)

Verifine Safety Type Insulin Pen Needle is intended for use with pen injector device for subcutaneous injection of insulin.

Additionally, after withdrawal of the Verifine Safety Type Insulin Pen Needle from the body, the attached needle safety shield automatically covers the needle to minimize the risk of accidental needlestick.

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

Prescription Use (Part 21 CFR 801 Subpart D)

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

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510(k) Summary

Date Prepared ー

April 22nd, 2021

Submitter's Information 2

Submission Sponsor:

Name: Promisemed Hangzhou Meditech Co., Ltd.

Address:No. 1388 Cangxing Street, Canggian Community, Yuhang District,

Hangzhou City, 311121 Zhejiang, China

Contact Name: Zearou Yang

Telephone No.: +86 571 88772985

Fax No.: +86 571 88772985

Email Address: zearou.yang@promisemed.ca

Submission Correspondent:

Name: Vee Care (Asia) Limited

Address: 17F Chung Pont Commercial Building, 300 Hennessy Road, Hong Kong,

China

Contact Name: Wei-Shan Hsu

E-mail: ws@vee.com.hk

Trade Name, Common Name, Classification 3

Trade/Product Name: Verifine Safety Type Insulin Pen Needle

Common Name: Insulin Pen Needle

Classification name: Needle, Hypodermic, Single Lumen

Regulation Number: 21 CFR 880.5570

Device Class: Class II

Product Code: FMI

4 Identification of Predicate Device(s)

K161950: Verifine Safety Type Insulin Pen Needle

5 Description of the Device

4

Verifine Safety Type Insulin Pen Needle is manufactured by Promisemed Hangzhou Meditech Co., Ltd, which is designed for use with a pen injector for the subcutaneous injection of insulin.

The Verifine Safety Type Insulin Pen Needle consists of needle tube, trigger shield, spring, fixer, needle hub, needle container, UV glue and silicone oil. UV glue is used to glue needle tube and needle hub and the silicone oil is used to needle tube lubrication.

The user proceeds with inserting the needle into the skin manually. Verifine Safety Type Insulin Pen Needle is designed to reduce occurrence of accidental needle sticks from patient end of the needle by providing a shield that covers and locks the needle after use. As the user proceeds with inserting the needle into the skin the shield will retract. After the injection is completed and needle is removed from the skin, the shield will automatically extend to cover the needle and lock in place. Once the Safety Type Insulin Pen Needle is in the locked mode, it can no longer be used.

Verifine Safety Type Insulin Pen Needle is sterile with a Sterility Assurance Level (SAL) of 10-6, non-pyrogenic and single-use devices. It is supplied with several models. Different models are distinguished by needle gauge and length.

6 Indications for Use

Verifine Safety Type Insulin Pen Needle is intended for use with pen injector device for subcutaneous injection of insulin.

Additionally, after withdrawal of the Verifine Safety Type Insulin Pen Needle from the body, the attached needle safety shield automatically covers the needle to minimize the risk of accidental needlestick.

7 Performance Testing Summary

The bench testing performed verifies that the performance of the subject device is substantially equivalent in terms of critical performance characteristics to the predicate device. These tests include:

  • · ISO 9626: Stainless steel needle tubing for the manufacture of medical devices - Requirements and test methods

5

  • · ISO11608-2: Needle-based injection systems for medical use Requirements and test methods - Part 2: Needles · ISO 7864: Sterile hypodermic needles for single use - Requirements and test methods
  • · ISO 23908: Sharps injury protection Requirements and test methods Sharps protection features for single-use hypodermic needles, introducers for catheters and needles used for blood sampling
  • · Biocompatibility
    • a. ISO 10993-1:2009 Biological Evaluation of Medical Devices -- Part 1: Evaluation and testing within a risk management process
    • b. ISO 10993-5:2009 Biological Evaluation of Medical Devices -- Part 5: Tests for in Vitro Cytotoxicity
    • c. ISO 10993-10:2010 Biological Evaluation of Medical Devices -- Part 10: Tests for Irritation and Skin Sensitization
    • d. ISO 10993-11:2006, Biological evaluation of medical devices Part 11: Tests for systemic toxicity-Acute systemic toxicity and pyrogen test
    • f. ASTM F756-13 Standard Practice for Assessment of Hemolytic Properties of Materials

Similarities and Differences of the Proposed Devices to the 8 Predicate Devices

The Verifine Safety Type Insulin Pen Needle is substantially equivalent to the predicate device, the Verifine Safety Type Insulin Pen Needle (K161950) in that these devices have identical designs, methods of construction and operation, and indications for use. The differences from the predicate is the sterilization method. The differences above between the subject device and predicate device do not affect the basic design principle, usage of the subject device.

Subject DevicePredicate Device (K161950)
Trade NameVerifine Safety Type
Insulin Pen NeedleVerifine Safety Type Insulin Pen NeedleComments
ManufacturerPromisemed Hangzhou
Meditech Co., LtdPromisemed Hangzhou
Meditech Co., Ltd
Device ClassClass IIClass II
Same

A detailed comparison to the predicate is provided in Table 1.

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Product CodeFMIFMISame
Regulation number880.5570880.5570Same
Regulation NameNeedle,
Hypodermic,
Single LumenNeedle,
Hypodermic,
Single
LumenSame
Intended
Use/
Indications for UseThe Safety Type Insulin
Pen Needle is intended
for use with pen injector
device for subcutaneous
injection of insulin.
Additionally, after
withdrawal of the Safety
Type Insulin Pen Needle
from the body, the
attached needle safety
shield automatically
covers the needle to
minimize the risk of
accidental needlestick.The Safety Type Insulin Pen
Needle is intended for use with
pen injector device for
subcutaneous injection of
insulin.
Additionally, after withdrawal
of the Safety Type Insulin Pen
Needle from the body, the
attached needle safety shield
automatically covers the
needle to minimize the risk of
accidental needlestick.Same
Operating PrincipleAs the user proceeds with
inserting the needle into
the skin the shield will
retract. After the
injection is completed
and needle is removed
from the skin, the shield
will automatically extend
to cover the needle and
lock in place. Once the
Safety Type Insulin Pen
Needle is in the locked
mode, it can no longer be
used.As the user proceeds with
inserting the needle into the
skin the shield will retract.
After the injection is
completed and needle is
removed from the skin, the
shield will automatically
extend to cover the needle and
lock in place. Once the Safety
Type Insulin Pen Needle is in
the locked mode, it can no
longer be used.Same
GaugeG29, G30, G31G29, G30, G31Same
Needle Length4mm,5mm,6mm,8mm4mm,5mm,6mm,8mmSame
Sharps
Injury
Prevention
FeaturesTrigger shieldTrigger shieldSame
Configuration
and
MaterialNeedle Tube: X5CrNi18-
10Needle Tube: X5CrNi18-10Same
Needle Hub:
Polyformaldehyde (POM)Needle Hub: Polyformaldehyde
(POM)Same
Fixer: Polyformaldehyde
(POM)Fixer: Polyformaldehyde (POM)Same
Spring: 0Cr18Mn8Ni5NSpring: 0Cr18Mn8Ni5NSame
Needle container:Needle container:Same
Polypropylene (PP)Polypropylene (PP)Same
Trigger shield:
Acrylonitrile Butadiene
Styrene (ABS)Trigger shield: Acrylonitrile
Butadiene Styrene (ABS)Same
PerformanceComplied with ISO 7864,
ISO 9626, ISO 11608-2 and
ISO 23908Complied with ISO 7864, ISO
9626, ISO 11608-2 and ISO 23908Same
SterilizationEO SterilizationGamma SterilizationDifferent¹
been performed
(Appendix 16A).
A 5 years shelf-
life has been
validated
supported by
accelerated
aging testing
using EO
sterilized
product
(Appendix 16B).
SAL:10-6SAL:10-6Same
Shelf Life5 years5 yearsSame
Single useYesYesSame
BiocompatibilityComplied with ISO10993
series standards, and the
following tests are
performed
  • Cytotoxicity: No
    cytotoxicity
  • Skin Irritation: No
    evidence of skin irritation
  • Skin Sensitization: No
    evidence of sensitization
  • Acute Systemic
    Toxicity:No systemic
    toxicity
  • Hemolysis: No evidence
    of hemolysis
  • Pyrogen: No pyrogenic
  • Repeated exposure
    systemic toxicity: No
    systemic toxicity | Complied with ISO10993 series
    standards, and the following
    tests are performed
  • Cytotoxicity: No cytotoxicity
  • Skin Irritation: No evidence of
    skin irritation
  • Skin Sensitization: No
    evidence of sensitization
  • Acute Systemic Toxicity:No
    systemic toxicity
  • Hemolysis: No evidence of
    hemolysis
  • Pyrogen: No pyrogenic | Different2 |

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Justification for the differences: の

1) Different Sterilization

The proposed sterilization method for the subect device is Ethylene Oxide sterilization as opposed to the predicate device which is sterilized by Gamma Irradiation. This difference in sterilization does not raise any additional concerns of safety or effectiveness because the proposed device met the necessary biocompatibility and sterility testing requirements per ISO 10993.

    1. Different Biocompatibility
      In addition to the Biocompatibility testing of the predicate device, the subject device was tested for Repeated Exposure Systemic Toxicity due to the nature

8

of the device and the possibility of inadvertant reuse. This additional testing does not raise any additional concerns of safety or effectiveness.

10 Conclusion

Based on the information provided within this 510(k) submission, proposed Verifine Safety Type Insulin Pen Needle is substantially equivalent to the predicate device (K161950) and is as safe, as effective and performs as well as the legally marketed predicate device.