K Number
K210227
Device Name
Sterile syringe for single use with/without needle
Date Cleared
2021-09-10

(225 days)

Product Code
Regulation Number
880.5860
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Sterile syringes for single use with/without needle are intended to be used for medical purposes to inject fluid into or withdraw fluid from body.
Device Description
The Sterile Syringes for Single Use with/without Needle are three-piece, sterile, single use hypodermic syringes with a 6% (Luer) male connector/lock fitting in various sizes. Each syringe assembly consists of a lubricated polypropylene barrel with a graduated scale, a lubricated synthetic rubber stopper and a polypropylene plunger rod. The plunger rod is pulled back to aspirate fluids or depressed to inject or expel fluids.
More Information

Not Found

No
The device description and performance studies focus on mechanical and material properties, with no mention of AI/ML or related concepts.

No
The device, a sterile syringe, is used to inject or withdraw fluids. It does not provide therapy itself but is a delivery mechanism or collection tool.

No

Explanation: The device description states its purpose is to "inject fluid into or withdraw fluid from body," which is a therapeutic or delivery function, not a diagnostic one. There is no mention of analysis, measurement, or detection of a medical condition.

No

The device description clearly outlines physical components (polypropylene barrel, synthetic rubber stopper, polypropylene plunger rod) and performance studies related to physical properties (biocompatibility, sterilization, shelf life, functional performance testing). There is no mention of software as the primary or sole component.

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

Here's why:

  • Intended Use: The intended use is "to inject fluid into or withdraw fluid from body." This describes a direct interaction with the body for therapeutic or diagnostic purposes in vivo (within the living organism).
  • Device Description: The description details a syringe, which is a tool for administering or collecting substances from or into the body.
  • Lack of IVD Characteristics: There is no mention of the device being used to examine specimens in vitro (outside the living organism) to provide information about a physiological state, health, or disease. IVDs typically involve analyzing blood, urine, tissue, or other body fluids in a laboratory setting.

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

The Sterile syringes for single use with/without needle are intended to be used for medical purposes to inject fluid into or withdraw fluid from body.

Product codes

FMF

Device Description

The Sterile Syringes for Single Use with/without Needle are three-piece, sterile, single use hypodermic syringes with a 6% (Luer) male connector/lock fitting in various sizes. Each syringe assembly consists of a lubricated polypropylene barrel with a graduated scale, a lubricated synthetic rubber stopper and a polypropylene plunger rod. The plunger rod is pulled back to aspirate fluids or depressed to inject or expel fluids.

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

Medical professionals and trained care givers; Hospitals and clinics.

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 following performance data were provided in support of the substantial equivalence determination:
Biocompatibility testing: Biocompatibility of the Sterile syringes for single use with/without needle was evaluated in accordance with ISO 10993-1:2018 for the body contact category of "External communication device - Blood path indirect" with a contact duration of "Limited ().

Sterilization and shelf life testing: The sterilization method has been validated per ISO 11135, which has thereby determined the routine control and monitoring parameters. The shelf life of the Sterile syringes for single use with/without needle is 3 years, determined based on stability studies which includes accelerated aging. EO residue and ECH residue tests were performed per ISO 10993-7:2008. Shelf Life Evaluation included physical performance, chemical performance and biological performance, including sterility, and single package seal strength test, creep/burst test, leakage test, gross leakage test and antibacterial performance test. These were conducted per ISO 11607, ASTM F1980-16, ASTM D 4169, ASTM F88/F88M-15, ASTM F1140/F1140M-13, ASTM F1929-15, ASTM F2096-11, and DIN 58953-6-2010.

Performance testing: Performance testing was performed according to ISO 7886-1: 2017, ISO 7864: 2016, ISO 80369-7:2016, and ISO 9626:2016 covering aspects such as cleanliness, limits for acidity or alkalinity, extractable metals, lubricant, tolerance on graduated capacity, scale, numbering of scales, overall length of scale to nominal capacity line, position of scale, dimensions, barrel flanges, design, conical fitting, position of nozzle on end of barrel, nozzle lumen, dead space, freedom from air and liquid leakage past plunger stopper, force to operate the piston, fit of plunger stopper/plunger in barrel, tubular needle designation, colour coding, needle hub, needle cap, needle tube, needle point, bond between tube and hub, patency of lumen, dimensional requirements for luer connectors, fluid leakage, sub-atmospheric pressure air leakage, stress cracking, resistance to separation from axial load, resistance to separation from unscrewing, resistance to overriding, surface finish and visual appearance, size designation, stiffness, resistance to breakage, and resistance to corrosion.

Key results: The Sterile Syringes for Single Use with/without Needle are substantially equivalent to its predicate device with respect to the indications for use, target populations, treatment method, and technological characteristics. The evaluation of biocompatibility testing items meets the requirements. Differences in syringe volume sizes and materials are addressed through testing per ISO 7886-1:2017 and biocompatibility testing per ISO 10993, respectively.

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

Not Found

Predicate Device(s)

K112057

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 880.5860 Piston syringe.

(a)
Identification. A piston syringe is a device intended for medical purposes that consists of a calibrated hollow barrel and a movable plunger. At one end of the barrel there is a male connector (nozzle) for fitting the female connector (hub) of a hypodermic single lumen needle. The device is used to inject fluids into, or withdraw fluids from, the body.(b)
Classification. Class II (performance standards).

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Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health and Human Services logo. To the right of that 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.

September 10, 2021

Zhejiang Kangkang Medical-Devices CO., Ltd. Chun Guo General Manager Longwang Industrial District, Chumen Town Yuhuan, Zhejiang 317605 China

Re: K210227

Trade/Device Name: Sterile syringe for single use with/without needle Regulation Number: 21 CFR 880.5860 Regulation Name: Piston Syringe Regulatory Class: Class II Product Code: FMF Dated: August 6, 2021 Received: August 12, 2021

Dear Chun Guo:

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.

1

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 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 Alan Stevens 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

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Indications for Use

510(k) Number (if known) K210227

Device Name

Sterile syringes for single use with/without needle

Indications for Use (Describe)

The Sterile syringes for single use with/without needle are intended to be used for medical purposes to inject fluid into or withdraw fluid from body.

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)

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K210227 510(k) Summary

Date

September 10, 2021

Submitter

Device submitter: Zhejiang Kangkang Medical-Devices CO., Ltd. Longwang Industrial District, Chumen Town, Yuhuan, Zhejiang, 317605, China

Contact person: Chun Guo General Manager Phone: 13586180908 / 89902728 Fax: 0576-87427630 Email: guochun@vip.126.com

Device

Trade Name of Device: Sterile syringes for single use with/without needle Common Name: Piston Syringe Regulation Number: 21 CFR 880.5860 Regulation Name: Piston Syringe Regulatory Class: II Product code: FMF Review Panel: General Hospital

Predicate Device

| Trade name: | Sterile Hypodermic Syringe for Single use with/without
Needle (used as Predicate Device)
Sterile Insulin Syringe for single use, with needle
Sterile Hypodermic Needle for single use |
|-------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Common name: | Piston Syringe |
| Classification: | Class II, 21 CFR 880.5860 |
| Product Code: | FMF |
| Premarket Notification: | K112057 |
| Manufacturer: | Shanghai Kindly Enterprise Division Group Company |

Device description

The Sterile Syringes for Single Use with/without Needle are three-piece, sterile, single use hypodermic syringes with a 6% (Luer) male connector/lock fitting in various sizes. Each syringe assembly consists of a lubricated polypropylene barrel with a graduated scale, a lubricated synthetic rubber stopper and a polypropylene plunger rod. The plunger rod is pulled back to aspirate fluids or depressed to inject or expel fluids.

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ItemsSpecification
Type of nozzleCentral nozzle (1, 2, 3, 5, 10ml),
Central nozzle or Eccentric nozzle (20, 30, 50, 60, 100ml)
StructureThree-piece structure
Color of needle
hubYellowGreyMediumBrownOrangePurpleMiddle blueBlackDeep greenYellowCreamPink
OD of needle
tube30G27G26G25G24G23G22G21G20G19 G18 G
Length of needle
tube1/2"5/8"1", 1 1/4", 1 1/2"
Length of needle
covers (mm)12.512.5,
16, 2516,
2516,
2525, 32, 38
Color of needle
coversTransparent
Type of wallNormal wall and thin wall
Blade angleShort bevel and long bevel

Indications for use

The Sterile Syringes for Single Use with/without Needle are intended to be used for medical purposes to inject fluid into or withdraw fluid from body.

Comparison of technological characteristics with the predicate devices

The Sterile Syringes for Single Use with/without Needle have the same intended use, technology, and are substantially equivalent to the predicate device. The differences between the Sterile Syringes for Single Use with/without Needle and the predicate device do not alter suitability of the proposed device for its intended use.

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Table 5-1 Substantial equivalence discussion – Sterile syringes for single use with/without needle

Device featureSubject DevicePredicate Device K112057
Indications for useThe Sterile Syringes for Single Use with/without Needle are intended to be used for medical purposes to inject fluid into or withdraw fluid from body.The Sterile Hypodermic Syringe for Single Use with/without needle is intended to be used for medical purposes to inject fluid into or withdraw fluid from body.
Product codeFMFFMF
Regulation number21 CFR 880.586021 CFR 880.5860
ClassIIII
Principle of operationFor manual use onlyFor manual use only
Intended userMedical professionals and trained care giversMedical professionals and trained care givers
Environment of useHospitals and clinicsHospitals and clinics
Syringe volume11ml, 2ml, 3ml, 5ml, 10ml, 20ml, 30ml, 50ml, 60ml, 100ml1ml, 3ml, 5ml, 6ml, 10ml, 20ml, 30ml, 35ml and 50ml
Nozzle typeLuer slip; Luer lockLuer slip; Luer lock
Lubricant for barrelSilicone oilSilicone oil
Barrel transparencyTransparent and clearTransparent and clear
GradationsLegibleLegible
legibility
Needle gauge18G, 19G, 20G, 21G, 22G, 23G, 24G, 25G, 26G, 27G, 30G18G, 19G, 20G, 21G, 22G, 23G, 24G, 25G, 26G, 27G, 28G, 29G, 30G
Needle hubColor-coded per ISO 6009Color-coded per ISO 6009
Single useYesYes
Performance specificationsComplies with ISO 7886-1:2017 Sterile Hypodermic syringes for single use - Part 1: Syringes for manual useComplies with ISO 7886-1:2017 Sterile Hypodermic syringes for single use - Part 1: Syringes for manual use
SterilizationEOEO
SAL10-610-6
Materials2Barrel: PP
Plunger: PP
Piston: Silicone Rubber
Needle: Stainless 304
Needle hub: PPBarrel: PP
Plunger: PP
Piston: Isoprene Rubber
Needle: Stainless 304
Needle hub: PP
PyrogenNon-pyrogenicNon-pyrogenic
BiocompatibilityThe biocompatibility evaluation for the subject device was conducted in accordance with the International Standard ISO 10993-1 "Biological Evaluation of Medical Devices - Part 1: Evaluation and Testing Within a Risk Management Process," as recognized by FDA and the "Use of International Standard ISO 10993-1 "Biological evaluation of medical devices- Part 1: Evaluation and testing within a risk management process", June 16, 2016. The syringe of testing included the following tests:
Cytotoxicity;
Skin sensitization;
Hemolysis;
Intracutaneous reactivity;
Acute systemic toxicity;
Pyrogenicity.
The evaluation of the above testing items meets the requirementsThe biocompatibility evaluation for the subject device was conducted in accordance with the International Standard ISO 10993-1 "Biological Evaluation of Medical Devices - Part 1: Evaluation and Testing Within a Risk Management Process,” as recognized by FDA and the "Use of International Standard ISO 10993-1 "Biological evaluation of medical devices- Part 1: Evaluation and testing within a risk management process", June 16, 2016. The syringe of testing included the following tests:
Cytotoxicity;
Skin sensitization;
Hemolysis;
Intracutaneous reactivity;
Acute systemic toxicity;
Pyrogenicity.
The evaluation of the above testing items meets the requirements
LabelingMeet the requirements of 21 CFR
Part 801Meet the requirements of 21 CFR Part
801

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  1. The subject device has larger syringe volume sizes. Differences are addressed through testing per ISO 7886-1:2017.

  2. There are material differences between the subject and predicate device. Differences are addressed through biocompatibility testing per ISO 10993.

Performance data

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

Biocompatibility testing

Biocompatibility of the Sterile syringes for single use with/without needle was evaluated in accordance with ISO 10993-1:2018 for the body contact category of "External communication device - Blood path indirect" with a contact duration of "Limited ( |

Sterilization and shelf life testing

The sterilization method has been validated per ISO 11135, which has thereby determined the routine control and monitoring parameters. The shelf life of the Sterile syringes for single use with/without needle is 3 years, determined based on stability studies which includes accelerated aging.

Sterilization and shelf life testing listed were performed on the proposed device.

EO residueISO 10993-7:2008
ECH residueISO 10993-7:2008
Shelf Life Evaluationphysical performance, chemical
performance and biological performance,
including sterility, and single package seal
strength test, creep/burst test, leakage test,
gross leakage test and antibacterial
performance test were performed

Shelf-Life Testing conducted per:

ISO 11607 Packaging for Terminally Sterilized Medical Devices

ASTM F1980-16 Standard Guide for Accelerated Aging of Sterile Barrier Systems for Medical Devices

ASTM D 4169 Standard Practice for Performance Testing of Shipping Containers and Systems ASTM F88/F88M-15 Standard Test Method for Seal Strength of Flexible Barrier Materials

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ASTM F1140/F1140M-13 Standard Test Methods for Internal Pressurization Failure Resistance of Unrestrained Packages

ASTM F1929-15 Standard Test Method for Detecting Deal Leaks in Porous Medical Packaging by Dye Penetration

ASTM F2096-11 Standard Test Method for Detecting Gross Leaks in Packaging by Internal Pressurization (Bubble Test)

DIN 58953-6-2010 Sterilization-Sterile Supply-Part 6: Microbial Barrier Testing of Packaging Materials for Medical Devices Which are to be Sterilized

Performance testing

Performance testing is performed according to the following standards:

ISO 7886-1: 2017
CleanlinessClause 6.1 of ISO 7886-1:2017
Limits for acidity or alkalinityClause 6.2 of ISO 7886-1:2017
Limits for extractable metalsClause 6.3 of ISO 7886-1:2017
LubricantClause 7 of ISO 7886-1:2017
Tolerance on Graduated capacityClause 8 of ISO 7886-1:2017
ScaleClause 9.1 of ISO 7886-1:2017
Numbering of scalesClause 9.2 of ISO 7886-1:2017
Overall length of scale to nominal
capacity lineClause 9.3 of ISO 7886-1:2017
Position of scaleClause 9.4 of ISO 7886-1:2017
DimensionsClause 10.1 of ISO 7886-1:2017
Barrel flangesClause 10.2 of ISO 7886-1:2017
DesignClause 11.1 of ISO 7886-1:2017
Conical fittingClause 12.1 of ISO 7886-1:2017 and
ISO 80369-7
Position of nozzle on end of barrelClause 12.2 of ISO 7886-1:2017
Nozzle lumenClause 12.3 of ISO 7886-1:2017
Dead SpaceClause 13.1 of ISO 7886-1:2017
Freedom from air and liquid leakage past
plunger stopperClause 13.2 of ISO 7886-1:2017
Force to operate the pistonClause 13.3 of ISO 7886-1:2017
Fit of plunger stopper/ plunger in barrelClause 13.4 of ISO 7886-1:2017
ISO 7864: 2016
CleanlinessClause 4.3 of ISO 7864: 2016
Limits for acidity or alkalinityClause 4.4 of ISO 7864: 2016
Limits for extractable metalsClause 4.5 of ISO 7864: 2016
Tubular needle designationClause 4.6 of ISO 7864: 2016
Colour codingClause 4.7 of ISO 7864: 2016
Needle hubClause 4.8 of ISO 7864: 2016, ISO
80369-7 and ISO 6009
Needle capClause 4.9 of ISO 7864: 2016
Needle tube (Tolerance on length,Freedom from defects, Lubricant)
Clause 4.10 of ISO 7864: 2016
Needle PointClause 4.11 of ISO 7864: 2016
Bond between Tube and HubClause 4.12 of ISO 7864: 2016
Patency of LumenClause 4.13 of ISO 7864: 2016
ISO 80369-7:2016
Dimensional requirements for luer
connectors.Clause 5 of ISO 80369-7: 2021
Fluid leakage (Positive pressure liquid
leakage)Clause 6.1.3 of ISO 80369-7: 2021
Sub-atmospheric pressure air leakageClause 6.2 of ISO 80369-7: 2021
Stress crackingClause 6.3 of ISO 80369-7: 2021
Resistance to separation from axial loadClause 6.4 of ISO 80369-7: 2021
Resistance to separation from
unscrewingClause 6.5 of ISO 80369-7: 2021
Resistance to overridingClause 6.6 of ISO 80369-7: 2021
ISO 9626:2016
Surface finish and visual appearanceClause 5.2 of ISO 9626:2016
CleanlinessClause 5.3 of ISO 9626:2016
Limits for acidity and alkalinityClause 5.4 of ISO 9626:2016
Size designationClause 5.5 of ISO 9626:2016
DimensionsClause 5.6 of ISO 9626:2016
StiffnessClause 5.8 of ISO 9626:2016
Resistance to breakageClause 5.9 of ISO 9626:2016
Resistance to corrosionClause 5.10 of ISO 9626:2016

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-Conclusion

The Sterile Syringes for Single Use with/without Needle are substantially equivalent to its predicate device with respect to the indications for use, target populations, treatment method, and technological characteristics. The differences between the predicate and the subject device do not raise any new or different questions of safety or effectiveness. Through functional performance testing and biocompatibility testing, the subject device has demonstrated substantial equivalence to the predicate device.