K Number
K211210
Device Name
Sterile Auto-Disable Syringes with/without Needle for Single Use
Date Cleared
2022-01-27

(279 days)

Product Code
Regulation Number
880.5860
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Sterile Auto-Disable syringes with/without needle for single use is used for aspiration of fluids from vials and ampoules and a variety of fluid injections below the surface of the skin except phlebotomy.
Device Description
The Sterile Auto-Disable syringes with/without needle for single use is a syringe with or without needle, sterile, single use hypodermic syringe with a 6% (Luer) male connector/lock fitting in various sizes. The 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. The main principle of the syringe is that after the injection is completed, the device automatically locks the plunger to prevent reuse.
More Information

Not Found

No
The device description and performance studies focus on mechanical and material properties, sterilization, and biocompatibility. There is no mention of AI, ML, image processing, or data-driven performance metrics.

No
The device is a syringe used for fluid aspiration and injection, which are procedures for administering or withdrawing substances, not for treating a disease or condition itself.

No

This device is a syringe for fluid injection and aspiration, primarily used for therapeutic purposes, not for diagnosing medical conditions.

No

The device description clearly outlines physical components (barrel, stopper, plunger rod, needle) and the performance studies focus on physical and material properties, not software validation.

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 used for "aspiration of fluids from vials and ampoules and a variety of fluid injections below the surface of the skin". This describes a procedure performed on a patient, not a test performed on a sample taken from a patient to diagnose a condition.
  • Device Description: The description details a syringe, which is a tool for administering or withdrawing substances from the body. It does not describe a reagent, instrument, or system used for testing biological samples.
  • Anatomical Site: The anatomical site is "Below the surface of the skin," indicating direct interaction with the patient's body. IVDs typically interact with samples like blood, urine, or tissue outside the body.
  • Performance Studies: The performance studies listed (ISO standards for syringes, biocompatibility, sterilization, packaging, shelf life) are relevant to a medical device used for injection/aspiration, not an IVD.

In vitro diagnostics are devices used to examine specimens, such as blood, tissue, or urine, that have been taken from the human body to detect diseases, conditions, or infections. This device does not fit that description.

N/A

Intended Use / Indications for Use

The Sterile Auto-Disable syringes with/without needle for single use is used for aspiration of fluids from vials and ampoules and a variety of fluid injections below the surface of the skin except phlebotomy.

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

FMF, FMF, FMI

Device Description

The Sterile Auto-Disable syringes with/without needle for single use is a syringe with or without needle, sterile, single use hypodermic syringe with a 6% (Luer) male connector/lock fitting in various sizes. The 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. The main principle of the syringe is that after the injection is completed, the device automatically locks the plunger to prevent reuse.

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
In accordance with ISO 10993-1, the device is classified as Externally Communicating Device, Blood Path Indirect, Limited Contac (

Sterilization, Shipping and shelf-life

  • EO sterilization validation per ISO11135:2014
  • Pyrogen testing per USP Bacterial Endotoxin Test
  • EO residuals per ISO 10993-7
  • Simulated shipping per ASTM D4169
  • Sterile Barrier Package testing performed on the proposed device:
    • Seal Strength ASTM F88/F88M-2015
    • Bubble leak testing ASTM D3078-02(2013)
    • Dye Penetration ASTM F1929-2015
  • Shelf life of 5 years validated using FDA recognized standards ASTM F1980-16 Standard Guide for Accelerated Aging of sterile barrier Systems for Medical Devices

Performance testing
Performance testing is performed according to the following standards:

  • ISO 7864:2016 Sterile hypodermic needles for single use Requirements and test A methods
  • A ISO 9626:2016, Stainless Steel Needle Tubing For The Manufacture of Medical Devices
  • ISO 80369-7:2016 Small-bore connectors for liquids and gases in healthcare applications — Part 7: Connectors for intravascular or hypodermic applications

  • ISO 7886-1:2017 Sterile hypodermic syringes for single use- Part 1: Syringes for manual use.

  • A ISO 7886-4:2018 sterile hypodermic syringes for single use — part 4: syringes with re-use prevention feature.

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.

K143497

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

§ 880.5860 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).

0

Image /page/0/Picture/0 description: The image contains the logos of the Department of Health & Human Services and the Food and Drug Administration (FDA). The Department of Health & Human Services logo is on the left, and the FDA logo is on the right. The FDA logo is a blue square with the letters "FDA" in white, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue.

January 27, 2022

Azur Medical Company Inc. Di Zhao General Manager 6710 Everglades Dr. Richmond, Virginia 23838

Re: K211210

Trade/Device Name: Sterile Auto-Disable Syringes with/without Needle for Single Use Regulation Number: 21 CFR 880.5860 Regulation Name: Piston Syringe Regulatory Class: Class II Product Code: FMF, FMF, FMI Dated: December 14, 2021 Received: December 21, 2021

Dear Di Zhao:

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 requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part

1

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 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,

CAPT Alan M. 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

2

Indications for Use

510(k) Number (if known) K211210

Device Name

Sterile Auto-Disable syringes with/without needle for single use

Indications for Use (Describe)

The Sterile Auto-Disable syringes with/without needle for single use is used for aspiration of fluids from vials and ampoules and a variety of fluid injections below the surface of the skin except phlebotomy.

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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3

K211210

510(k) summary

January 27, 2022

I Submitter

Device submitter: Azur Medical Company Inc. 6710 Everglades Dr., Richmond, Virginia, VA 23838, USA

Contract manufacturer: Zhejiang Kangkang Medical-Devices CO., Ltd. Longwang Industrial District, Chumen Town, Yuhuan, Zhejiang, 317605, China Registration number: 3015042030

Contact person: Di Zhao General Manager Phone: 928-5922380 Email: dzhao@azur-ppe.com

II Device

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

III Predicate Devices

Trade name:Safety Auto-Disable Syringe with Needle (Auto-Lock)
Common name:Piston Syringe
Classification:Class II, 21 CFR 880.5860
Product Code:MEG, FMF, FMI
Premarket Notification:K143497
Manufacturer:Guangdong Intmed Medical Appliance Co., Ltd.

IV Device description

The Sterile Auto-Disable syringes with/without needle for single use is a syringe with or without needle, sterile, single use hypodermic syringe with a 6% (Luer) male

4

connector/lock fitting in various sizes. The 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. The main principle of the syringe is that after the injection is completed, the device automatically locks the plunger to prevent reuse.

Syringe SizeNeedle GaugeNeedle Length
Available in 1ml, 2ml, 3ml, 5ml and 10ml.Available in 18G, 19G, 20G, 21G, 22G, 23G, 24G, 25G, 26G, 27G, 30GAvailable in 1/2", 5/8", 1", 1 1/4", 1 1/2"

V Indications for use

The Sterile Auto-Disable syringes with/without needle for single use is used for aspiration of fluids from vials and ampoules and a variety of fluid injections below the surface of the skin except phlebotomy.

VI Comparison of technological characteristics with the predicate devices

The Sterile Auto-Disable syringes with/without needle for single use have the same intended use, technology, design and performance specifications are either identical or substantially equivalent to existing legally marketed predicate devices. The differences between the Sterile Auto-Disable syringes with/without needle for single use and predicate devices do not alter suitability of the proposed device for its intended use.

Device featureSubject DevicePredicate Device K143497Comment
Indications for useThe Sterile Auto-Disable
syringes with/without needle
for single use is used for
aspiration of fluids from vials
and ampoules and a variety of
fluid injections below the
surface of the skin except
phlebotomy.The Safety Auto-Disable
Syringe with Needle
(Auto-Lock) is used for
aspiration of fluids from vials
and ampoules and a variety of
fluid injections below the
surface of the skin except
phlebotomy.
It has a detachable needle with
a dedicated fitting. The Safety
Auto-Disabled Syringe with
Needle (Auto-Lock) contains an
inner mechanism used to allowDifferent
Comment #1
Device featureSubject DevicePredicate Device K143497Comment
the needle to be retracted inside the plunger rod of the syringe after the operator's thumb force released. After activation the needle is fully contained inside the syringe guarding against accidental needle sticks during normal handling and disposal of the used needle/syringe combination.
Product codeFMF, FMIMEG, FMF, FMIDifferent
Comment #2
Regulation
number21 CFR 880.586021 CFR 880.5860Same
ClassIIIISame
Principle of
operationFor manual use onlyFor manual use onlySame
Safety FeaturesActive safety feature, manually
activated by userActive safety feature, manually
activated by userSame
Intended userMedical professionals and
trained care giversMedical professionals and
trained care giversSame
Environment of
useHospitals and clinicsHospitals and clinicsSame
Syringe volume1 ml, 3 ml, 5 ml, 10 ml1ml, 3ml, 5ml, 10mlSame
Nozzle typeLuer slip; Luer lockNeedle hub Luer connectorSame
LubricantSilicone oilPDMSSame
Barrel
transparencyTransparent and clearClear as required by
ISO 7886-1Same
Gradations
legibilityLegibleLegible according to
ISO 7886-1Same
Needle Length1/2", 5/8", 1", 1 1/4", 1 1/2"12-38mmSame
Needle Gauge18G, 19G, 20G, 21G, 22G,
23G, 24G, 25G, 26G, 27G,
30G21G, 22G, 23G, 24G, 25G,
26G, 27G, 28GDifferent
Comment #3
Configuration of
the tipShort bevel, long bevel.15 °C regular pointDifferent
Comment #4
Needle hubColor-coded per ISO 6009Colorless according to ISO
7864Same
Device featureSubject DevicePredicate Device K143497Comment
Single useYesYesSame
Performance
specificationsComplies with ISO 7864, ISO
7886-1, ISO 7886-4Conforms to ISO 7864, ISO
7886-1, ISO 7886-4Same
SterilizationEOEOSame
SAL10-610-6Same
MaterialsBarrel: PPBarrel: PolypropyleneDifferent
Comment #5
Plunger: PPPlunger: Polypropylene
Piston: Silicone RubberPiston: Isoprene rubber
Needle: Stainless steelNeedle Hub: Polypropylene
Needle hub: PPNeedle: Stainless Steel
Needle Sheath: Stainless Steel
O Ring: Silicone rubber
PyrogenNon-pyrogenicNon-pyrogenicSame
BiocompatibilityConforms to ISO 10993 See
belowConforms to ISO10993Same
LabelingMeet the requirements of 21
CFR Part 801Meet the requirements of 21
CFR Part 801Same

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

5

6

Comment #1

The subject device and the predicate device have the same intended use, to aspirate and inject fluids into a patient. The predicate device has a needle safety feature which after use allows the needle to be encapsulated into the plunger rod of the syringe to prevent needle sticks, thus preventing re-use of the syringe. The subject device does not have a needle safety feature but has a disc on the plunger which could be stuck by the buckle of the syringe to prevent re-use of the syringe. The subject device and the predicate device both have the same intended use, this difference does not affect the clinical safety of the subject device.

Comment #2

The subject device and the predicate device are both syringes that render the syringe unusable after injection, the predicate device also has a needle safety feature.

Comment #3

The subject device is available in gauges 18g-30g and the predicate device is available in Performance testing was done per ISO 9626 and ISO 7864 done to 21g-28g. demonstrate that the differences in needle gauges do not affect the clinical safety or effectiveness of the devices.

Comment #4

7

The bevel of subject device is different from the predicate device. However, this difference does not affect intended use. The difference was addressed through ISO 9626 and ISO 7864. Therefore, the differences on bevel do not raise different question of safety and effectiveness.

Comment #5

The material of subject device is different from the predicate device. The piston of subject device is silicone rubber while the predicate device is isoprene rubber. The configurations of subject device do not include Needle Sheath compared with predicate device, which was not affect intended use and did not introduce new materials. However, the materials of subject device were demonstrated to be equivalently biocompatible by the biocompatibility tests done. Therefore, the differences on materials do not raise new questions about safety and effectiveness.

VII Performance Testing

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

Biocompatibility testing

In accordance with ISO 10993-1, the device is classified as Externally Communicating Device, Blood Path Indirect, Limited Contac ( ●

Sterilization, Shipping and shelf-life

  • . EO sterilization validation per ISO11135:2014
  • . Pyrogen testing per USP Bacterial Endotoxin Test
  • EO residuals per ISO 10993-7 ●
  • . Simulated shipping per ASTM D4169
  • Sterile Barrier Package testing performed on the proposed device: .
    • o Seal Strength ASTM F88/F88M-2015
    • o Bubble leak testing ASTM D3078-02(2013)
    • o Dye Penetration ASTM F1929-2015
  • . Shelf life of 5 years validated using FDA recognized standards ASTM F1980-16 Standard Guide for Accelerated Aging of sterile barrier Systems for Medical

8

Devices

Performance testing

Performance testing is performed according to the following standards:

  • ISO 7864:2016 Sterile hypodermic needles for single use Requirements and test A methods
  • A ISO 9626:2016, Stainless Steel Needle Tubing For The Manufacture of Medical Devices
  • ISO 80369-7:2016 Small-bore connectors for liquids and gases in healthcare applications — Part 7: Connectors for intravascular or hypodermic applications

  • ISO 7886-1:2017 Sterile hypodermic syringes for single use- Part 1: Syringes for manual use.

  • A ISO 7886-4:2018 sterile hypodermic syringes for single use — part 4: syringes with re-use prevention feature.

VIII Conclusion

The differences between the predicate and subject device do not raise any new or different questions of safety or effectiveness. The Sterile Auto-Disable syringes with/without needle for single use are substantially equivalent to The Safety Auto-Disable Syringe with Needle (Auto-Lock) with respect to indications for use, target population, and technological characteristics.