K Number
K212033
Date Cleared
2022-08-17

(414 days)

Product Code
Regulation Number
880.5860
Reference & Predicate Devices
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The Sterile Hypodermic Syringe for Single Use with/without need for medical purposes to inject fluid into or withdraw fluid from body.

The sterile insulin syringe for single use with needle, with the callbration unit of insulin for U-100, is a device intended for medical purposes for the manual aspiration of insulin, and for the injection of insulin into parts of the body below the surface skin.

The sterile insulin syringe for single use with needle, with the callbration unit of insulin for U-40 is a device intended for medical purposes for the manual aspiration of insulin and for the injection of insulin into parts of the body below the surface skin.

The Sterile Hypodermic Needle for single use is intended for use with syringes and injection devices for general purpose fluid injection/aspiration.

Device Description
  • Disposable Sterile Syringe, with/without needle; luer/luer-lock: Piston, Plunger, Barrel. EO Sterilized. Prescription use. Single use. The plunger of syringe can be pulled and pushed along inside the barrel, allowing the syringe to take in and expel the fluids through the connector to the patient. Length 83-152mm, Diameter 50-31mm, Tip type luer/luer-lock, Needle tip configuration long bevel angle, Nozzle type Luer / Lock, 6% conical, 1,2 mm, Barrel marking specs 0.01ml-0.5ml, Graduation legibility Legible, Needle cover color Transparent, Lubricant composition Dimethicone, Barrel transparency Transparent/ UV resistant, Needle cover strength 15N (min. 2N max. 15N), Hub/needle bond strength min. 22-69 N. Complied with ISO 7886-1, ISO 7864, ISO 9626. Volume 1mL, 2mL, 2.5mL, 3mL, 5mL, 10mL, 20mL, 25mL, 30mL, 50mL. Sizes 18G, 19G, 20G, 21G, 22G, 23G, 24G, 25G, 26G, 27G. Needle Lengths 13-38 mm. Piston material Isoprene Rubber, Barrel material PP, Plunger material PP, Needle material PP, SUS304. SAL 10-6. Endotoxin Limit 20 EU per device. Biocompatibility Complied with ISO 10993-4/5/10/11 (Cytotoxicity, Irritation, Sensitization Acute Systemic Toxicity, Hemolytical effect).

  • Sterile Insulin Syringe for Single use, with needle: Needle Cap, Needle, Piston, Plunger, Barrel, End Cap. EO Sterilized. Prescription use. Single use. The plunger of syringe can be pulled and pushed along inside the barrel, allowing the syringe to take in and expel the fluids through the connector to the patient. Complied with ISO 8537. Volume 0.5ml, 1ml volumes with fixed needle. Needle Lengths 8mm. Piston material Isoprene Rubber, Barrel material PP, Plunger material PP, Needle material SUS304, Needle Cap material PE, End Cap material PE. SAL 10-6. Endotoxin Limit 20 EU per device. Biocompatibility ISO 10993-4/5/10/11 (Cytotoxicity, Irritation, Sensitization Acute Systemic Toxicity, Subchronic Toxicity, Hemolytical effect).

  • Sterile Hypodermic needle for Single use: Protective cap, Needle, Adhesives, Needle hub. EO Sterilized. Prescription use. Medical professionals and trained care givers. Protective cap, Needle, Adhesives, Needle hub. Single use. For Manual Use Only, For Single Use only. Complied with: ISO 7864, ISO 9626. Sizes 18G, 19G, 20G, 21G, 22G, 23G, 24G, 25G, 26G, 27G, 28G, 30G. Needle Lengths 13-38 mm. Protective cap materials PP, Adhesive Epoxy resin, Needle Hub materials PP, Needle material SUS304. SAL 10-6. Endotoxin Limit 20 EU per device. Biocompatibility Complied with ISO 10993-4/5/10/11 (Cytotoxicity, Irritation, Sensitization Acute Systemic Toxicity, Hemolytical effect).

AI/ML Overview

The provided text is a 510(k) summary for medical devices (syringes and needles). It does not describe a study involving an AI model or a device that uses AI. Instead, it focuses on demonstrating substantial equivalence of the submitted devices to a predicate device through performance testing against established international standards for medical devices.

Therefore, the requested information regarding acceptance criteria and a study proving an AI device meets those criteria cannot be extracted from this document. The document primarily details the physical and performance specifications of the syringes and needles themselves.

To directly answer your request based on the provided document, I must state that the information related to AI model acceptance criteria, test sets, ground truth establishment, expert adjudication, MRMC studies, and training set details are not present in the provided text. The document describes a traditional medical device submission, not an AI/ML-enabled medical device.

However, I can extract the acceptance criteria and performance data for the physical medical devices described:


Acceptance Criteria and Device Performance for Physical Medical Devices

The acceptance criteria for these devices are defined by compliance with a series of international ISO standards and USP guidelines. The "device performance" is reported as having "complied with" these standards. No specific quantitative performance metrics (e.g., accuracy, precision, etc.) are provided in a numerical table format for an AI algorithm, as this is not an AI device.

Table of Acceptance Criteria and Reported Device Performance

Category/StandardAcceptance Criteria (defined by standard)Reported Device Performance
Disposable Sterile Syringe, with/without needle; luer/luer-lock
ISO 9626 (Stainless steel needle tubing)Requirements and test methods for needle tubingComplied with
ISO 7886-1 (Sterile hypodermic syringes for manual use)Requirements and test methodsComplied with
ISO 7864 (Sterile hypodermic needles for single use)Requirements and test methodsComplied with
ISO 80369-7 (Small-bore connectors)Requirements for connectorsComplied with
ISO 10993-4 (Biological evaluation - Blood interaction)Selection of Tests for Interactions with BloodComplied with, Hemocompatibility carried out
ISO 10993-5 (Biological evaluation - Cytotoxicity)Tests for In Vitro CytotoxicityComplied with, Cytotoxicity carried out
ISO 10993-10 (Biological evaluation - Irritation/Sensitization)Tests for Irritation and Skin SensitizationComplied with, Irritation and Sensitization carried out
ISO 10993-11 (Biological evaluation - Systemic Toxicity)Tests for Systemic ToxicityComplied with, Acute Systemic Toxicity carried out
USP 788 (Particulate Matter in Injections)Requirements for particulate matterComplied with
ISO 10993-7 (Biological evaluation - EO residuals)Requirements for Ethylene oxide sterilization residualsComplied with
ISO 10993-12 (Biological evaluation - Sample prep)Sample preparation and reference materialsComplied with
ISO 11135 (EO Sterilization)Requirements for sterilization processComplied with
ISO 11607-2 (Packaging for sterilized devices)Validation requirements for packagingComplied with
SAL (Sterility Assurance Level)10-6Met (Reported in Device Description)
Endotoxin Limit20 EU per deviceMet (Reported in Device Description)
Sterile Insulin Syringe for Single use, with needle
ISO 8537 (Sterile single-use syringes for insulin)Requirements and test methodsComplied with
ISO 10993-4 (Biological evaluation - Blood interaction)Selection of Tests for Interactions with BloodComplied with, Hemocompatibility carried out
ISO 10993-5 (Biological evaluation - Cytotoxicity)Tests for In Vitro CytotoxicityComplied with, Cytotoxicity carried out
ISO 10993-10 (Biological evaluation - Irritation/Sensitization)Tests for Irritation and Skin SensitizationComplied with, Irritation and Sensitization carried out
ISO 10993-11 (Biological evaluation - Systemic Toxicity)Tests for Systemic ToxicityComplied with, Acute Systemic Toxicity, Sub-acute Systemic Toxicity, Sub-chronic Systemic Toxicity carried out
USP 788 (Particulate Matter in Injections)Requirements for particulate matterComplied with
ISO 10993-7 (Biological evaluation - EO residuals)Requirements for Ethylene oxide sterilization residualsComplied with
ISO 10993-12 (Biological evaluation - Sample prep)Sample preparation and reference materialsComplied with
ISO 11135 (EO Sterilization)Requirements for sterilization processComplied with
ISO 11607-2 (Packaging for sterilized devices)Validation requirements for packagingComplied with
SAL (Sterility Assurance Level)10-6Met (Reported in Device Description)
Endotoxin Limit20 EU per deviceMet (Reported in Device Description)
Sterile Hypodermic needle for Single use
ISO 9626 (Stainless steel needle tubing)Requirements and test methods for needle tubingComplied with
ISO 7864 (Sterile hypodermic needles for single use)Requirements and test methodsComplied with
ISO 10993-4 (Biological evaluation - Blood interaction)Selection of Tests for Interactions with BloodComplied with, Hemocompatibility carried out
ISO 10993-5 (Biological evaluation - Cytotoxicity)Tests for In Vitro CytotoxicityComplied with, Cytotoxicity carried out
ISO 10993-10 (Biological evaluation - Irritation/Sensitization)Tests for Irritation and Skin SensitizationComplied with, Irritation and Sensitization carried out
ISO 10993-11 (Biological evaluation - Systemic Toxicity)Tests for Systemic ToxicityComplied with, Acute Systemic Toxicity carried out
USP 788 (Particulate Matter in Injections)Requirements for particulate matterComplied with
ISO 10993-7 (Biological evaluation - EO residuals)Requirements for Ethylene oxide sterilization residualsComplied with
ISO 10993-12 (Biological evaluation - Sample prep)Sample preparation and reference materialsComplied with
ISO 11135 (EO Sterilization)Requirements for sterilization processComplied with
ISO 11607-2 (Packaging for sterilized devices)Validation requirements for packagingComplied with
SAL (Sterility Assurance Level)10-6Met (Reported in Device Description)
Endotoxin Limit20 EU per deviceMet (Reported in Device Description)

Regarding an AI-enabled device and its study, the following information is NOT available in the provided document:

  • 1. Table of acceptance criteria and reported device performance for an AI model: Not applicable, as this is not an AI device.
  • 2. Sample size used for the test set and data provenance: No test set for an AI model is mentioned. The performance testing refers to physical tests on the medical devices themselves.
  • 3. Number of experts used to establish ground truth & qualifications: Not applicable for an AI model's ground truth. The ground truth for the physical devices' performance is established by the specifications and test methods within the referenced ISO standards.
  • 4. Adjudication method for the test set: Not applicable.
  • 5. If a multi reader multi case (MRMC) comparative effectiveness study was done: "No prospective clinical trials were conducted in support of this 510(K)."
  • 6. If a standalone (algorithm only) performance was done: Not applicable, as there is no algorithm.
  • 7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.): For the physical devices, the "ground truth" is adherence to established engineering and material standards for safety and performance (e.g., fluid aspiration/injection, material biocompatibility, sterility).
  • 8. The sample size for the training set: Not applicable, as there is no AI model.
  • 9. How the ground truth for the training set was established: Not applicable, as there is no AI model.

In summary, the provided document details a 510(k) submission for conventional medical devices (syringes and needles) and their compliance with relevant international standards, not an AI-enabled medical device. Therefore, the specific criteria requested for AI devices are not found within this text.

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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 USA logo. To the right of that is the FDA logo, with the letters "FDA" in a blue square. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

August 17, 2022

Shandong Zhushi Pharmaceutical Group Co., Ltd % Bruce Cai Technical Manager Humiss Inc. 5#501, No. 445, Renmin Road, Qingcun Town, Fengxian District Shanghai, 201414 China

Re: K212033

Trade/Device Name: Disposable Sterile Syringe, with/without needle; luer/luer-lock: Sterile Insulin Syringe for Single use, with needle: Sterile Hypodermic needle for Single use Regulation Number: 21 CFR 880.5860 Regulation Name: Piston Syringe Regulatory Class: Class II Product Code: FMF, FMF, FMI Dated: July 5, 2022 Received: July 11, 2022

Dear Bruce Cai:

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

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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,

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

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DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Indications for Use

510(k) Number (if known) K212033

Device Name

Disposable Sterile Syringe, with/without needle; luer/luer-lock

Indications for Use (Describe)

The Sterile Hypodermic Syringe for Single Use with/without need 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)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

Form Approved: OMB No. 0910-0120 Expiration Date: 06/30/2023 See PRA Statement below.

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DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Indications for Use

510(k) Number (if known)

K212033

Device Name

Sterile Insulin Syringe for Single use, with needle

Indications for Use (Describe)

The sterile insulin syringe for single use with needle, with the callbration unit of insulin for U-100, is a device intended for medical purposes for the manual aspiration of insulin, and for the injection of insulin into parts of the body below the surface skin.

The sterile insulin syringe for single use with needle, with the callbration unit of insulin for U-40 is a device intended for medical purposes for the manual aspiration of insulin and for the injection of insulin into parts of the body below the surface skin.

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)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

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DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Indications for Use

510(k) Number (if known)

K212033

Device Name

Sterile Hypodermic needle for Single use

Indications for Use (Describe)

The Sterile Hypodermic Needle for single use is intended for use with syringes and injection devices for general purpose fluid injection/aspiration.

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)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

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K212033 510(k) SUMMARY

I. PREPARATION DATE: August 8, 2022

II. SUBMITTER

Manufacturer name: Shandong Zhushi Pharmaceutical Group Co., Ltd. Address; No. 6, Shande Road, Shan County, Heze City, Shandong Province, 274300, China Contact Person: Junhui Zhu Title: Manager Tel: +86-15764021131 Fax: +86-530-4265777 E-mail: 2307426957@gq.com

III. Correspondent Contact Information

Bruce Cai (Contact Person) Humiss Inc. Tel: +86-13585598660 E-mail: cc401vip@126.com Summary Preparation Date: 2021.4.21

IV. DEVICE

Name of Device:- Disposable Sterile Syringe, with/without needle; luer/luer-lock- Sterile Insulin Syringe for Single use, with needle- Sterile Hypodermic needle for Single use
Common Name- Disposable Sterile Syringe- Disposable insulin syringe- Disposable Hypodermic needle
Classification Name- Piston Syringe- Piston Syringe- Hypodermic Single Lumen Needle
Regulation Number- 21 CFR 880.5860- 21 CFR 880.5860- 21 CFR 880.5570
Product Code- FMF- FMF- FMI
Device Class- Class II

V. PREDICATE DEVICE

K190002- Sterile Hypodermic Syringe for Single use with/without needle,

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Sterile Insulin Syringe for Single use with needle, Sterile Hypodermic needle for Single use.

VI. Device Description

ModelsSubject Device
Product nameDisposable Sterile Syringe, with/without needle; luer/luer-lock
Indications for useThe 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.
ConfigurationPiston, Plunger, Barrel
Sterility conditionEO Sterilized
Environment of usePrescription use
Intended usersMedical professionals and trained care givers
Single useYes
Operation modeThe plunger of syringe can be pulled and pushed along inside the barrel, allowing the syringe to take in and expel the fluids through the connector to the patient.
Length83-152mm
Diameter50-31mm
Tip typeluer/luer-lock
Needle tip configurationThe blade angle of the injection needle is the long bevel angle.
Nozzle typeLuer / Lock, %6 conical, 1,2 mm
Barrel marking specs0.01ml-0.5ml
Graduation legibilityLegible
Needle cover dimensions
Needle cover colorTransparent
Lubricant compositionDimethicone
Barrel transparencyTransparent/ UV resistant
Needle cover strength15N (min. 2N max. 15N)
Hub/needle bond strengthmin. 22-69 N
Product performanceComplied with ISO 7886-1, ISO 7864, ISO 9626
Volume1mL, 2mL, 2.5mL, 3mL, 5mL, 10mL, 20mL, 25mL, 30mL, 50mL
Sizes18G, 19G, 20G, 21G, 22G, 23G, 24G, 25G, 26G, 27G
Needle Lengths13-38 mm
Piston materialIsoprene Rubber
Barrel materialPP
Plunger materialPP

Table 5.1. Device Description Summary for Disposable Sterile Syringe

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Needle materialPP, SUS304
SAL10-6
Endotoxin Limit20 EU per device
BiocompatibilityComplied with ISO 10993-4/5/10/11 (Cytotoxicity, Irritation, Sensitization Acute Systemic Toxicity, Hemolytical effect)
ModelsSubject Device
Product nameSterile Insulin Syringe for Single use, with needle
Indications for useThe sterile insulin syringe for single use with needle, withthe calibration unit of insulin for U-100, is a device intendedfor medical purposes for the manual aspiration of insulin,and for the injection of insulin into parts of the body belowthe surface skin.The sterile insulin syringe for single use with needle, withthe calibration unit of insulin for U-40 is a device intendedfor medical purposes for the manual aspiration of insulin,and for the injection of insulin into parts of the body belowthe surface skin.
ConfigurationNeedle Cap, Needle, Piston, Plunger, Barrel, End Cap
Sterility conditionEO Sterilized
Environment of usePrescription use
Single useYes
Operation modeThe plunger of syringe can be pulled and pushed alonginside the barrel, allowing the syringe to take in and expelthe fluids through the connector to the patient.
Product performanceComplied with ISO 8537
Volume0.5ml, 1ml volumes with fixed needle
Needle Lengths8mm
Piston materialIsoprene Rubber
Barrel materialPP
Plunger materialPP
Needle materialSUS304
Needle Cap materialPE
End Cap materialPE
SAL10-6
Endotoxin Limit20 EU per device
BiocompatibilityISO 10993-4/5/10/11 (Cytotoxicity, Irritation, SensitizationAcute Systemic Toxicity, Subchronic Toxicity, Hemolyticaleffect

Table 5.2. Device Description Summary for Insulin Syringe

Table 5.3. Device Description Summary for Needle

ModelsSubject device
------------------------

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Product nameSterile Hypodermic needle for Single use
Indications for useThe Sterile Hypodermic Needle for single use is intended for use with syringes and injection devices for general purpose fluid injection/aspiration.
ConfigurationProtective cap, Needle, Adhesives, Needle hub
Sterility conditionEO Sterilized
Environment of usePrescription use
Intended usersMedical professionals and trained care givers
ConfigurationProtective cap, Needle, Adhesives, Needle hub
Single useYes
Operation modeFor Manual Use Only, For Single Use only
Product performanceComplied with: ISO 7864, ISO 9626
Sizes18G, 19G, 20G, 21G, 22G, 23G, 24G, 25G, 26G, 27G, 28G, 30G
Needle Lengths13-38 mm
Protective cap materialsPP
AdhesiveEpoxy resin
Needle Hub materialsPP
Needle materialSUS304
SAL10-6
Endotoxin Limit20 EU per device
BiocompatibilityComplied with ISO 10993-4/5/10/11 (Cytotoxicity, Irritation, Sensitization Acute Systemic Toxicity, Hemolytical effect)

VII. Predicate Comparison

Table 6.1 Sterile Hypodermic Syringe for Single use, with/without needle; luer/luer-lock
Predicate Comparison
ModelsSubject DevicePredicate DeviceK190002Comparison
Product nameDisposable Sterile Syringe,with/without needle;luer/luer-lockSterile HypodermicSyringe for Single use,with/without needleSimilar
Product codeFMFFMFSame
Regulationnumber21 CFR 880.586021 CFR 880.5860Same
ClassIIIISame
Indications foruseThe Sterile HypodermicSyringe for Single Usewith/without needle isintended to be used formedical purposes to injectfluid into or withdraw fluidThe Sterile HypodermicSyringe for Single Usewith/without needle isintended to be used formedical purposes to injectfluid into or withdrawSame

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from body.fluid from body.
ConfigurationPiston, Plunger, BarrelPiston, Plunger, BarrelSame
Sterility conditionEO SterilizedEO SterilizedSame
Environment of usePrescription usePrescription useSame
Intended usersMedical professionals and trained care giversMedical professionals and trained care giversSame
Single useYesYesSame
Operation modeThe plunger of syringe can be pulled and pushed along inside the barrel, allowing the syringe to take in and expel the fluids through the connector to the patient.The plunger of syringe can be pulled and pushed along inside the barrel, allowing the syringe to take in and expel the fluids through the connector to the patient.Same
Label/labelingComplied with 21 CFR part 801Complied with 21 CFR part 801Same
Product performanceComplied with ISO 7886-1, ISO 7864, ISO 9626Complied with ISO 7886-1, ISO 7864, ISO 9626Same
Volume1mL, 2mL, 2.5mL, 3mL, 5mL, 10mL, 20mL, 25mL, 30mL, 50mL1mL, 3mL, 5mL, 6mL, 10mL, 20mL, 30mL, 35mL, 50mL and 60 mLDifference 1
Sizes18G, 19G, 20G, 21G, 22G, 23G, 24G, 25G, 26G, 27G18G, 19G, 20G, 21G, 22G, 23G, 24G, 25G, 26G, 27G, 28G, 29G, 30GDifference 2
Needle Lengths13-38 mm4-38 mmDifference 3
Patient contact component and material
PistonIsoprene RubberIsoprene RubberSame
BarrelPPPPSame
PlungerPPPPSame
NeedlePP, SUS304PP, SUS304Same
Sterilization
SAL10-610-6Same
Endotoxin Limit20 EU per device20 EU per deviceSame

Table 6.2. Sterile Insulin Syringe for Single use, with needle Predicate Comparison

ModelsSubject DevicePredicate DeviceK190002
Product nameSterile Insulin Syringe forSingle use, with needleDisposable insulinsyringeSame

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Product codeFMFFMFSame
Regulationnumber21 CFR 880.586021 CFR 880.5860Same
ClassIIIISame
Indications foruseThe sterile insulin syringefor single use with needle,with the calibration unit ofinsulin for U-100, is a deviceintended for medicalpurposes for the manualaspiration of insulin, and forthe injection of insulin intoparts of the body below thesurface skin.The sterile insulin syringefor single use with needle,with the calibration unit ofinsulin for U-40 is a deviceintended for medicalpurposes for the manualaspiration of insulin, and forthe injection of insulin intoparts of the body below thesurface skin.The sterile insulinsyringe for single usewith needle, with thecalibration unit ofinsulin for U-100, is adevice intended formedical purposes for themanual aspiration ofinsulin, and for theinjection of insulin intoparts of the body belowthe surface skin.The sterile insulinsyringe for single usewith needle, with thecalibration unit ofinsulin for U-40 is adevice intended formedical purposes for themanual aspiration ofinsulin, and for theinjection of insulin intoparts of the body belowthe surface skin.Same
ConfigurationNeedle Cap, Needle, Piston,Plunger, Barrel, End CapNeedle Cap, Needle,Piston, Plunger, Barrel,End CapSame
SterilityconditionEO SterilizedEO SterilizedSame
Environment ofusePrescription usePrescription useSame
Intended usersPatient usePatient useSame
Single useYesYesSame
Operation modeThe plunger of syringe canbe pulled and pushed alonginside the barrel, allowingthe syringe to take in andexpel the fluids through theconnector to the patient.The plunger of syringecan be pulled andpushed along inside thebarrel, allowing thesyringe to take in andexpel the fluids throughthe connector to theSame
Label/labelingComplied with 21 CFR part 801Complied with 21 CFR part 801Same
Product performanceComplied with ISO 8537Complied with ISO 8537Same
Volume0.5ml, 1ml volumes with fixed needle0.3ml, 0.5ml, 1ml volumes with fixed needleDifference 4
Needle Lengths8mm8mm, 13mmDifference 5
Patient contact component and material
PistonIsoprene RubberIsoprene RubberSame
BarrelPPPPSame
PlungerPPPPSame
NeedlePP, SUS304PP, SUS304Same
Needle cap / End CapPE/PEPP/PPDifference 6
Sterilization
SAL10-610-6Same
Endotoxin Limit20 EU per device20 EU per deviceSame

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Table 6.3. Sterile Hypodermic needle for Single use Predicate Comparison

ModelsSubject DevicePredicate Device K190002
Product nameSterile Hypodermic needle for Single useSterile Hypodermic needle for Single use
Product codeFMIFMI
Regulation number21 CFR 880.557021 CFR 880.5570
ClassIIII
Intended usersThe Sterile Hypodermic Needle for single use is intended for use with syringes and injection devices for general purpose fluid injection/aspiration.The Sterile Hypodermic Needle for single use is intended for use with syringes and injection devices for general purpose fluid injection/aspiration.
ConfigurationProtective cap, Needle, Adhesives, Needle hubProtective cap, Needle, Adhesives, Needle hub
Sterility conditionEO SterilizedEO Sterilized
Environment of usePrescription usePrescription use
Single useYesYes

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Operation modeFor Manual Use Only, ForSingle Use onlyFor Manual Use Only,For Single Use only
ProductperformanceComplied with: ISO 7864,ISO 9626Complied with: ISO7864, ISO 9626
Sizes18G, 19G, 20G, 21G, 22G,23G, 24G, 25G, 26G, 27G,28G, 30G18G, 19G, 20G, 21G,22G, 23G, 24G, 25G,26G, 27G, 28G, 29G,30GDifference 7
Needle Lengths13-38 mm4-38 mmDifference 8
Protective capmaterialsPPPP
AdhesiveEpoxy resinEpoxy resin
Needle HubPPPP
Needle materialSUS304SUS304
SAL10-610-6
Endotoxin Limit20 EU per device20 EU per device

VIII. Substantial Equivalence Discussion

7.1 Disposable Sterile Syringe Discussion

The indications for use statement for the Disposable Sterile Syringe subject device are identical to the predicate device. There are no technological differences between the predicate and subject devices except for the following: syringe volumes, needle gauge sizes, needle lengths.

  • Difference 1: The subject device includes different syringe volumes compared to the predicate. The subject device includes 2mL, 2.5mL, volume syringes while the predicate does not include these sizes. The predicate device includes 6ml, 35ml and 60 ml syringe volumes which the subject device does not include. These slight differences have no adverse effect on clinical safety and performance. All the subject device hypodermic syringes are tested in accordance with ISO 7886-1 standard. The requirements of the standards are met.
  • Difference 2: The subject device does not include needle gauges 28G, 29G, 30G while the predicate device includes these sizes. The needles are tested in accordance with ISO 7864 and ISO 9626 and released in accordance with the standards compliance. This was verified by performance testing according to ISO 7864 and ISO 9626.
  • Difference 3: The predicate device includes additional needle lengths compared to the subject device. The subject device includes the following additional needle lengths: 13-38 mm. The needles are tested in accordance to ISO 7864 and ISO 9626 and released in accordance with the standards compliance. This was verified by performance testing according to ISO 7864 and ISO 9626.

7.2 Insulin Syringe Discussion

The indications for use statement for the Sterile Insulin Syringe are identical to the predicate

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device. There are no technological differences between the subject and the predicate device except for the following: syringe volumes, needle lengths and Needle cap/End Cap material. This was verified by performance testing according to ISO 8537. The intended use, principle of operation, materials, specifications, and sterilization information for the subject device are the same as for the predicate device. Therefore, it can be determined that the proposed device is substantially equivalent to the predicate device.

  • Difference 4: The subject device includes different syringe volumes compared to the predicate. The subject device does not include 0.3ml volume syringes while the predicate includes this size. These slight differences have no adverse effect on clinical safety and performance. The subject device insulin syringe is tested in accordance with ISO 8537 standard. The requirements of the standards are met.
  • Difference 5: The subject device includes different syringe volumes compared to the predicate. The subject device does not include 13mm needle while the predicate includes this length. These slight differences have no adverse effect on clinical safety and performance. The subject device insulin syringe is tested in accordance with ISO 8537 standard. The requirements of the standards are met.
  • Difference 6: The Needle cap and End Cap of the subject device is PE, while the predicate device material is PP. Biocompatibility studies are carried out in according to ISO 10993-1. Biological safety was demonstrated. The intended use, principle of operation, and sterilization information for the subject device are the same as the predicate device. The differences between the predicate and the subject device do not raise any new or different questions of safety or effectiveness. Therefore, it can be determined that the proposed device is substantially equivalent to the predicate device.

7.3 Needle Discussion

The indications for use statement for the subject device is identical to the predicate device. There are no technological differences between the subject and the predicate device except for the following: needle gauge sizes and needle length.

  • Difference 7: The subject device includes additional needle gauges compared to the predicate. The subject device does not include needle gauges 29G while the predicate device includes these sizes. The needles are tested in accordance with ISO 7864 and ISO 9626 and released in accordance with the standards compliance. This was verified by performance testing according to ISO 7864 and ISO 9626.
  • Difference 8: The predicate device includes additional needle lengths compared to the subject device. The subject device includes the following additional needle lengths: 13-38 mm. The needles are tested in accordance to ISO 7864 and ISO 9626 and released in accordance with the standards compliance. This was verified by performance testing according to ISO 7864 and ISO 9626.

VIV. Performance Testing

8.1 Sterile Hypodermic Syringe for Single use, with/without needle; luer/luer-lock

The Sterile Hypodermic Syringe for Single use described in this summary were tested and demonstrated to be in conformance with the following FDA recognized standards:

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  • . ISO 9626 Second edition: Stainless steel needle tubing for the manufacture of medical devices - Requirements and test methods
  • ISO 7886-1 Second edition 2017-05 Sterile hypodermic syringes for single use Part 1: . Syringes for manual use
  • . ISO 7864:2016 Fourth Edition: Sterile hypodermic needles for single use - Requirements and test methods
  • . ISO 80369-7:2016 Small-bore connectors for liquids and gases in healthcare applications - Part 7: Connectors for intravascular or hypodermic applications
  • . 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 10993-10:2010 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
  • USP 788 Particulate Matter in Injections
  • . ISO 10993-7:2008 Biological evaluation of medical devices - Part 7: Ethylene oxide sterilization residuals
  • . ISO 10993-12:2012 Biological evaluation of medical devices - Part 12: Sample preparation and reference materials
  • . ISO 11135:2014 Sterilization of health-care products - Ethylene oxide - Requirements for the development, validation and routine control of a sterilization process for medical devices
  • . ISO 11607-2:2019 Packaging for terminally sterilized medical devices - Part 2: Validation requirements for forming, sealing and assembly processes

The Sterile Hypodermic Syringe for Single use is considered in the category of "External Communicating Devices" and are accepted to be in contact for a period less than 24 hours with "indirect blood path". Thus, cytotoxicity (ISO 10993-5:2009, irritation and sensitization (ISO 10993-10:2010), acute systemic toxicity (ISO 10993-11:2017), hemocompatibility (EN ISO 10993-4:2017) were carried out for the device in question.

8.2 Sterile Insulin Syringe for Single use, with needle

The Sterile Insulin Syringe for Single use described in this summary were tested and demonstrated to be in conformance with the following FDA recognized standards:

  • ISO 8537 Third edition 2016-03-15 Sterile single-use syringes, with or without needle, for insulin
  • . 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 10993-10:2010 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

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Systemic Toxicity

  • USP 788 Particulate Matter in Injections
  • . ISO 10993-7:2008 Biological evaluation of medical devices - Part 7: Ethylene oxide sterilization residuals
  • . ISO 10993-12:2012 Biological evaluation of medical devices - Part 12: Sample preparation and reference materials
  • . ISO 11135:2014 Sterilization of health-care products - Ethylene oxide - Requirements for the development, validation and routine control of a sterilization process for medical devices
  • ISO 11607-2:2019 Packaging for terminally sterilized medical devices - Part 2: Validation requirements for forming, sealing and assembly processes

The Sterile Insulin Syringe for Single use is considered in the category of "External Communicating Devices" and are accepted to be in contact for a period between 24 hours - 30 days because of repetitive use of patient with "indirect blood path". Thus, cytotoxicity (ISO 10993-5:2009, irritation and sensitization (ISO 10993-10:2010), acute systemic toxicity (ISO 10993-11:2017), sub-acute systemic toxicity (ISO 10993-11:2017), sub-chronic systemic toxicity (ISO 10993-11:2017), hemocompatibility (EN ISO 10993-4:2017) were carried out for the device in question.

8.3 Sterile Hypodermic needle

The Sterile Hypodermic needle described in this summary were tested and demonstrated to be in conformance with the following FDA recognized standards:

  • ISO 9626 Second edition: Stainless steel needle tubing for the manufacture of medical • devices - Requirements and test methods
  • . ISO 7864:2016 Fourth Edition: Sterile hypodermic needles for single use - Requirements and test methods
  • . 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 10993-10:2010 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
  • . USP 788 Particulate Matter in Injections
  • . ISO 10993-7:2008 Biological evaluation of medical devices - Part 7: Ethylene oxide sterilization residuals
  • . ISO 10993-12:2012 Biological evaluation of medical devices - Part 12: Sample preparation and reference materials
  • . ISO 11135:2014 Sterilization of health-care products - Ethylene oxide - Requirements for the development, validation and routine control of a sterilization process for medical devices
  • . ISO 11607-2:2019 Packaging for terminally sterilized medical devices - Part 2: Validation requirements for forming, sealing and assembly processes

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The Sterile Hypodermic needle is considered in the category of "External Communicating Devices" and are accepted to be in contact for a period less than 24 hours with "indirect blood path". Thus, cytotoxicity (ISO 10993-5:2009, irritation and sensitization (ISO 10993-10:2010), acute systemic toxicity (ISO 10993- 11:2017), hemocompatibility (EN ISO 10993-4:2017) were carried out for the device in question.

X. Clinical study

No prospective clinical trials were conducted in support of this 510(K).

XI. Conclusion

The differences between the predicate and the subject device do not raise any new or different questions of safety or effectiveness. The subject devices are substantially equivalent to the predicate devices with respect to the indications for use, target populations, treatment method, and technological characteristics.

§ 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).