(543 days)
Single use Needle is intended for use with syringes and injection devices for general purpose fluid injection/aspiration.
Single use Syringe with Needle is intended to be used for medical purposes to inject fluid into or withdraw fluid from body.
Membrane Filter Syringe is intended to be used for medical purposes to inject fluid into or withdraw fluid from body. The filter operates when injecting the drug into the human body to remove foreign substances from the drug solutions.
The device has three model with the following:
(1) Single use Needle (108 model codes including Sofjec-16-13)
Single use Needle consist of Cap, Needle and Hub and Blister paper function to sustain sterilization of the product. The Cap function to protect the needle. This device is single use. This device is provided EO Sterilization.
(2) Single use Syringe with Needle (1734 model codes including HJ-1-16G-13)
Single use Syringe with Needle consist of Syringe, Cap, Needle and Hub and Blister paper function to sustain sterilization of the product. The Cap function to protect the needle. This device is single use. This device is provided EO Sterilization and the syringes are two type of Luer Slip and Luer Lock. These device are injecting the medicine with syringes. This device is finished biocompatibility test and performance test for safety.
(3) Membrane Filter Syringe (16 model codes including HJM-18-1)
This devices are consists of membrane filter needle and syringe. Membrane filter needle is attached 0.5nm filtration membrane (Acrylic copolymer material). Syringe is two type. (Luer slip type and Luer lock type) This device is Filtering with syringes and injection device is finished biocompatibility test and performance test for safety.
This document is a 510(k) premarket notification for medical devices (syringes and needles), which primarily focuses on demonstrating substantial equivalence to previously cleared predicate devices. It does not contain the kind of acceptance criteria and performance study details typically found for novel AI/ML medical devices.
Therefore, the requested information regarding acceptance criteria, device performance, sample sizes for test/training sets, expert involvement in ground truth establishment, adjudication methods, MRMC studies, standalone performance, and ground truth types is not present in this document.
This document details the following aspects relevant to the device clearance:
1. Acceptance Criteria and Device Performance:
- The document does not specify quantitative acceptance criteria in terms of metrics like sensitivity, specificity, or AUC as one would expect for an AI/ML device.
- Instead, the "acceptance criteria" are compliance with established international standards for medical devices of this type. The "reported device performance" is the statement that the device "Complied with" these standards.
| Acceptance Criteria (Standard Compliance) | Reported Device Performance (Compliance) |
|---|---|
| ISO 7886-1:2017: Sterile Hypodermic Syringes | Complied with |
| ISO 7864:2016: Sterile Hypodermic Needles | Complied with |
| ISO 9626:2016: Stainless steel needle tubing | Complied with |
| ISO 80369-7:2016: Small-bore connectors | Complied with |
| ISO 10993-1: Biocompatibility | Complied with |
| USP <788>: Particulate Matter | Met USP acceptance criteria |
| ASTM F1980: Accelerated Aging (for shelf-life) | Complied with (3-year shelf life) |
| EN ISO 11135: Ethylene Oxide Sterilization | Complied with |
| ISO 10993-7: Ethylene Oxide sterilization residuals | Complied with |
| USP <85>, <161>: Pyrogen Test (Endotoxin) | Complied with (Endotoxin) |
| ISTA 2017 2A: Simulated transportation test | Complied with (Integrity Test) |
2. Sample Size and Data Provenance:
- This document does not refer to "test sets" or "training sets" in the context of AI/ML models. The performance assessment is based on physical and chemical testing of the devices themselves, performed according to the listed ISO and USP standards.
- The data provenance is from the manufacturer's internal testing as part of their regulatory submission for a physical medical device (needles and syringes), not AI/ML data. The manufacturer is Hwajin Medical Co., Ltd. from South Korea. The studies are non-clinical (laboratory/bench testing) and not specifically "retrospective" or "prospective" in the same sense as clinical trials or AI/ML data collection.
3. Number of Experts and Qualifications for Ground Truth:
- Not applicable. Ground truth, in this context, refers to the established standards and test methods for physical properties and biocompatibility of medical devices. There are no "experts establishing ground truth" in the sense of image annotation or clinical diagnosis for an AI/ML model. The "experts" would be the scientists and engineers who developed and performed the standard tests to verify compliance.
4. Adjudication Method:
- Not applicable. There is no human interpretation or adjudication process described as it would be for an AI/ML diagnostic output.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study:
- No MRMC study was done, as this is a submission for a physical medical device (syringe/needle), not an AI/ML diagnostic aid. Therefore, there is no effect size of human readers improving with AI assistance.
6. Standalone Performance:
- Not applicable. This is a physical device, so the concept of "algorithm only without human-in-the-loop performance" does not apply. The device's "standalone" performance is its ability to meet the defined ISO and USP standards.
7. Type of Ground Truth Used:
- The "ground truth" for this device's performance is compliance with internationally recognized medical device performance standards (ISO, USP, ASTM, EN), and biocompatibility testing results. It is not based on expert consensus, pathology, or outcomes data in the way an AI/ML device would be.
8. Sample Size for the Training Set:
- Not applicable. This is not an AI/ML device, so there is no "training set." The product development and manufacturing processes conform to quality system regulations.
9. How the Ground Truth for the Training Set was Established:
- Not applicable for the same reason as above.
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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 & 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.
February 13, 2023
Hwajin Medical Co.,Ltd. Jeon Hun Q.m.r 20, Seongsimwon-gil, Seongnam-myeon, Dongnam-gu Cheonan-si. Chungcheongnam-do 31244 Korea. South
Re: K212635
Trade/Device Name: Sofjec Regulation Number: 21 CFR 880.5860 Regulation Name: Piston Syringe Regulatory Class: Class II Product Code: FMF, MEG, FMI Dated: January 11, 2023 Received: January 13, 2023
Dear Jeon Hun:
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 801); medical device reporting of medical device-related adverse events) (21 CFR 803) for
{1}------------------------------------------------
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.
Alan M.
Stevens
-S3
CAPT 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) K212635
Device Name Sofjec
Indications for Use (Describe) Single use Needle
Single use Needle is intended for use with syringes and injection devices for general purpose fluid injection/aspiration.
Single use Syringe with Needle
Single use Syringe with Needle is intended to be used for medical purposes to inject fluid into or withdraw fluid from body.
Membrane Filter Syringe
Membrane Filter Syringe is intended to be used for medical purposes to inject fluid into or withdraw fluid from body. The filter operates when injecting the drug into the human body to remove foreign substances from the drug solutions.
| 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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Image /page/3/Picture/0 description: The image shows the logo for Hwajin. The logo is black, except for two orange dots above the "J" in Hwajin. The "A" in Hwajin is stylized to look like an upside down "V".
20, Seongsimwon-gil, Seongnam-myeon, Dongnam-gu, Cheonan-si, Chungcheongnam-do, Republic of Korea Tel: +82 (41) 554 6181 Fax:+82 (41) 554 7178
K212635- 510(k) Summary
1. Date Prepared
February 13, 2023
Submitter's Information & Contact Person 2.
- Name of Manufacturer: HWAJIN MEDICAL CO., LTD.
- Address: 20, Seonsimwon-gil, Seongnam-myeon, Dongnam-gu, Cheonan-si, Chungcheongnamdo, 31244, Republic of Korea
- Contact Name: Jeon Sung Hun/Q.M.R
- Telephone No.: +82-41-554-6181
- Fax No.: +82-41-554-7178
- Email Address: sh-jeon(@hwajinmedical.com
3. Trade Name, Common Name, Classification
Common name: Syringe, Piston Trade name: Sofjec
| Classification Description | 21 CFR Section | Product Code | Class |
|---|---|---|---|
| Syringe, Piston | 880.5860 | FMF | II |
| Syringe, Antistick | 880.5860 | MEG | II |
| Needle, Hypodermic, Single Lumen | 880.5570 | FMI | II |
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Image /page/4/Picture/0 description: The image shows the word "HWAJIN" in a bold, sans-serif font. The letters are dark gray, except for two orange dots above the "J". The "A" is stylized with a triangle shape in the middle. The logo appears to be for a company or brand named Hwajin.
Tel: +82 (41) 554 6181 Fax:+82 (41) 554 7178
4. Identification of Predicate Device(s)
The identified predicate devices within this submission are shown as follow:
Predicate device
- K190002 - Sterile Hypodermic Syringe for Single Use, with/without needle, Sterile Insulin Syringe for Single Use, Sterile Hypodermic needle for Single use
- K173743 Greenmedi Safety Filter Syringe ●
5. Description of the Device
The device has three model with the following:
- (1) Single use Needle(108 model codes including Sofjec-16-13)
Single use Needle consist of Cap, Needle and Hub and Blister paper function to sustain sterilization of the product. The Cap function to protect the needle. This device is single use. This device is provided EO Sterilization.
Needle length according to gauge of Sofjec
| No | Model name | Gauge | Needle length |
|---|---|---|---|
| 1 | Sofjec-16 | 16 | 13,16,19,25,32,38 |
| 2 | Sofjec-17 | 17 | 13,16,19,25,32,38 |
| 3 | Sofjec-18 | 18 | 13,16,19,25,32,38 |
| 4 | Sofjec-19 | 19 | 13,16,19,25,32,38 |
| 5 | Sofjec-20 | 20 | 13,16,19,25,32,38 |
| 6 | Sofjec-21 | 21 | 13,16,19,25,32,38 |
| 7 | Sofjec-22 | 22 | 13,16,19,25,32,38 |
| 8 | Sofjec-23 | 23 | 13,16,19,25,32,38 |
| 9 | Sofjec-24 | 24 | 13,16,19,25,32,38 |
| 10 | Sofjec-25 | 25 | 13,16,19,25,32,38 |
| 11 | Sofjec-26 | 26 | 13,16,19,25,32,38 |
| 12 | Sofjec-27 | 27 | 13,16,19,25,32,38 |
| 13 | Sofjec-28 | 28 | 13,16,19,25,32,38 |
| 14 | Sofjec-29 | 29 | 4,5,6,10,13,16,19,25,32,38 |
| 15 | Sofjec-30 | 30 | 4,5,6,10,13,16,19,25,32,38 |
| 16 | Sofjec-31 | 31 | 4,5,6,10,13,16,19,25,32,38 |
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Image /page/5/Picture/0 description: The image shows the word "HWAJIN" in a bold, sans-serif font. The letters are black, except for two orange dots above the "J". The "A" in the word is stylized with a caret symbol instead of a horizontal bar.
20, Seongsimwon-gil, Seongnam-myeon, Dongnam-gu, Cheonan-si, Chungcheongnam-do, Republic of Korea Tel: +82 (41) 554 6181 Fax:+82 (41) 554 7178
- (2) Single use Syringe with Needle (1734 model codes including HJ-1-16G-13) Single use Syringe with Needle consist of Syringe, Cap, Needle and Hub and Blister paper function to sustain sterilization of the product. The Cap function to protect the needle. This device is single use. This device is provided EO Sterilization and the syringes are two type of Luer Slip and Luer Lock. These device are injecting the medicine with syringes. This device is finished biocompatibility test and performance test for safety.
- (3) Membrane Filter Syringe(16 model codes including HJM-18-1) This devices are consists of membrane filter needle and syringe. Membrane filter needle is attached 0.5nm filtration membrane (Acrylic copolymer material). Syringe is two type. (Luer slip type and Luer lock type) This device is Filtering with syringes and injection device is finished biocompatibility test and performance test for safety.
{6}------------------------------------------------
Image /page/6/Picture/0 description: The image shows the logo for Hwajin. The logo is in black text, except for two orange dots above the letter 'I'. The font is sans-serif and bolded.
20, Seongsimwon-gil, Seongnam-myeon, Dongnam-gu, Cheonan-si, Chungcheongnam-do, Republic of Korea Tel: +82 (41) 554 6181 Fax:+82 (41) 554 7178
6. Indications for Use
| Characteristics | Subject DeviceSofjec Single use Needle,Single use Syringe withneedleK212635 | Predicate DeviceSterile Hypodermic Syringefor Single Use with/withoutNeedle, Hypodermic Needlefor Single UseK190002 | Secondary PredicateGreenmedi Safety FilterSyringeK173743 | |
|---|---|---|---|---|
| Indication forUse | Single use NeedleSingle use Needle is intendedfor use with syringes andinjection devices for generalpurpose fluidinjection/aspiration.Single use Syringe withNeedleSingle use Syringe withNeedle is intended to be usedfor medical purposes to injectfluid into or withdraw fluidfrom body.Membrane Filter SyringeMembrane Filter Syringe isintended to be used formedical purposes to injectfluid into or withdraw fluidfrom body. The filter operateswhen injecting the drug intothe human body to removeforeign substances from thedrug solutions. | Sterile Hypodermic Needlefor single useThe Sterile HypodermicNeedle for single use isintended for use with syringesand injection devices forgeneral purpose fluidinjection/ aspiration.Sterile Hypodermic Syringefor Single Use with/withoutNeedleThe Sterile HypodermicSyringe for Single Usewith/without Needle isintended to be used formedical purposes to injectfluid into or withdraw fluidfrom body. | The Greenmedi safety filtersyringe is intended to injectthe drug solutions into thehuman body. It is designed toprevent needle stick injuries.The 0.5um filter operateswhen injecting the drug intothe human body to removeforeign substances from thedrug solutions. | |
| PrescriptionOnly or Overthe Counter | Prescription Only | Prescription Only | Prescription Only | |
| Proposed Device | Predicate Device - K190002 | SE decision | ||
| Indicationsfor Use | Single use NeedleSingle use Needle is intended for use withsyringes and injection devices for generalpurpose fluid injection / aspiration.Single use Syringe with NeedleSingle use Syringe with Needle isintended to be used for medical purposesto inject fluid into or withdraw fluidfrom body. | Sterile Hypodermic Needle for singleuseThe Sterile Hypodermic Needle for singleuse is intended for use with syringes andinjection devices for general purposefluid injection/ aspiration.Sterile Hypodermic Syringe for SingleUse with/without NeedleThe Sterile Hypodermic Syringe forSingle Use with/without Needle isintended to be used for medical purposesto inject fluid into or withdraw fluid frombody. | Same | |
| OperationMode | For manual use only | For manual use only | Same | |
| Configuration | Single use NeedleProtective cap, Needle tube,Adhesives, Needle hubSingle use Syringe with NeedlePiston, Plunger, Barrel, (Needle) | Sterile HypodermicNeedle for single useProtective cap, Needle tube,Adhesives, Needle hubSterile Hypodermic Syringe for SingleUse with/without NeedlePiston, Plunger, Barrel, (Needle) | Same | |
| Tip type | Luer Slip, Luer Lock | Luer Slip, Luer Lock | Same | |
| Principle ofoperation | Normal | Normal | Same | |
| Volume/Sizes | Single use Needle16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 26, 27,28, 29, 30 ,31(G)Single use Syringe with NeedleLuer slipSyringe Volume 1,2,2.5,3,5,10,20,30,50 | Sterile HypodermicNeedle for single use18, 19, 20, 21, 22, 23, 24, 25, 26, 27, 28,29, 30(G)Sterile Hypodermic Syringe for SingleUse with/without Needle | Difference | |
| Proposed Device | Predicate Device - K190002 | SE decision | ||
| Needle gauge | 16, 17, 18, 19, 20, 21,22, 23, 24, 25, 26, 27,28, 29, 30 ,31 (G) | Luer slipSyringeVolume1,2,3,5,10,20,30,35,50,60(ml) | ||
| Luer Lock | ||||
| Syringe Volume | 1,2,2.5,3,5,10,20,1G,1W,1B(ml) | Luer LockSyringeVolume1,2,3,5,10,20,30,35,50,60(ml) | ||
| Needle gauge | 16, 17, 18, 19, 20, 21,22, 23, 24, 25, 26, 27,28, 29, 30 ,31(G) | Needlegauge18, 19, 20, 21, 22,23, 24, 25, 26, 27,28, 29, 30(G) |
Same between proposed device and the predicate is applicable.
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Image /page/7/Picture/0 description: The image shows the logo for Hwajin. The logo is in black font, except for two orange dots above the letter 'I'. The letter 'A' is stylized to look like an upside down 'V'.
Tel: +82 (41) 554 6181 Fax:+82 (41) 554 7178
Determination of Substantial Equivalence 7.
There are no significant differences in the technological characteristics of this device compared to the predicate device which adversely affect safety or effectiveness. Provided below is a table summarizing and comparing the technological characteristics of the Sofjec and the predicate devices:
Table 1. General Comparison of Syringe with Needle.
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Image /page/8/Picture/0 description: The image shows the logo for HWAJIN. The logo is in black text, except for two orange dots above the letter 'J'. The letter 'A' is stylized to look like an upside down 'V'.
20, Seongsimwon-gil, Seongnam-myeon, Dongnam-gu, Cheonan-si, Chungcheongnam-do, Republic of Korea Tel: +82 (41) 554 6181 Fax:+82 (41) 554 7178
Different- Syringe Volume and Connector Type
The Syringe volume for proposed device is different from the predicate devices. However, this difference is just in dimension. Different volume device will be selected by physician per patient's condition. This difference does not affect intended use. Moreover, the syringe volume of the proposed syringe is covered by the syringe volume of the predicate device. Therefore, this difference does not affect substantially equivalence on safety and effectiveness.
| NeedleLengths | 4, 5, 6, 10, 13, 16, 19, 25, 32, 38 (mm) | Difference |
|---|---|---|
| 4-38mm |
Different-Needle Size and Length
The needle size and length for proposed device is different from the predicate device. However, this difference is just in dimension. Different size and length device will be selected by physician per patient's condition. This difference does not affect intended use. Moreover, the needle length of the range of the needle length of the predicate device. The needle size of the syringe is very close to that of the comparison product. Therefore, this difference does not affect substantially equivalence on safety and effectiveness with the predicate device.
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Image /page/9/Picture/0 description: The image shows the word "HWAJIN" in bold, dark gray letters. Above the letters "JI" are two orange dots. The font is sans-serif and the letters are closely spaced together.
| Proposed Device | Predicate Device - K190002 | SE decision | ||||
|---|---|---|---|---|---|---|
| Materials | Single use Needle | Sterile HypodermicNeedle for single use | Different | |||
| Part | Raw material | Part | Raw material | |||
| Protective cap | PP | Piston | Isoprene Rubber | |||
| Hub | PPPigment | Barrel | PP | |||
| Needle | Stainless Steel(SUS 304L) | Plunger | PP | |||
| Silicone | Polydimethylsiloxane | Needle Cover | PP | |||
| Needle | Stainless Steel (SUS304) | |||||
| Single use Syringe with Needle | Sterile Hypodermic Syringe for SingleUse with/without Needle | |||||
| Barrel | Polypropylene (PP) | Part | Raw material | |||
| Gasket | Thermoplastic elastomer | Protective cap | PP | |||
| Plunger | Polypropylene (PP)Pigment | Needle tube | Stainless steel (SUS304) | |||
| Silicone | Polydimethylsiloxane | Adhesives | Epoxy resin | |||
| Adhesives | Epoxy Resin | Needle hub | PP | |||
| The differences between the subject device and the predicate are the followingThe color of the plunger is pink color. The difference does not affect substantially equivalence on safety and effectiveness with the predicate. | ||||||
| Sterilization method and SAL | Sterilized by ethyleneoxide gas SAL = 10-6 | Sterilized by ethyleneoxide gas SAL = 10-6 | Same | |||
| Product performance | Complied withISO 7886-1ISO 7864ISO 9626 | Complied withISO 7886-1ISO 7864ISO 9626 | Same |
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Image /page/10/Picture/0 description: The image shows the logo for Hwajin. The logo is in a dark gray color, with the letters "HWAJIN" in a bold, sans-serif font. Above the "JI" in Hwajin are two orange dots. The logo is simple and modern.
20, Seongsimwon-gil, Seongnam-myeon, Dongnam-gu, Cheonan-si, Chungcheongnam-do, Republic of Korea Tel: +82 (41) 554 6181 Fax:+82 (41) 554 7178
| Proposed Device | Predicate Device - K173743 | SE decision | |
|---|---|---|---|
| Indicationsfor Use | Membrane Filter SyringeMembrane Filter Syringe is intended to beused for medical purposes to inject fluid intoor withdraw fluid from body. The 0.5nm filteroperates when injecting the drug into thehuman body to remove foreign substancesfrom the drug solutions. | The Greenmedi safety filter syringe isintended to inject the drug solutions intothe human body. It is designed to preventneedle stick injuries. The 0.5um filteroperates when injecting the drug into thehuman body to remove foreignsubstances from the drug solutions. | Same |
| OperationMode | For manual use only | For manual use only | Same |
| Configuration | Membrane Filter SyringeNeedle, Protective cap, Filter, Bushing,Syringe (Barrel, Gasket, Plunger) | Needle, Lubricant For needle, Hub,Protective Cap, Barrel, Lubricant Forbarrel, Plunger, Gasket, Filter, Checkvalve | Different |
| Different-ConfigurationThe configuration of proposed syringe with needle is similar as predicate device, considering the needle may becomedisengaged from the syringe when activating the syringe with luer-slip connector, therefore the proposedsyringe doesn't have the configuration of barrel with check valve. We think the difference on configuration will not raisenew questions on safety and effectiveness of the proposed device. | |||
| Principle ofoperation | Normal | Normal | Same |
| Volume/Sizes | Membrane Filter SyringeLuer slip:1,2,2.5,3,5,10,20,30,50(ml)Luer Lock:1,2,2.5,3,5,10,20,50(ml)18G Only | 2ml, 3ml, 5ml, 10ml23G | Difference |
| Different- Syringe Volume and Connector TypeThe Syringe volume for proposed device is different from the predicate devices. However, this difference is just in dimension. Different volume device will be selected by physician per patient's condition. This difference does not affect intended use. Moreover, the syringe volume of the proposed syringe with covered by the range of the syringe volume of the predicate device. Therefore, this difference does not affect needle is substantially equivalence on safety and effectiveness. | |||
| NeedleLengths | 4, 5, 6, 10, 13, 16, 19, 25, 32, 38 (mm) | 17mm | Difference |
Table 2. General Comparison of Filter Syringe
The needle size and length for proposed device is different from the predicate device. However, this difference is just in dimension. Different size and length device will be selected by physician per patient's condition. This difference does not affect intended use. Moreover, the needle length of the proposed syringe in the needle length of the predicate device. The needle size of the syringe is very close to that of the comparison product. Therefore, this difference does not affect substantially equivalence on safety and effectiveness with the predicate device.
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Image /page/11/Picture/0 description: The image shows the logo for Hwajin. The logo is black, except for two orange dots above the "I" in "Hwajin". The text is bold and sans-serif.
| Proposed Device | Predicate Device - K173743 | SE decision | |||||
|---|---|---|---|---|---|---|---|
| Materials | |||||||
| Part | Raw material | ||||||
| Needle | STS304 | ||||||
| Membrane Filter SyringeCover | Polypropylene (PP) | LubricantFor needle | Silicone Oil | ||||
| Hub | Polypropylene (PP) | Hub | Polypropylene | Different | |||
| Pigment | Protectivecap | Polypropylene | |||||
| Filter | Membrane(Polydimethylsiloxane) | Barrel | Polypropylene | ||||
| Plunger | Polypropylene(Pink) | LubricantFor barrel | Silicone Oil | ||||
| Plunger | Polypropylene (green) | ||||||
| Gasket | Thermoplastic elastomer | Gasket | Thermoplastic elastomer | ||||
| Filter | Membrane | ||||||
| Checkvalve | Silicon | ||||||
| The differences between the subject device and the predicate are the following | |||||||
| The color of the plunger is pink color. The difference does not affect substantially equivalence on safety and effectiveness. | |||||||
| Filter spec. | Membrane Filter Syringe0.5nm | 5μm | Different | ||||
| Performance testing was done on the filter to ensure that the filter achieve its intended use without affecting theflow of the drug solutions into the body. Different does not affect intended use. It is only different the filter spec. | |||||||
| Sterilizationmethod andSAL | Sterilized by ethyleneoxide gas SAL = 10-6 | Sterilized by ethyleneoxide gas SAL = 10-6 | Same | ||||
| Complied with | Complied with | ||||||
| Productperformance | ISO 7886-1 | ISO 7886-1 | Same | ||||
| ISO 7864 | ISO 7864 | ||||||
| ISO 9626 |
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Non-Clinical Test Summary
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- Biocompatibility Test
The devices were tested for biocompatibility per ISO 10993-1 Biological evaluation of medical devices -Part 1: Evaluation and testing within a risk management process.
- Biocompatibility Test
Result of evaluation test for consideration
Category: External communicating device Contact: Blood path, Indirect Contact duration: A-Limited (≤24) Test item:
- . Cytotoxicity
- In vitro hemolysis
- Skin Sensitization ●
- Pyrogen
- ◆ Acute Toxicity
- Intracutaneous reactivity ●
Particulate matter testing was conducted in accordance with USP <788> Particulate Matter in Injection and met the USP acceptance criteria.
2) Performance Test
- ISO 7864:2016 Sterile hypodermic needles for single use
- ISO 7886-1:2017 Sterile Hypodermic Syringes For Single Use
- 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 - Patt 7: Connectors for intravascular or hypodermic applications
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- Sterilization, Shelf-life Testing and Simulated Shipping
- Shelf-life test for 3years: ASTM F1980:2002 Standard Guide for Accelerated Aging of Sterile medical ● device packages
- Ethylene Oxide Sterilization Validation Test: EN ISO11135:2014 Sterilization of medical devices-Validation and routine control of sterilization by ethylene oxide sterilization.
- Ethylene oxide gas residual test : ISO10993-7:2008 Biological evaluation of medical devices -- Part 7: Ethylene oxide sterilization residuals
- Pyrogen Test: Endotoxin: USP 39, <85> Bacterial Endotoxins Tests, USP 45, <161> Medical Devices - Bacterial Endotoxin and Pyrogen Tests
- ISTA 2017 Integrity Test Procedure 2A: Simulated transportation test
Clinical Test Summary
No clinical studies were considered necessary and performed.
8. Conclusion
Based on the above information and all data provided in this submission, the comparison of intended uses, technological characteristics, and non-clinical performance testing demonstrates that the subject device is substantially equivalent to the legally marketed predicate device.
§ 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).