K Number
K223353
Device Name
DropSafeTM SicuraTM
Manufacturer
Date Cleared
2022-12-02

(30 days)

Product Code
Regulation Number
880.5570
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
The DropSafe™ Sicura™ are sterile, single-use passive safety injection needles to be used in combination with a (pre-)filled syringe for subcutaneous and intramuscular injection.
Device Description
DropSafe™ Sicura™ are Sterile, single-use passive safety injection needles to be used in combination with a (pre-)filled syringe for subcutaneous and intramuscular injection. DropSafe™ Sicura™ are single patient and used by HCP (Healthcare professionals: nurses, pharmacist and physician). DropSafe™ Sicura™ passive safety injection needles, are hypodermic needles intended for subcutaneous and intramuscular injection of fluids using syringes with male luer slip or luer lock fitting. Passive safety injection needles are equipped with passive sharps prevention feature. They are sterilized with ETO. Non-toxic single use, single patient devices. The device is designed to minimize the risk from accidental needle sticks with an already used needle by application of a sharps injury prevention feature. Following use, the slider of the needle is automatically locked out preventing reuse. The needle is protected by an external cover, the cover must be in place during the connection between the needle and the syringe. After removing the external cover the needle is still protected by a transparent slider, the slider will protect the needle and the user during the injection activity (sharp prevention feature). The slider is transparent for allowing the user to have a clear view of the cannula during the injection. During the injection the slider progressively uncovers the cannula; this action is possible thanks to the presence of two components (spring and sleeve) which let the slider moves up and down. Once the injection is done and the needle removed from the slider automatically covers the cannula and remain blocked, guaranteeing the sharp prevention feature. The confirmation about the blocking is done thanks to the appearing of red marks visible through the housing. DropSafe™ Sicura™ is not intended to be used for the drawing up of drugs from vials and/or ampule, for which it's indicated to use blunt needles. Each DropSafe™ Sicura™ is individually packaged in a sealed container. The DropSafe™ Sicura™ is used by opening the blister and applying the needle on a syringe filled with drug. While inserting the needle into the skin at a 90° or 45° angle (with or without skin fold), the slider glides into the housing. While the slider glides into the housing, the safety feature is activated. Following injection, the slider glides back into its initial position, completely covering the needle where it remains locked. The red safety lock indicator tells the user that the safety lock has been activated. Once the DropSafe™ Sicura™ is in the locked mode, it cannot be reused. The DropSafe™ Sicura™ is detached from the syringe and disposed of into a sharps container according to local requirements. The DropSafe™ Sicura™ assembly consists of a cannula that is assembled into an injection molded hub using an UV glue. The hub has been designed in order to guarantee a proper connection with luer lock and luer slip nozzle of syringes. The cannula is lubricated using a silicone-based lubricant for ease of injection and thus reduce friction during the injection. The other components that are assembled onto hub/cannula components are stainless steel spring, injection molded housing, sleeve with red coloured stripes and slider. The coupling of spring, sleeve and slider let have the safety prevention feature of the device, avoiding accidental needle-sticks. This needle assembly is inserted into a protective injection molded cover and blistered with a peel away medical grade paper which provides a sterility barrier.
More Information

No
The device description focuses on mechanical components and passive safety features, with no mention of AI or ML.

No.
This device is a passive safety injection needle for administering fluids, but it does not have an inherent therapeutic effect itself. Its primary function is to facilitate the injection safely and prevent needlestick injuries.

No

This device is a safety injection needle used for administering fluids, not for diagnosing conditions or diseases. Its primary purpose is to ensure safe injection and prevent accidental needle sticks.

No

The device description clearly details physical components like needles, hubs, springs, sleeves, and covers, and describes mechanical actions for safety features. There is no mention of software as part of the device's functionality.

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

Here's why:

  • Intended Use: The intended use is for subcutaneous and intramuscular injection of fluids using a syringe. This is a direct medical intervention on the patient's body for delivering medication.
  • Device Description: The device is a safety injection needle designed to prevent needlestick injuries during and after injection. It is used in combination with a syringe to administer substances into the body.
  • Lack of IVD Characteristics: IVD devices are used to examine specimens derived from the human body (like blood, urine, tissue) to provide information for diagnosis, monitoring, or screening. The DropSafe™ Sicura™ does not perform any such analysis or testing of bodily specimens.

The device is clearly intended for the administration of substances into the body, which falls under the category of medical devices used for treatment or intervention, not in vitro diagnosis.

N/A

Intended Use / Indications for Use

The DropSafe™ Sicura™ are sterile, single-use passive safety injection needles to be used in combination with a (pre-)filled syringe for subcutaneous and intramuscular injection.

Product codes

FMI

Device Description

DropSafe™ Sicura™ are Sterile, single-use passive safety injection needles to be used in combination with a (pre-)filled syringe for subcutaneous and intramuscular injection.

DropSafe™ Sicura™ are single patient and used by HCP (Healthcare professionals: nurses, pharmacist and physician).

DropSafe™ Sicura™ passive safety injection needles, are hypodermic needles intended for subcutaneous and intramuscular injection of fluids using syringes with male luer slip or luer lock fitting. Passive safety injection needles are equipped with passive sharps prevention feature. They are sterilized with ETO. Non-toxic single use, single patient devices.

The device is designed to minimize the risk from accidental needle sticks with an already used needle by application of a sharps injury prevention feature. Following use, the slider of the needle is automatically locked out preventing reuse. The needle is protected by an external cover, the cover must be in place during the connection between the needle and the syringe.

After removing the external cover the needle is still protected by a transparent slider, the slider will protect the needle and the user during the injection activity (sharp prevention feature). The slider is transparent for allowing the user to have a clear view of the cannula during the injection.

During the injection the slider progressively uncovers the cannula; this action is possible thanks to the presence of two components (spring and sleeve) which let the slider moves up and down.

Once the injection is done and the needle removed from the slider automatically covers the cannula and remain blocked, guaranteeing the sharp prevention feature.

The confirmation about the blocking is done thanks to the appearing of red marks visible through the housing.

DropSafe™ Sicura™ is not intended to be used for the drawing up of drugs from vials and/or ampule, for which it's indicated to use blunt needles.

Each DropSafe™ Sicura™ is individually packaged in a sealed container. The DropSafe™ Sicura™ is used by opening the blister and applying the needle on a syringe filled with drug. While inserting the needle into the skin at a 90° or 45° angle (with or without skin fold), the slider glides into the housing. While the slider glides into the housing, the safety feature is activated. Following injection, the slider glides back into its initial position, completely covering the needle where it remains locked. The red safety lock indicator tells the user that the safety lock has been activated. Once the DropSafe™ Sicura™ is in the locked mode, it cannot be reused. The DropSafe™ Sicura™ is detached from the syringe and disposed of into a sharps container according to local requirements.

The DropSafe™ Sicura™ assembly consists of a cannula that is assembled into an injection molded hub using an UV glue. The hub has been designed in order to guarantee a proper connection with luer lock and luer slip nozzle of syringes. The c a n n u l a i s lubricated using a silicone-based lubricant for ease of injection and thus reduce friction during the injection. The other components that are assembled onto hub/cannula components are stain less steel spring, injection molded housing, sleeve with red coloured stripes and slider. The coupling of spring, sleeve and slider let have the safety prevention feature of the device, avoiding accidental needle-sticks. This needle assembly is inserted into a protective injection molded cover and blistered with a peel away medical grade paper which provides a sterility barrier.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Body parts below the surface of the skin (for injection into, or withdrawal of fluids from)

Indicated Patient Age Range

Not Found

Intended User / Care Setting

HCP (Healthcare professionals: nurses, pharmacist and physician)

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)

Non-Clinical Performance Data:
Verification/Validation testing was conducted in compliance with the requirements of ISO 7864:2016, ISO 9626:2016, ISO 23908:2011 and ISO 80369-7:2021 as summarized below. All testing met the applicable requirements.
Test parameter: Cannula Materials; Requirement: The needle shall be made of tubing materials specified in ISO 9626:2016 and ISO 15510:2014; Result: Meets standard.
Test parameter: Dimensions; Requirement: The needles diameters are in compliance with clause 4.10.1 of ISO 7864:2016 and requirements of ISO 9626:2016. Tolerances on lengths shall be in accordance to ISO 7864:2016(clause 4.10.2); Result: Meets standard.
Test parameter: Bond between hub and needle tube; Requirement: The union of the hub and needle tube shall not break when tested in accordance to ISO 7864 (Clause 4.12); Result: Meets standard.
Test parameter: Freedom from defects; Requirement: The needle tube shall fulfill the requirements of ISO 7864 (clause 4.10.3); Result: Meets standard.
Test parameter: Lubrication; Requirement: The needle tube should be lubricated. The lubricant shall not, under normal or corrected- to-normal vision, bevisible as droplets of fluid on the outer or inner surfaces of the needle tube. The quantity of lubricant used should not exceed 0.25 mg/cm² of the lubricated surface area of the needle tube; Result: Meets standard.
Test parameter: Cleanliness; Requirement: When inspected by normal or corrected-to-normal vision without magnification under an illuminance of 300 lx to 700 lx, the surface of the hypodermic needle tube shall appear free from particles and extraneous matter. When examined under 2,5x magnification, the hub socket (fluid path surface) shall appear free from particles and extraneous matter; Result: Meets standard.
Test parameter: Limits for Acidity or Alkalinity; Requirement: When determined with a laboratory pH meter and using a general purpose electrode, the pH value of an extract prepared in accordance with Annex A shall be within one unit of pH of that of the control fluid; Result: Meets standard.
Test parameter: Limits for extractable metals; Requirement: When tested by a recognized microanalytical method, for example by an atomic absorption method, an extract prepared in accordance with Annex A shall, when corrected for the metals content of the control fluid, contain not greater than a combined total of 5 mg/l of lead, tin, zinc and iron. The cadmium content of the extract shall, when corrected for the cadmium content of the control fluid, be lower than 0,1 mg/l; Result: Meets standard.
Test parameter: Color of hub; Requirement: The hub shall be made either of pigmented or of unpigmented material. If pigmented, the color shall be in accordance with ISO 6009; Result: Meets standard.
Test parameter: Needle point; Requirement: When examined under 2.5x magnification the needle point shall appear sharp and free from feather edges, burrs and hooks. The needle point should be designed so as to minimize coring and fragmentation when penetrating vial closures. Penetration testing can provide an indication of the needle point sharpness and lubrication; Result: Meets standard.
Test parameter: Patency of lumen; Requirement: the flow rate of water through the needle shall not be less than 80 % of an unprocessed needle tube of equivalent outer diameter and length having a minimum inner diameter in accordance with ISO 9626 when tested under the same pressure; Result: Meets standard.
Test parameter: Sharp injury protection; Requirement: The needle shall meet the requirements of ISO 23908, the conformity to this standard has been verified also through usability and Sharps injury prevention studies; Result: Meets standard.
Test parameter: Hub conical fitting; Requirement: The conical socket of the hypodermic needle hub shall meet the requirements of ISO 80369-7; Result: Meets standard.
Test parameter: Sterility and Biocompatibility; Requirement: The needle in its unit packaging shall have been subjected to a validated sterilization process resulting in a Sterility Assurance Level of at least 10-6 in accordance with recognized ISO standards. The needle shall be free from biological hazard in accordance with the requirements of ISO 10993-1; Result: Meets standard.

Clinical Performance Data:
Simulated Use Study: Performed to validate the Instructions For Use (IFU) with the participation of clinical users. The study evidenced that the use of this device does not affect the injection technique or the functionality of the hypodermic needle coupled with a hypodermic syringe and is safe and effective when used as per the Instructions for Use.

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

Not Found

Predicate Device(s)

K111797

Reference Device(s)

K051865

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 880.5570 Hypodermic single lumen needle.

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

0

Image /page/0/Picture/0 description: The image 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 the FDA logo, which is a blue square with the letters "FDA" in white. Underneath the square are the words "U.S. FOOD & DRUG ADMINISTRATION" in blue.

December 2, 2022

Pikdare SpA % Dave Yungvirt CEO Third Party Review Group, LLC 25 Independence Blvd Warren, New Jersey 07059

Re: K223353

Trade/Device Name: DropSafe™ Sicura™ Regulation Number: 21 CFR 880.5570 Regulation Name: Hypodermic single lumen needle Regulatory Class: Class II Product Code: FMI Dated: October 30, 2022 Received: November 2, 2022

Dear Dave Yungvirt:

We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976. the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.

1

Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about 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.

Image /page/1/Picture/5 description: The image shows a digital signature. The signature is by Courtney Evans -S. The date of the signature is 2022.12.02. The time of the signature is 11:41:35 -05'00'.

For 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

2

Indications for Use

510(k) Number (if known) K223353

Device Name DropSafeTM Sicura™

Indications for Use (Describe)

The DropSafe™ Sicura™ are sterile, single-use passive safety injection needles to be used in combination with a (pre-)filled syringe for subcutaneous and intramuscular injection

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)

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3

510(k) Summary - K223353

As required by the Safe Medical Devices Act of 1990 and in accordance with 21 CFR §807.92(a).

[807.92 (a)(1,2)]

| Date Summary

Prepared:July 20, 2022
Submitted By:Pikdare S.p.A
Via Saldarini Catelli 10
22070 Casnate con Bernate – COMO - Italy
Phone: +39 031 7297757
Primary Contact:Roberta Zanoni - RA
roberta.zanoni@pikdare.com
Secondary Contact:Sylvie verdon - RA US
Sylvie.Verdon@htl-strefa.com
Trade Name:DropSafe™ Sicura™

Models:

Reference numberDescription
02094000180250DropSafe™ Sicura™ G18X25
02094000210250DropSafe™ Sicura™ G21X25
02094000220250DropSafe™ Sicura™ G22X25
02094000230250DropSafe™ Sicura™ G23X25
02094000250160DropSafe™ Sicura™ G25X16
02094000250250DropSafe™ Sicura™ G25X25
02094000270130DropSafe™ Sicura™ G27X13
02094000300130DropSafe™ Sicura™ G30X13
Common Name:Passive Safety Injection Needle
Regulation Number:21 CFR § 880.5570
Product Code:FMI
Device Classification:II
Review Panel:80 General Hospital

Section 8 Page 1 of 10

4

Predicate Device

[807.92(a)(3)]

The legally marketed devices to which substantial equivalence is claimed are:

ManufacturerTrade Name510(k) Number
Terumo Europe NVK-pack SurshieldTMK111797

Description of Device:

[807.92(a)(4)]

Device description

DropSafe™ Sicura™ are Sterile, single-use passive safety injection needles to be used in combination with a (pre-)filled syringe for subcutaneous and intramuscular injection.

DropSafe™ Sicura™ are single patient and used by HCP (Healthcare professionals: nurses, pharmacist and physician).

DropSafe™ Sicura™ passive safety injection needles, are hypodermic needles intended for subcutaneous and intramuscular injection of fluids using syringes with male luer slip or luer lock fitting. Passive safety injection needles are equipped with passive sharps prevention feature. They are sterilized with ETO. Non-toxic single use, single patient devices.

The device is designed to minimize the risk from accidental needle sticks with an already used needle by application of a sharps injury prevention feature. Following use, the slider of the needle is automatically locked out preventing reuse. The needle is protected by an external cover, the cover must be in place during the connection between the needle and the syringe.

After removing the external cover the needle is still protected by a transparent slider, the slider will protect the needle and the user during the injection activity (sharp prevention feature). The slider is transparent for allowing the user to have a clear view of the cannula during the injection.

During the injection the slider progressively uncovers the cannula; this action is possible thanks to the presence of two components (spring and sleeve) which let the slider moves up and down.

Once the injection is done and the needle removed from the slider automatically covers the cannula and remain blocked, guaranteeing the sharp prevention feature.

The confirmation about the blocking is done thanks to the appearing of red marks visible through the housing.

DropSafe™ Sicura™ is not intended to be used for the drawing up of drugs from vials and/or ampule, for which it's indicated to use blunt needles.

Each DropSafe™ Sicura™ is individually packaged in a sealed container. The DropSafe™ Sicura™ is used by opening the blister and applying the needle on a syringe filled with drug. While inserting the needle into the skin at a 90° or 45° angle (with or without skin fold), the

Section 8 Page 2 of 10

5

slider glides into the housing. While the slider glides into the housing, the safety feature is activated. Following injection, the slider glides back into its initial position, completely covering the needle where it remains locked. The red safety lock indicator tells the user that the safety lock has been activated. Once the DropSafe™ Sicura™ is in the locked mode, it cannot be reused. The DropSafe™ Sicura™ is detached from the syringe and disposed of into a sharps container according to local requirements.

The DropSafe™ Sicura™ assembly consists of a cannula that is assembled into an injection molded hub using an UV glue. The hub has been designed in order to guarantee a proper connection with luer lock and luer slip nozzle of syringes. The c a n n u l a i s lubricated using a silicone-based lubricant for ease of injection and thus reduce friction during the injection. The other components that are assembled onto hub/cannula components are stain less steel spring, injection molded housing, sleeve with red coloured stripes and slider. The coupling of spring, sleeve and slider let have the safety prevention feature of the device, avoiding accidental needle-sticks. This needle assembly is inserted into a protective injection molded cover and blistered with a peel away medical grade paper which provides a sterility barrier.

6

Indications for Use:

[807.92(a)(5)]

The DropSafe™ Sicura™ are sterile, single-use passive safety injection needles to be used in combination with a (pre-)filled syringe for subcutaneous and intramuscular injection.

Technological Characteristics:

[807.92(a)(6)]

A comparison of characteristics of DropSafe™ Sicura™ and the predicate d e v i c e s is shown in the table below:

Device NameNew DevicePredicate Device
ManufacturerPikdare SPATerumo Europe NV
510(k) NumberK223353K111797
Intended useSterile, single-use passive safety
injection needle to be used in
combination with a (pre-)filled
syringe for subcutaneous and
intramuscular injectionA single use injection needle with an
integrated passive sharps protection
feature designed to reduce needle stick
injury and to be used in combination
with a (pre-)filled syringe for
subcutaneous and intramuscular
injection
Indication for
useSterile, single-use passive safety
injection needle to be used in
combination with a (pre-)filled
syringe for subcutaneous and
intramuscular injectionThe K-Pack Surshield™ Needle is a
sterile hypodermic needle for single use
with a passive sharps protection feature
that covers the cannula immediately and
permanently after use; and is intended for
use in combination with hypodermic
syringes for subcutaneous and
intramuscular injection.
Operation
principleManualManual

7

| Design | Injection moulded Hub
Cannula
Glue
Spring
Injection moulded Sleeve
Injection moulded Slider
Injection moulded Housing
Injection moulded Cover
Blister | Injection moulded hub
Cannula
Glue
Injection moulded tube
Spring
Injection moulded grip
Injection moulded sleeve
Injection moulded slider
Injection moulded housing
Injection moulded case
Injection moulded cap
Paper seal |
|--------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Product Code | FMI | FMI |

8

| Device Name | Subject Device | Predicate
Device | |
|------------------|--------------------------------------------|-------------------------------------|----------------------|
| Length | 25 mm - 16 mm - 13mm | 1/2" (12mm) | |
| Gauges | G18 - G21 - G22 - G23 - G25 -
G27 - G30 | 27G | |
| Materials | Cannula | Stainless Steel | Stainless Steel |
| | Hub | Polypropylene
Medical Grade | Polypropylene |
| | Housing | Polypropylene
Medical Grade | Plastic moulded part |
| | Cover | Polypropylene
Medical Grade | Plastic moulded part |
| | Slider | Polycarbonate
Medical Grade (PC) | Plastic moulded part |
| | Sleeve | ABS (Food grade) | Plastic moulded part |
| | Spring | Stainless steel wire | Stainless steel wire |
| | Glue | UV Glue | UV Glue |
| Lubricant | Silicone Medial Grade | Silicone Medical Grade | |
| Blister | Medical Paper and Plastic Film | | |
| Biocompatibility | Conforms toISO
10993-1 | Conforms to
ISO 10993-1 | |
| Sterilization | Ethylene Oxide | Ethylene Oxide | |

The new device and the predicate device are classified under 21 CFR 880.5570, which states: "A hypodermic single lumen needle is a device intended to inject fluids into, or withdraw fluids from, parts of the body below the surface of the skin." The intended use of the devices is identical (intended for use with pre-filled syringes). Based upon the above comparisons to the predicate device, DropSafe™ passive safety injection needles do not raise any new issues of safety of effectiveness

9

Reference Device

Manufacturer NameTrade Name510(k) Number
Terumo CorpSurGuard 2 SafetyK051865
Needle

The reference device has been included in this submission to cover the gage and lengths of the New Device. The difference between the New Device and the Reference Device is the sharps prevention feature: the new device includes a sharp prevention feature based on an active sharp prevention system and Reference Device includes a Sharp prevention feature based on a passive sharp prevention system. The Reference device has been considered taking into account the offered lengths and gauges of the hypodermic needle included in a safety needle.

10

Non-Clinical Performance Data:

[(807.92(b)(1)]

Verification/Validation testing was conducted in compliance with the requirements of ISO 7864:2016, ISO 9626:2016, ISO 23908:2011 and ISO 80369-7:2021 as summarized below. All testing met the applicable requirements.

Test parameterRequirementResult
Cannula MaterialsThe needle shall be made of tubing materials
specified in ISO 9626:2016 and
ISO 15510:2014.Meets standard
DimensionsThe needles diameters are in compliance
with clause 4.10.1 of ISO 7864:2016 and
requirements of ISO 9626:2016.
Tolerances on lengths shall be in
accordance to ISO 7864:2016(clause
4.10.2)Meets standard
Bond between hub and
needle tubeThe union of the hub and needle tube shall not break
when tested in accordance to ISO 7864 (Clause
4.12).Meets standard
Freedom from defectsThe needle tube shall fulfill the requirements of ISO
7864 (clause 4.10.3)Meets standard
LubricationThe needle tube should be lubricated. The lubricant
shall not, under normal or corrected- to-normal
vision, bevisible as droplets of fluid on the outer or
inner surfaces of the needle tube. The quantity of
lubricant used should not exceed 0.25 mg/cm² of the
lubricated surface area of the needle tubeMeets standard
CleanlinessWhen inspected by normal or corrected-to-normal
vision without magnification under an illuminance
of 300 lx to 700 lx, the surface of the hypodermic
needle tube shall appear free from particles and
extraneous matter. When examined under 2,5×
magnification, the hub socket (fluid path surface)
shall appear free from particles and extraneous
matter.Meets standard
Limits for Acidity or
AlkalinityWhen determined with a laboratory pH meter and
using a general purpose electrode, the pH value of
an extract prepared in accordance with Annex A
shall be within one unit of pH of that of the control
fluid.Meets standard
Limits for extractable
metalsWhen tested by a recognized microanalytical
method, for example by an atomic absorption
method, an extract prepared in accordance with
Annex A shall, when corrected for the metals
content of the control fluid, contain not greater than
a combined total of 5 mg/l of lead, tin, zinc and
iron. The cadmium content of the extract shall,
when corrected for the cadmium content of the
control fluid, be lower than 0,1 mg/lMeets standard
Color of hubThe hub shall be made either of pigmented or of
unpigmented material. If pigmented, the color shall
be in accordance with ISO 6009.Meets standard
Needle pointWhen examined under 2.5× magnification the
needle point shall appear sharp and free from
feather edges, burrs and hooks.Meets standard
The needle point should be designed so as to
minimize coring and fragmentation when
penetrating vial closures
Penetration testing can provide an indication of the
needle point sharpness and lubrication
Patency of lumenthe flow rate of water through the needle shall not
be less than 80 % of an unprocessed needle tube of
equivalent outer diameter and length having a
minimum inner diameter in accordance with ISO
9626 when tested under the same pressure.Meets standard
Sharp injury
protectionThe needle shall meet the requirements of ISO
23908, the conformity to this standard has been
verified also through usability and Sharps injury
prevention studiesMeets standard
Hub conical fittingThe conical socket of the hypodermic needle hub
shall meet the requirements of ISO 80369-7Meets standard
Sterility and
BiocompatibilityThe needle in its unit packaging shall have been
subjected to a validated sterilization process
resulting in a Sterility Assurance Level of at least
10-6 in accordance with recognized ISO standards.Meets standard
The needle shall be free from biological hazard in
accordance with the requirements of ISO 10993-1.

Section 8 Page 8 of 10

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Clinical Performance Data:

[(807.92(b)(2)]

FDA GUIDANCE Medical Devices with Sharps Injury Prevention Features (issued on August 9, 2005).

Testing was performed to evaluate the function of the safety feature in a simulated clinical environment with the participation of clinical users. The Simulated Use Study was performed to validate the Instructions For Use (IFU) with the participation of clinical users. As evidenced in the study, the use of this device does not affect the injection technique or the functionality of the hypodermic needle coupled with a hypodermic syringe and is safe and effective when used as per the Instructions for Use.

Conclusion:

[(807.92(b)(3)]

DropSafe™ Sicura™ is substantially equivalent in the intended use, technology/principle of operation and performance to the predicate devices and do not raise any new questions of safety and effectiveness.