K Number
K231165
Device Name
Shina Syringe; Shina Safety Syringe
Date Cleared
2023-10-27

(185 days)

Product Code
Regulation Number
880.5860
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Shina Syringe, Shina Safety Syringe is a plastic sterile syringe and hypodermic single lumen needle intended to be used for medical purpose to inject fluid into or withdraw fluid from body.
Device Description
A sterile device consisting of a calibrated barrel (cylinder) with plunger intended to be used for injection/withdrawal of fluids/gas (e.g., medication) to/from a medical device or the body (i.e., capable of both); a needle is (not) included. lt is intended for various medical applications and is not dedicated to medication administration. At the distal end of the barrel is a male connector (typically Luer-lock/slip type) for the attachment to a hypodermic needle or an administration set. It is typically made of plastic and silicone materials and may have anti-stick plunger allowing smooth plunger movement, either manually or by a syringe pump. This is a single-use device.
More Information

Not Found

No
The device description and performance studies focus on the mechanical and material properties of a standard syringe and needle, with no mention of AI or ML capabilities.

No
The device is a syringe used for injecting or withdrawing fluids/gas, not for treating or preventing a disease or condition itself.

No
The device description states its purpose is to inject or withdraw fluid, not to diagnose a medical condition.

No

The device description clearly states it is a physical syringe and needle made of plastic and silicone materials, intended for injecting or withdrawing fluids. It does not mention any software components.

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

Here's why:

  • Intended Use: The intended use is to "inject fluid into or withdraw fluid from body." This describes a direct interaction with the patient's body for therapeutic or diagnostic purposes within the body, not for testing samples outside the body.
  • Device Description: The description focuses on the mechanical function of a syringe and needle for fluid transfer to or from the body or a medical device. It doesn't mention any components or processes related to analyzing biological samples.
  • Lack of IVD Characteristics: IVD devices are typically used to examine specimens (like blood, urine, tissue) to provide information about a person's health. This device does not perform any such analysis.

Therefore, the Shina Syringe and Shina Safety Syringe are medical devices used for fluid administration and withdrawal, but they do not fit the definition of an In Vitro Diagnostic device.

N/A

Intended Use / Indications for Use

Shina Syringe, Shina Safety Syringe is a plastic sterile syringe and hypodermic single lumen needle intended to be used for medical purpose to inject fluid into or withdraw fluid from body.

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

MEG, FMF, FMI

Device Description

A sterile device consisting of a calibrated barrel (cylinder) with plunger intended to be used for injection/withdrawal of fluids/gas (e.g., medication) to/from a medical device or the body (i.e., capable of both); a needle is (not) included. It is intended for various medical applications and is not dedicated to medication administration. At the distal end of the barrel is a male connector (typically Luer-lock/slip type) for the attachment to a hypodermic needle or an administration set. It is typically made of plastic and silicone materials and may have anti-stick plunger allowing smooth plunger movement, either manually or by a syringe pump. This is a single-use device.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

Indicated Patient Age Range

Adults and Pediatrics

Intended User / Care Setting

Not Found

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)

Bench test were performed. Bench testing included biocompatibility and mechanical testing. The tests demonstrated that the device performs in a substantially equivalent manner to the predicate device. The following bench testing is performed to demonstrate the functionality is substantially equivalent.
Syringe:

  • Appearance and Structure: ISO 7886-1:2017 Sterile hypodermic syringes for single use — Part 1: Syringes for manual use
  • Graduated capacity: ISO 7886-1:2017 Sterile hypodermic syringes for single use — Part 1: Syringes for manual use
  • Scale: ISO 7886-1:2017 Sterile hypodermic syringes for single use — Part 1: Syringes for manual use
  • Barrel: ISO 7886-1:2017 Sterile hypodermic syringes for single use — Part 1: Syringes for manual use
  • Plunger stopper / Plunger assembly: ISO 7886-1:2017 Sterile hypodermic syringes for single use — Part 1: Syringes for manual use
  • Nozzle: ISO 7886-1:2017 Sterile hypodermic syringes for single use - Part 1: Syringes for manual use
  • Dead Space: ISO 7886-1:2017 Sterile hypodermic syringes for single use - Part 1: Syringes for manual use
  • Freedom from liquid leakage past plunger stopper: ISO 7886-1:2017 Sterile hypodermic syringes for single use - Part 1: Syringes for manual use
  • Freedom from air leakage past plunger stopper: ISO 7886-1:2017 Sterile hypodermic syringes for single use - Part 1: Syringes for manual use
  • Force to operate the piston: ISO 7886-1:2017 Sterile hypodermic syringes for single use - Part 1: Syringes for manual use
  • Fit of plunger stopper / plunger in barrel: ISO 7886-1:2017 Sterile hypodermic syringes for single use - Part 1: Syringes for manual use
  • Amount of Silicon Oil: 0.25mg or less per square centimeter of inner area
  • EO Gas residuals: ISO 10993-7:2008 Ethylene oxide sterilization residuals
  • Sterility test: EO, ECH residuals

Needle:

  • Cleanliness: ISO 7864:2016 Sterile hypodermic needles for single use - Requirements and test methods
  • Size designation: ISO 7864:2016 Sterile hypodermic needles for single use - Requirements and test methods
  • Colour coding: ISO 7864:2016 Sterile hypodermic needles for single use - Requirements and test methods
  • Needle hub: ISO 7864:2016 Sterile hypodermic needles for single use - Requirements and test methods
  • Needle tube (Tolerances on length): ISO 7864:2016 Sterile hypodermic needles for single use - Requirements and test methods
  • Freedom from defects: ISO 7864:2016 Sterile hypodermic needles for single use - Requirements and test methods
  • Lubricant: ISO 7864:2016 Sterile hypodermic needles for single use - Requirements and test methods
  • Needle point: ISO 7864:2016 Sterile hypodermic needles for single use - Requirements and test methods
  • Bond between hub and needle tube: ISO 7864:2016 Sterile hypodermic needles for single use - Requirements and test methods
  • Patency of lumen: ISO 7864:2016 Sterile hypodermic needles for single use - Requirements and test methods
  • Sharps injury protection: ISO 23908:2011 Sharps injury protection
  • Materials: ISO 9626:2016 Stainless steel needle tubing for the manufacture of medical devices – Requirements and test methods
  • Surface finish and visual appearance: ISO 9626:2016 Stainless steel needle tubing for the manufacture of medical devices – Requirements and test methods
  • Cleanliness: ISO 9626:2016 Stainless steel needle tubing for the manufacture of medical devices – Requirements and test methods
  • Limits for acidity and alkalinity: ISO 9626:2016 Stainless steel needle tubing for the manufacture of medical devices – Requirements and test methods
  • Size designation: ISO 9626:2016 Stainless steel needle tubing for the manufacture of medical devices – Requirements and test methods
  • Dimension: ISO 9626:2016 Stainless steel needle tubing for the manufacture of medical devices – Requirements and test methods
  • Stiffness: ISO 9626:2016 Stainless steel needle tubing for the manufacture of medical devices – Requirements and test methods
  • Resistance to breakage: ISO 9626:2016 Stainless steel needle tubing for the manufacture of medical devices – Requirements and test methods
  • Resistance to corrosion: ISO 9626:2016 Stainless steel needle tubing for the manufacture of medical devices – Requirements and test methods

Syringe with needle (Model : WNLS0125):

  • Extraction : pH: Difference of pH ≤ 1.0
  • Extraction : Potassium permanganate reducing substances: Difference of the consumption ≤ 2.0 mL
  • Extraction: Residue on evaporation: Amount of residue ≤ 1.0 mg
  • Extraction: Pb, Fe, Sn, Zn: Total content of heavy metals ≤ 5.0 mg/L
  • Extraction: Cd: Content of Cd ≤ 0.1 mg/L

Syringe with needle (Model : WNLG0123, WNLS0123, WNSG0125, WNLS0125); (Model : WNLG0323, WNLS0323, WNSG0325, WNLS0325); (Model : WNLG0523, WNLS0523, WNSG0525, WNLS0525); (Model : WNLG1023, WNLS1023, WNSG1025, WNLS1025):

  • Particulate test report: USP Method 1. Light obscuration method

Safety test with ISO 23908:

  • Simulated Clinical Use: ISO 23908:2011 Sharps injury protection

Biocompatibility for 25G Model (Model : SSN2501), 23G Model (Model : SSN2301), and Syringe (Model : SSN2301):

  • Cytotoxicity: ISO 10993-5:2009 Biological evaluation of medical devices - Part 5: Tests for in vitro cytotoxicity
  • Acute systemic toxicity test: ISO 10993-11:2017 Biological evaluation of medical devices - Part 11: Tests for systemic toxicity
  • Pyrogen test: ISO 10993-11:2017 Test for systemic toxicity, pyrogen test USP
  • Sensitization test: ISO 10993-10:2010 Biological evaluation of medical devices - Part 10 Tests for irritation and skin sensitization
  • Hemolytic test: ISO 10993-4:2017, ASTM F756-17
  • Intracutaneous reactivity test: ISO 10993-23 :2021 Biological evaluation of medical devices - Part 23 Tests for irritation

The performance tests demonstrated that the subject device performs in a substantially equivalent manner to the predicate device.

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

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

K210443, K210444

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found

§ 880.5860 Piston syringe.

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

0

Image /page/0/Picture/0 description: The image contains two logos. On the left is the Department of Health & Human Services logo. On the right is the FDA logo, which includes the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text.

October 27, 2023

Shina Med Corporation % Peter Chung President Plus Global 300, Atwood street Pittsburgh, Pennsylvania 15213

Re: K231165

Trade/Device Name: Shina Syringe; Shina Safety Syringe Regulation Number: 21 CFR 880.5860 Regulation Name: Piston Syringe Regulatory Class: Class II Product Code: MEG. FMF. FMI Dated: September 22, 2023 Received: September 22, 2023

Dear Peter Chung:

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 (the 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 available 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

Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device" (https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download).

Your device is also subject to, among other requirements, the Quality System (QS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30. Design controls; 21 CFR 820.90. Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review, the QS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181).

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 Part 803) for devices or postmarketing safety reporting (21 CFR Part 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 Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.

Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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).

Sincerelv.

Juliane C. Lessard -S

Juliane C. Lessard, Ph.D. Director DHT3C: Division of Drug Delivery and General Hospital Devices,

2

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

3

Indications for Use

510(k) Number (if known)

K231165

Device Name

Shina Syringe, Shina Safety Syringe

Indications for Use (Describe)

Shina Syringe, Shina Safety Syringe is a plastic sterile syringe and hypodermic single lumen needle intended to be used for medical purpose to inject fluid into or withdraw fluid from body.

Type of Use (Select one or both, as applicable)
---------------------------------------------------

Prescription Use (Part 21 CFR 801 Subpart D)

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510(k) Summary

1. Applicant

  • Company : Shina Med Corporation 1)
    1. Address : 455-30. Bogaewonsam-ro, Anseong-si, Gyeonggi-do, Republic of Korea
    1. Tel : 82-31-8057-2125
    1. Fax :
  • Prepared date : 10/16/2023 5)
    1. Contact person : Peter Chung, 412-512-8802
    1. Contact person address : 300, Atwood Street, Pittsburgh, PA, 15213, USA
    1. Submission date : Apr. 25, 2023

2. Device Information

  • Trade name : Shina Syringe, Shina Safety Syringe 1)
    1. Common name : Piston syringe
  • Regulation name : Syringe, Antistick 2)
  • Product code : MEG / FMF, FMI 3)
    1. Regulation number : 21 CFR 880.5860
    • 21 CFR 880.5570
    1. Class of device : Class II
    1. Panel : General Hospital

3. The legally marketed device to which we are claiming equivalence

K210443, Poonglim Pharmatech Inc. / PLPT LDV (Low Dead Volume) Sterile Syringe K210444, Poonglim Pharmatech Inc. / EZ-Injec LDV Sterile safety Needle

4. Device description

A sterile device consisting of a calibrated barrel (cylinder) with plunger intended to be used for injection/withdrawal of fluids/gas (e.g., medication) to/from a medical device or the body (i.e., capable of both); a needle is (not) included. lt is intended for various medical applications and is not dedicated to medication administration. At the distal end of the barrel is a male connector (typically Luer-lock/slip type) for the attachment to a hypodermic needle or an administration set. It is typically made of plastic and silicone materials and may have anti-stick plunger allowing smooth plunger movement, either manually or by a syringe pump. This is a single-use device.

5. Intended Use

Shina Syringe, Shina Safety Syringe is a plastic sterile syringe and hypodermic single lumen needle intended to be used for medical purpose to inject fluid into or withdraw fluid from body.

6. Performance data:

  • Bench test were performed. Bench testing included biocompatibility and mechanical testing. The tests 1) demonstrated that the device performs in a substantially equivalent manner to the predicate device. The following bench testing is performed to demonstrate the functionality is substantially equivalent.
Test itemRequirements
Appearance and StructureISO 7886-1:2017 Sterile hypodermic syringes for single use — Part 1: Syringes for manual use
Graduated capacityISO 7886-1:2017 Sterile hypodermic syringes for single use — Part 1: Syringes for manual use
ScaleISO 7886-1:2017 Sterile hypodermic syringes for single use — Part 1: Syringes for manual use
BarrelISO 7886-1:2017 Sterile hypodermic syringes for single use — Part 1: Syringes for manual use
Plunger stopper / Plunger assemblyISO 7886-1:2017 Sterile hypodermic syringes for single use — Part 1: Syringes for manual use

Svringe

5

NozzleISO 7886-1:2017 Sterile hypodermic syringes for single use - Part 1: Syringes for manual use
Dead SpaceISO 7886-1:2017 Sterile hypodermic syringes for single use - Part 1: Syringes for manual use
Freedom from liquid leakage past plunger stopperISO 7886-1:2017 Sterile hypodermic syringes for single use - Part 1: Syringes for manual use
Freedom from air leakage past plunger stopperISO 7886-1:2017 Sterile hypodermic syringes for single use - Part 1: Syringes for manual use
Force to operate the pistonISO 7886-1:2017 Sterile hypodermic syringes for single use - Part 1: Syringes for manual use
Fit of plunger stopper / plunger in barrelISO 7886-1:2017 Sterile hypodermic syringes for single use - Part 1: Syringes for manual use
Amount of Silicon Oil0.25mg or less per square centimeter of inner area
EO Gas residualsISO 10993-7:2008 Ethylene oxide sterilization residuals
Sterility testEO, ECH residuals

Needle

Test itemRequirements
CleanlinessISO 7864:2016 Sterile hypodermic needles for single use - Requirements and test methods
Size designationISO 7864:2016 Sterile hypodermic needles for single use - Requirements and test methods
Colour codingISO 7864:2016 Sterile hypodermic needles for single use - Requirements and test methods
Needle hubISO 7864:2016 Sterile hypodermic needles for single use - Requirements and test methods
Needle tube (Tolerances on
length)ISO 7864:2016 Sterile hypodermic needles for single use - Requirements and test methods
Freedom from defectsISO 7864:2016 Sterile hypodermic needles for single use - Requirements and test methods
LubricantISO 7864:2016 Sterile hypodermic needles for single use - Requirements and test methods
Needle pointISO 7864:2016 Sterile hypodermic needles for single use - Requirements and test methods
Bond between hub and needle
tubeISO 7864:2016 Sterile hypodermic needles for single use - Requirements and test methods
Patency of lumenISO 7864:2016 Sterile hypodermic needles for single use - Requirements and test methods
Sharps injury protectionISO 23908:2011 Sharps injury protection
MaterialsISO 9626:2016 Stainless steel needle tubing for the manufacture of medical
devices – Requirements and test methods
Surface finish and visual appearanceISO 9626:2016 Stainless steel needle tubing for the manufacture of medical
devices – Requirements and test methods
CleanlinessISO 9626:2016 Stainless steel needle tubing for the manufacture of medical
devices – Requirements and test methods
Limits for acidity and alkalinityISO 9626:2016 Stainless steel needle tubing for the manufacture of medical
devices – Requirements and test methods
Size designationISO 9626:2016 Stainless steel needle tubing for the manufacture of medical
devices – Requirements and test methods
DimensionISO 9626:2016 Stainless steel needle tubing for the manufacture of medical
devices – Requirements and test methods
StiffnessISO 9626:2016 Stainless steel needle tubing for the manufacture of medical
devices – Requirements and test methods
Resistance to breakageISO 9626:2016 Stainless steel needle tubing for the manufacture of medical
devices – Requirements and test methods
Resistance to corrosionISO 9626:2016 Stainless steel needle tubing for the manufacture of medical
devices – Requirements and test methods

Syringe with needle (Model : WNLS0125)

Test itemRequirements
Extraction : pHDifference of pH $\leq$ 1.0
Extraction : Potassium permanganate reducingDifference of the consumption $\leq$ 2.0 mL

6

substances
Extraction: Residue on evaporationAmount of residue ≤ 1.0 mg
Extraction: Pb, Fe, Sn, ZnTotal content of heavy metals ≤ 5.0 mg/L
Extraction: CdContent of Cd ≤ 0.1 mg/L

Syringe with needle (Model : WNLG0123, WNLS0123, WNSG0125, WNLS0125)

Test itemRequirements
Particulate test reportUSP Method 1. Light obscuration method

Syringe with needle (Model : WNLG0323, WNLS0323, WNSG0325, WNLS0325)

Test itemRequirements
Particulate test reportUSP Method 1. Light obscuration method

Syringe with needle (Model : WNLG0523, WNLS0523, WNSG0525, WNLS0525)

Test itemRequirements
Particulate test reportUSP Method 1. Light obscuration method

Syringe with needle (Model : WNLG1023, WNLS1023, WNSG1025, WNLS1025)

Test itemRequirements
Particulate test reportUSP Method 1. Light obscuration method

Safety test with ISO 23908

Test itemRequirements
Simulated Clinical UseISO 23908:2011 Sharps injury protection

2) Biocompatibility

25G Model (Model : SSN2501)

#Test itemTest method / Test criteria
1CytotoxicityISO 10993-5:2009 Biological evaluation of medical devices - Part 5: Tests
for in vitro cytotoxicity
2Acute systemic toxicity
testISO 10993-11:2017 Biological evaluation of medical devices - Part 11:
Tests for systemic toxicity
3Pyrogen testISO 10993-11:2017 Test for systemic toxicity, pyrogen test
USP
4Sensitization testISO 10993-10:2010 Biological evaluation of medical devices - Part 10
Tests for irritation and skin sensitization
5Hemolytic testISO 10993-4:2017, ASTM F756-17
6Intracutaneous reactivity
testISO 10993-23 :2021 Biological evaluation of medical devices - Part 23
Tests for irritation

23G Model (Model : SSN2301)

#Test itemTest method / Test criteria
1CytotoxicityISO 10993-5:2009 Biological evaluation of medical devices - Part 5: Tests
for in vitro cytotoxicity
2Acute systemic toxicity
testISO 10993-11:2017 Biological evaluation of medical devices - Part 11:
Tests for systemic toxicity
3Pyrogen testISO 10993-11:2017 Test for systemic toxicity, pyrogen test
USP
4Sensitization testISO 10993-10:2010 Biological evaluation of medical devices – Part 10
Tests for irritation and skin sensitization
5Hemolytic testISO 10993-4:2017, ASTM F756-17
6Intracutaneous reactivity
testISO 10993-23:2021 Biological evaluation of medical devices – Part 23
Tests for irritation

7

Syringe (Model : SSN2301)

#Test itemTest method / Test criteria
1CytotoxicityISO 10993-5:2009 Biological evaluation of medical devices - Part 5: Tests
for in vitro cytotoxicity
2Acute systemic toxicity
testISO 10993-11:2017 Biological evaluation of medical devices - Part 11:
Tests for systemic toxicity
3Pyrogen testISO 10993-11:2017 Test for systemic toxicity, pyrogen test
USP
4Sensitization testISO 10993-10:2010 Biological evaluation of medical devices – Part 10
Tests for irritation and skin sensitization
5Hemolytic testISO 10993-4:2017, ASTM F756-17
6Intracutaneous reactivity
testISO 10993-23 :2021 Biological evaluation of medical devices – Part 23
Tests for irritation

The performance tests demonstrated that the subject device performs in a substantially equivalent manner to the predicate device.

7. Predicate device comparison table

ManufacturerShina Med CorporationPoonglim Pharmatech Inc.Poonglim Pharmatech Inc.Remark
510(k) No.K210443K210444N/A
Indication for
useShina Syringe, Shina Safety
Syringe is a plastic sterile
syringe and hypodermic
single lumen needle
intended to be used for
medical purpose to inject
fluid into or withdraw fluid
from body.PLPT LDV (Low Dead Volume)
Sterile Syringe is intended to
be used for medical purpose
to inject fluid into or withdraw
fluid from body.This produce is intended for
use to inject fluid into or
withdraw fluids from parts of
the body below the surface of
the skin.Identical
Classification
nameSyringe, AntistickLow Dead Space Piston
SyringeLow Dead Space Needle,
Single Lumen, HypodermicDifferent
Trade nameShina Syringe, Shina Safety
SyringePLPT LDV (Low Dead Volume)
Sterile SyringeEZ-Injec LDV Sterile Safety
NeedleN/A
Model/type40 Models including WOS01--N/A
ComponentsNeedle, Hub, Safety cover,
Barrel, Gasket, PlungerBarrel, Gasket, PlungerNeedle, Hub, Safety coverIdentical
Nozzle typeLock and Slip typeLock typeLock and Slip typeIdentical
Materials
Needle
Hub
Safety cover
Barrel
Gasket
PlungerStainless Steel
PP
PP
PP
Hydrogenated styrene
isoprene butadiene block
copolymer
PPPP
Rubber
PPStainless Steel
PP
PPDifferent
Capacity1mL, 3mL, 5mL, 10mL1mL-Different
Needle Gauge23G, 25G-25GDifferent
Needle Length25.4mm-25mmDifferent
Sharps FunctionSafety Guard-Safety GuardIdentical
Principle of
operationManualManualManualIdentical
PerformancesISO 7886
ISO 7864
ISO 9626
USP
ISO 23908ISO 7886ISO 7864
ISO 9626
ISO 23908
USPIdentical

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ManufacturerShina Med CorporationPoonglim Pharmatech Inc.Poonglim Pharmatech Inc.Remark
BiocompatibilityCytotoxicityCytotoxicityCytotoxicityIdentical
Acute systemic toxicityAcute systemic toxicityAcute systemic toxicity
PyrogenicityPyrogenicityPyrogenicity
SensitizationSensitizationSensitization
HemolysisIrritationIrritation
Intracutaneous testHemocompatibilityHemocompatibility
Sterilization
MethodEO gasEO gasEO gasIdentical
PopulationsAdults and PediatricsAdults and PediatricsAdults and PediatricsIdentical
Dead spaceMeets ISO 7886-1 standardLess than 0.0023mL with 95%
confidence and 95% reliabilityLess than 0.0054mL with 95%
confidence and 95% reliabilityDifferent
    1. Different classification name
      We set K210443 and K210444 as predicate devices. The product code is set differently to MEG for subject device and QNQ for predicate device respectively. However, K210443 and K210444 were set as predicate devices because of the similarity in appearance and purpose of use of needles and syringes with safety features.
    1. Different syringe capacity
      The volume of the syringe is 1mL for the predicate device and 1ml, 3mL and 10mL for the subject device. Syringes with a volume larger than 1 mL are not included in the range, but tests were performed that included each syringe under ISO 7886 standard.
    1. Different needle gauge
      The gauge of the needle is 25G for the predicate device and 23G for the subject device. 23G needles are not included in the range, but both the 23G and 25G have been tested for performance under ISO 7864 and ISO 9626 standards.
    1. Different needle length
      The needle of the subject device is 25.4mm while the needle length of the predicate device is 25mm. Through testing of ISO 7864 and ISO 9626, the needle length of the subject device has been evaluated for substantial equivalence.
    1. Different materials
      All materials are not identical. Only gasket material is different. Subject device had been performed the biocompatibility tests according to ISO 10993 series to meet the toxicity endpoints.
    1. Different dead space
      The subject device was tested to meet the dead space requirements of ISO 7886-1. The predicate device is a low dead volume syringe and needle while the subject device is not a low dead volume device. Although the subject device does not meet a lower dead space specification, it still meets the ISO 7886-1 recommendations to perform its intended use.

8. Conclusion

The device is investigated for function to compare the operation of function between Shina Syringe, Shina Safety Syringe and predicate devices.

Comparison results demonstrate that the specifications and performance of the device are substantially equivalent to the legally marketed predicate device.

Therefore, it is concluded that Shina Syringe, Shina Safety Syringe are substantially equivalent to the legally marketed predicate devices.