K Number
K231165
Date Cleared
2023-10-27

(185 days)

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

AI/ML Overview

This document describes the acceptance criteria and study proving the device meets those criteria for the Shina Syringe and Shina Safety Syringe.

The listed information primarily focuses on bench testing for mechanical, physical, and biocompatibility properties, rather than effectiveness studies involving human subjects or AI-assisted diagnoses. Therefore, several requested sections, particularly those related to clinical studies, human readers, ground truth establishment for training sets, and effect sizes of AI assistance, are not applicable based on the provided text.


1. Table of Acceptance Criteria and Reported Device Performance

The device performance is demonstrated by compliance with various ISO standards and USP <788>. The document does not explicitly present specific numerical results for each test item but states that the tests demonstrated that the device performs in a substantially equivalent manner to the predicate device and meets the requirements.

Syringe

Test ItemAcceptance Criteria (Standard)Reported Device Performance
Appearance and StructureISO 7886-1:2017 Sterile hypodermic syringes for single use — Part 1: Syringes for manual useDemonstrated substantial equivalence
Graduated capacityISO 7886-1:2017 Sterile hypodermic syringes for single use — Part 1: Syringes for manual useDemonstrated substantial equivalence
ScaleISO 7886-1:2017 Sterile hypodermic syringes for single use — Part 1: Syringes for manual useDemonstrated substantial equivalence
BarrelISO 7886-1:2017 Sterile hypodermic syringes for single use — Part 1: Syringes for manual useDemonstrated substantial equivalence
Plunger stopper / Plunger assemblyISO 7886-1:2017 Sterile hypodermic syringes for single use — Part 1: Syringes for manual useDemonstrated substantial equivalence
NozzleISO 7886-1:2017 Sterile hypodermic syringes for single use — Part 1: Syringes for manual useDemonstrated substantial equivalence
Dead SpaceISO 7886-1:2017 Sterile hypodermic syringes for single use — Part 1: Syringes for manual useMeets ISO 7886-1 standard
Freedom from liquid leakage past plunger stopperISO 7886-1:2017 Sterile hypodermic syringes for single use — Part 1: Syringes for manual useDemonstrated substantial equivalence
Freedom from air leakage past plunger stopperISO 7886-1:2017 Sterile hypodermic syringes for single use — Part 1: Syringes for manual useDemonstrated substantial equivalence
Force to operate the pistonISO 7886-1:2017 Sterile hypodermic syringes for single use — Part 1: Syringes for manual useDemonstrated substantial equivalence
Fit of plunger stopper / plunger in barrelISO 7886-1:2017 Sterile hypodermic syringes for single use — Part 1: Syringes for manual useDemonstrated substantial equivalence
Amount of Silicon Oil0.25mg or less per square centimeter of inner areaDemonstrated substantial equivalence
EO Gas residualsISO 10993-7:2008 Ethylene oxide sterilization residualsReported Compliance
Sterility testEO, ECH residualsReported Compliance

Needle

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

Syringe with needle (Model : WNLS0125)

Test ItemAcceptance CriteriaReported Device Performance
Extraction : pHDifference of pH $\leq$ 1.0Reported Compliance
Extraction : Potassium permanganate reducing substancesDifference of the consumption $\leq$ 2.0 mLReported Compliance
Extraction: Residue on evaporationAmount of residue $\leq$ 1.0 mgReported Compliance
Extraction: Pb, Fe, Sn, ZnTotal content of heavy metals $\leq$ 5.0 mg/LReported Compliance
Extraction: CdContent of Cd $\leq$ 0.1 mg/LReported Compliance

Syringe with needle (Particulate test for various models including WNLG0123, WNLS0123, WNSG0125, WNLS0125, WNLG0323, WNLS0323, WNSG0325, WNLS0325, WNLG0523, WNLS0523, WNSG0525, WNLS0525, WNLG1023, WNLS1023, WNSG1025, WNLS1025)

Test ItemAcceptance CriteriaReported Device Performance
Particulate test reportUSP <788> Method 1. Light obscuration methodReported Compliance

Safety test

Test ItemAcceptance Criteria (Standard)Reported Device Performance
Simulated Clinical UseISO 23908:2011 Sharps injury protectionReported Compliance

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

Test ItemAcceptance Criteria (Standard)Reported Device Performance
CytotoxicityISO 10993-5:2009 Biological evaluation of medical devices - Part 5Reported Compliance
Acute systemic toxicity testISO 10993-11:2017 Biological evaluation of medical devices - Part 11Reported Compliance
Pyrogen testISO 10993-11:2017 Test for systemic toxicity, pyrogen test USP <151>Reported Compliance
Sensitization testISO 10993-10:2010 Biological evaluation of medical devices - Part 10Reported Compliance
Hemolytic testISO 10993-4:2017, ASTM F756-17Reported Compliance
Intracutaneous reactivity testISO 10993-23:2021 Biological evaluation of medical devices - Part 23Reported Compliance

2. Sample size used for the test set and the data provenance

The document does not explicitly state the sample size for each bench test conducted. The provenance of the data is that these are bench tests conducted by the manufacturer, Shina Med Corporation, in the Republic of Korea. The studies are by nature retrospective in the context of device development, where the device is manufactured and then tested to established standards.


3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

This section is not applicable. The ground truth for these types of mechanical, physical, and biocompatibility tests is established by published international standards (ISO, USP, ASTM), not by expert consensus in diagnostic interpretation.


4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

This section is not applicable. Adjudication methods are typically used in clinical studies involving interpretation of medical data by multiple experts. The reported studies are bench tests against defined international standards.


5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance

This section is not applicable. No MRMC comparative effectiveness study was performed or discussed, as the device is a syringe and needle, not an AI-assisted diagnostic tool.


6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

This section is not applicable. The device is a physical medical device (syringe and needle) and does not involve an algorithm or AI.


7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

The ground truth used for these tests are established international and national standards for medical devices, specifically:

  • ISO 7886-1: Sterile hypodermic syringes for single use
  • ISO 7864: Sterile hypodermic needles for single use
  • ISO 9626: Stainless steel needle tubing
  • USP <788>: Particulate Matter in Injections
  • ISO 23908: Sharps injury protection
  • ISO 10993 series for Biological evaluation of medical devices (Parts 4, 5, 7, 10, 11, 23)
  • ASTM F756-17: Standard Practice for Assessment of Hemolytic Properties of Materials

8. The sample size for the training set

This section is not applicable. As this is a physical medical device submission focusing on bench testing, there is no AI model or "training set" in the context of machine learning.


9. How the ground truth for the training set was established

This section is not applicable for the same reasons as section 8.

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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.

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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,

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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)

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

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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 onlength)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 needletubeISO 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 medicaldevices – Requirements and test methods
Surface finish and visual appearanceISO 9626:2016 Stainless steel needle tubing for the manufacture of medicaldevices – Requirements and test methods
CleanlinessISO 9626:2016 Stainless steel needle tubing for the manufacture of medicaldevices – Requirements and test methods
Limits for acidity and alkalinityISO 9626:2016 Stainless steel needle tubing for the manufacture of medicaldevices – Requirements and test methods
Size designationISO 9626:2016 Stainless steel needle tubing for the manufacture of medicaldevices – Requirements and test methods
DimensionISO 9626:2016 Stainless steel needle tubing for the manufacture of medicaldevices – Requirements and test methods
StiffnessISO 9626:2016 Stainless steel needle tubing for the manufacture of medicaldevices – Requirements and test methods
Resistance to breakageISO 9626:2016 Stainless steel needle tubing for the manufacture of medicaldevices – Requirements and test methods
Resistance to corrosionISO 9626:2016 Stainless steel needle tubing for the manufacture of medicaldevices – 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

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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 <788> Method 1. Light obscuration method

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

Test itemRequirements
Particulate test reportUSP <788> Method 1. Light obscuration method

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

Test itemRequirements
Particulate test reportUSP <788> Method 1. Light obscuration method

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

Test itemRequirements
Particulate test reportUSP <788> 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: Testsfor in vitro cytotoxicity
2Acute systemic toxicitytestISO 10993-11:2017 Biological evaluation of medical devices - Part 11:Tests for systemic toxicity
3Pyrogen testISO 10993-11:2017 Test for systemic toxicity, pyrogen testUSP <151>
4Sensitization testISO 10993-10:2010 Biological evaluation of medical devices - Part 10Tests for irritation and skin sensitization
5Hemolytic testISO 10993-4:2017, ASTM F756-17
6Intracutaneous reactivitytestISO 10993-23 :2021 Biological evaluation of medical devices - Part 23Tests for irritation

23G Model (Model : SSN2301)

#Test itemTest method / Test criteria
1CytotoxicityISO 10993-5:2009 Biological evaluation of medical devices - Part 5: Testsfor in vitro cytotoxicity
2Acute systemic toxicitytestISO 10993-11:2017 Biological evaluation of medical devices - Part 11:Tests for systemic toxicity
3Pyrogen testISO 10993-11:2017 Test for systemic toxicity, pyrogen testUSP <151>
4Sensitization testISO 10993-10:2010 Biological evaluation of medical devices – Part 10Tests for irritation and skin sensitization
5Hemolytic testISO 10993-4:2017, ASTM F756-17
6Intracutaneous reactivitytestISO 10993-23:2021 Biological evaluation of medical devices – Part 23Tests for irritation

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Syringe (Model : SSN2301)

#Test itemTest method / Test criteria
1CytotoxicityISO 10993-5:2009 Biological evaluation of medical devices - Part 5: Testsfor in vitro cytotoxicity
2Acute systemic toxicitytestISO 10993-11:2017 Biological evaluation of medical devices - Part 11:Tests for systemic toxicity
3Pyrogen testISO 10993-11:2017 Test for systemic toxicity, pyrogen testUSP <151>
4Sensitization testISO 10993-10:2010 Biological evaluation of medical devices – Part 10Tests for irritation and skin sensitization
5Hemolytic testISO 10993-4:2017, ASTM F756-17
6Intracutaneous reactivitytestISO 10993-23 :2021 Biological evaluation of medical devices – Part 23Tests 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 foruseShina Syringe, Shina SafetySyringe is a plastic sterilesyringe and hypodermicsingle lumen needleintended to be used formedical purpose to injectfluid into or withdraw fluidfrom body.PLPT LDV (Low Dead Volume)Sterile Syringe is intended tobe used for medical purposeto inject fluid into or withdrawfluid from body.This produce is intended foruse to inject fluid into orwithdraw fluids from parts ofthe body below the surface ofthe skin.Identical
ClassificationnameSyringe, AntistickLow Dead Space PistonSyringeLow Dead Space Needle,Single Lumen, HypodermicDifferent
Trade nameShina Syringe, Shina SafetySyringePLPT LDV (Low Dead Volume)Sterile SyringeEZ-Injec LDV Sterile SafetyNeedleN/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
MaterialsNeedleHubSafety coverBarrelGasketPlungerStainless SteelPPPPPPHydrogenated styreneisoprene butadiene blockcopolymerPPPPRubberPPStainless SteelPPPPDifferent
Capacity1mL, 3mL, 5mL, 10mL1mL-Different
Needle Gauge23G, 25G-25GDifferent
Needle Length25.4mm-25mmDifferent
Sharps FunctionSafety Guard-Safety GuardIdentical
Principle ofoperationManualManualManualIdentical
PerformancesISO 7886ISO 7864ISO 9626USP <788>ISO 23908ISO 7886ISO 7864ISO 9626ISO 23908USP <788>Identical

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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
SterilizationMethodEO 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.

§ 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).