K Number
K231720

Validate with FDA (Live)

Date Cleared
2023-09-08

(87 days)

Product Code
Regulation Number
880.5570
Reference & Predicate Devices
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The Sterile Hypodermic Needles for Single Use are intended to be used with a luer slip syringe and injection devices for general purpose fluid injection/aspiration.

Device Description

The Sterile Hypodermic Needles for Single Use is composed of a needle hub, protective cover, needle tube and jointing, connected with a luer lock or luer slip syringe and injection devices for general purpose fluid injection. The Sterile Hypodermic Needles for Single Use is for single use only. After opening the inner packaging and taking out the product, tighten the needle to the syringe and remove the protective cover, extract the drug liquid, exhaust the air and then inject. It is provided sterile. The sterilization method is EO sterilization and the sterilization assurance level is 10-6.

AI/ML Overview

This document outlines the acceptance criteria and supporting study details for a Sterile Hypodermic Needle for Single Use (K231720) according to its 510(k) summary. This is not an AI/ML-based device, so many of the requested fields (especially those related to AI algorithm performance, human reader studies, and ground truth establishment for AI training/test sets) are not applicable.

The "device" in question is a physical medical device (hypodermic needles), not a software or AI-driven system. Therefore, the acceptance criteria and study descriptions are focused on physical and biological performance, rather than algorithm performance.


Acceptance Criteria and Device Performance for Sterile Hypodermic Needles for Single Use (K231720)

The substantial equivalence determination for this device is based on its compliance with established international and national standards for medical devices, rather than a comparative effectiveness study involving human readers or AI.

1. Table of Acceptance Criteria and Reported Device Performance

CategoryAcceptance Criteria (Standard / Test)Reported Device Performance
I. Biocompatibility
CytotoxicityISO 10993-5:2009All evaluation acceptance criteria were met.
Skin SensitizationISO 10993-10:2010All evaluation acceptance criteria were met.
HemolysisISO 10993-4:2017All evaluation acceptance criteria were met.
Intracutaneous ReactivityISO 10993-10:2010All evaluation acceptance criteria were met.
Acute Systemic ToxicityISO 10993-11:2017All evaluation acceptance criteria were met.
PyrogenicityISO 10993-11:2017 (for testing); Device non-pyrogenic (for general claim)All evaluation acceptance criteria were met; Non-pyrogenic.
Particulate MatterUSP <788> Particulate Matter in InjectionsMet USP acceptance criteria.
II. Sterilization & Shelf Life
Sterilization ValidationISO 11135:2014 (EO Sterilization)Sterilization method validated to ISO11135.
EO ResidueISO 10993-7:2008Compliant with ISO 10993-7:2008.
ECH ResidueISO 10993-7:2008Compliant with ISO 10993-7:2008.
Bacterial EndotoxinUSP42-NF37<85>Compliant with USP42-NF37<85>.
Shelf Life (Stability)Ageing test (method not specified but implies meeting performance over time)Five (5) years.
Sterile Barrier PackagingASTM F88/F88M-15 (Seal Strength)Compliant.
ASTM F1929-15 (Dye Penetration)Compliant.
ASTMF1140/F1140M-13 (Creep/Burst Testing)Compliant.
ASTM F2096-11 (Gross Leakage)Compliant.
III. Performance Testing
CleanlinessISO 7864:2016 Clause 4.3; ISO 9626:2016 Clause 5.3Complied (implied by "all evaluation acceptance criteria were met" for biocompatibility tests which can be affected by cleanliness, and by general statement of compliance with these standards).
Limits for acidity or alkalinityISO 7864:2016 Clause 4.4; ISO 9626:2016 Clause 5.4Complied.
Limits for extractable metalsISO 7864:2016 Clause 4.5Complied.
Tubular needle designationISO 7864:2016 Clause 4.6Complied.
Color codingISO 7864:2016 Clause 4.7; ISO 6009Complied (Color-coded per ISO 6009).
Needle hubISO 7864:2016 Clause 4.8; ISO 80369-7Complied.
Needle capISO 7864:2016 Clause 4.9Complied.
Needle tube (Tolerance on length, Freedom from defects, Lubricant)ISO 7864:2016 Clause 4.10Complied.
Needle PointISO 7864:2016 Clause 4.11Complied.
Bond between Tube and HubISO 7864:2016 Clause 4.12Complied.
Patency of LumenISO 7864:2016 Clause 4.13Complied.
Surface finish & visual appearanceISO 9626:2016 Clause 5.2Complied.
Size designationISO 9626:2016 Clause 5.5Complied.
DimensionsISO 9626:2016 Clause 5.6Complied.
StiffnessISO 9626:2016 Clause 5.8Complied.
Resistance to breakageISO 9626:2016 Clause 5.9Complied.
Resistance to corrosionISO 9626:2016 Clause 5.10Complied.
Dimensional requirements for luer connectorsISO 80369-7:2021 Clause 5Complied.
Fluid leakage (Positive pressure liquid leakage)ISO 80369-7:2021 Clause 6.1.3Complied.
Sub-atmospheric pressure air leakageISO 80369-7:2021 Clause 6.2Complied.
Stress crackingISO 80369-7:2021 Clause 6.3Complied.
Resistance to separation from axial loadISO 80369-7:2021 Clause 6.4Complied.
Resistance to separation from unscrewingISO 80369-7:2021 Clause 6.5Complied.
Resistance to overridingISO 80369-7:2021 Clause 6.6Complied.
IV. Labeling21 CFR Part 801Met the requirements of 21 CFR Part 801.

2. Sample Size Used for the Test Set and Data Provenance

The document does not specify exact sample sizes for each test. Testing of physical medical devices typically involves testing a statistically significant sample size from a production lot to demonstrate compliance with standards. The data provenance is implied to be from laboratory testing performed on the manufacturer's device, likely in China (where the manufacturer is located). The testing is prospective for the purpose of demonstrating compliance for this specific device model.

3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications of Those Experts

This information is not applicable as the device is a physical medical device (hypodermic needle), not an AI/ML diagnostic or image analysis system. Ground truth is established through validated laboratory test methods and established international/national standards, not through expert consensus in the medical imaging context.

4. Adjudication Method for the Test Set

This is not applicable as the ground truth is established through objective laboratory testing against defined standards (e.g., ISO, ASTM, USP), not through the adjudication of medical opinion.

5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done

No, an MRMC comparative effectiveness study was not done. This type of study is relevant for AI/ML-driven diagnostic aids that assist human readers in interpreting medical images. This device is a sterile hypodermic needle, a physical disposable medical tool.

6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done

No, a standalone performance evaluation in the context of an AI algorithm was not done. This is not an algorithmic device.

7. The Type of Ground Truth Used

The "ground truth" for this physical device is defined by the acceptance criteria specified in the referenced international standards (e.g., ISO 10993, ISO 7864, ISO 9626, ISO 80369, ASTM, USP). These standards define the physical, chemical, and biological properties a device must meet to be considered safe and effective for its intended use. Testing protocols outlined within these standards serve as the objective 'ground truth' against which the device's performance is measured. Compliance is determined by the device meeting all the specified numerical and qualitative requirements of these standards.

8. The Sample Size for the Training Set

This information is not applicable as there is no "training set" in the context of a physical medical device. The manufacturing process is controlled by Good Manufacturing Practices (GMP) and validated testing, not machine learning training.

9. How the Ground Truth for the Training Set Was Established

This information is not applicable as there is no "training set" involved in the development or evaluation of this physical medical device.

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Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

September 8, 2023

Wepon Medical Technology Co., Ltd. % Esther Zhang Official Correspondent Shanghai Ling Fu Technology Co., Ltd. 4F No. 585-2, Wanyuan Rd. Minhang District Shanghai, Shanghai 201102 China

Re: K231720

Trade/Device Name: Sterile Hypodermic Needles for Single Use Regulation Number: 21 CFR 880.5570 Regulation Name: Hypodermic Single Lumen Needle Regulatory Class: Class II Product Code: FMI Dated: June 8, 2023 Received: June 13, 2023

Dear Esther Zhang:

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

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

Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part

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801); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4. Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

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

For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely,

Alan Sthe

CAPT Alan Stevens Assistant Director DHT3C: Division of Drug Delivery and General Hospital Devices, and Human Factors OHT3: Office of GastroRenal, ObGyn, General Hospital and Urology Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known) K231720

Device Name Sterile Hypodermic Needles for Single Use

Indications for Use (Describe)

The Sterile Hypodermic Needles for Single Use are intended to be used with a luer slip syringe and injection devices for general purpose fluid injection/aspiration.

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

X Prescription Use (Part 21 CFR 801 Subpart D)Over-The-Counter Use (21 CFR 801 Subpart C)
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Section 5 510(k) summary

l Submitter

Device submitter: Wepon Medical Technology CO., LTD. Floor 4, Building A, No. 58, Jinhu Road, Chengdong Street, Wenling Zhejiang, CN 317500

Contract manufacturer: Zhejiang Kangkang Medical-Devices CO., Ltd. Longwang Industrial District, Chumen Town, Yuhuan, Zhejiang, 317605, China Registration number: 3015042030

Contact person: Di Zhao Deputy General Manager Phone: 928-5922380 Email: dizhao@wepon-ppe.com

II Correspondent

Shanghai Ling Fu Technology Co., Ltd. 4F No. 585-2, Wanyuan Rd. Minhang District, Shanghai, P.R.China Contact: Esther ZHANG Email: Esther.zhang@llins-tech.com

III Device

Trade Name of Device: Sterile Hypodermic Needles for Single Use Common Name: Hypodermic Single Lumen Needle Regulation Number: 21 CFR 880.5570 Regulation Name: Hypodermic Single Lumen Needle Regulatory Class: II Product code: FMI Review Panel: General Hospital

IV Predicate Devices

Trade name:Sterile Hypodermic Needles for Single Use (used as the predicate device);
Common name:Hypodermic single lumen needle
Classification:Class II, 21 CFR 880.5570
Product Code:FMI
Premarket Notification:K180417

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Manufacturer:

V Device description

The Sterile Hypodermic Needles for Single Use is composed of a needle hub, protective cover, needle tube and jointing, connected with a luer lock or luer slip syringe and injection devices for general purpose fluid injection. The Sterile Hypodermic Needles for Single Use is for single use only. After opening the inner packaging and taking out the product, tighten the needle to the syringe and remove the protective cover, extract the drug liquid, exhaust the air and then inject. It is provided sterile. The sterilization method is EO sterilization and the sterilization assurance level is 10-6.

GaugeLength30G27G26G25G24G23G22G21G20G19G18G
1/2"
5/8"
1"
1 1/4"
1 1/2"

Table 1 specification of proposed device

VI Indications for use

The Sterile Hypodermic Needles for Single Use are intended to be used with a luer lock or luer slip syringe and injection devices for general purpose fluid injection/aspiration.

VII Comparison of technological characteristics with the predicate devices

The Sterile Hypodermic Needles for Single Use have intended use, technology, design and performance specifications are either identical or substantially equivalent to existing legally marketed predicate devices. The differences between the Sterile Hypodermic Needles for Single Use and predicate devices do not alter suitability of the proposed device for its intended use.

DevicefeatureSubject DevicePredicate DeviceK180417Comments
Indications foruseThe Sterile HypodermicNeedles for Single Useare intended to be usedwith a luer lock or luer slipsyringe and injectiondevices for generalpurpose fluidinjection/aspiration.The Sterile HypodermicNeedles forSingle Use are intended tobe used with a luer slip orluer slip syringe andinjection devices forgeneral purpose fluidinjection/aspiration.Same
Product codeFMIFMISame
Regulation21 CFR 880.557021 CFR 880.5570Same
DevicefeatureSubject DevicePredicate DeviceK180417Comments
number
ClassIIIISame
Principle ofoperationFor manual use onlyFor manual use onlySame
Intended userMedical professionals andtrained care giversMedical professionals andtrained care giversSame
Environmentof useHospitals and clinicsHospitals and clinicsSame
Needle gauge30G, 27G, 26G, 25G,24G, 23G, 22G, 21G,20G, 19G, 18G14G, 15G, 16G, 17G,18G, 19G, 20G, 21G,22G, 23G, 24G, 25G,26G, 27G, 29G, 30GDifference
Length1/2", 5/8", 1", 1¼", 1½"6-60mm
Type of wallnormal wall or thin wallnot provide
blade angleshort bevel or long bevelnot provide
Needle hubNeedle hubPolypropyleneNeedle hubPolypropyle neSame
main structureand materialsNeedle tubeStainless steelNeedleStainless steel
protectivecoverPolypropyleneprotectivecapPolypropyle ne
Needle hubColor-coded per ISO 6009Color-coded per ISO 6009Same
Single useYesYesSame
PerformancespecificationsComplies with ISO 7864;ISO 9626; ISO 80369-7Complies with ISO 7864;ISO 9626; ISO 80369-7Same
SterilizationEOEOSame
SAL10-610-6Same
PyrogenNon-pyrogenicNon-pyrogenicSame
BiocompatibilityThebiocompatibilityevaluation for the subjectdevice was conducted inaccordance with theInternational Standard ISO10993-1 "BiologicalEvaluation of MedicalDevices - Part 1:Evaluation and TestingWithin a RiskComply with ISO 10993.The test is as follows:The devices meetbiocompatibility endpointsfor cytotoxicity, irritation,sensitization, systemictoxicity, andhemolysis material-mediatedpyrogensSame
DevicefeatureSubject DevicePredicate DeviceK180417Comments
Management Process," asrecognized by FDA andthe "Use of InternationalStandard ISO 10993-1"Biological evaluation ofmedical devices- Part 1:Evaluation and testingwithin a risk managementprocess", June 16, 2016.The syringe of testingincluded the followingtests:Cytotoxicity;Skin sensitization;Hemolysis;Intracutaneous reactivity;Acute systemic toxicity;Pyrogenicity.The evaluation of theabove testing items meetsthe requirements
LabelingMeet the requirements of21 CFR Part 801Meet the requirements of21 CFR Part 801

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Different 1

The needle gauge and length of subject devices are different from the predicate device, and the type of wall and needle bevel are unknown. The subject device specifications are within the range of the predicate device. This difference does not affect intended use and does not raise different questions of safety and effectiveness.

VIII Performance data

The following performance data were provided in support of the substantial equivalence determination.

Biocompatibility testing

Biocompatibility of the Sterile Hypodermic Needles for Single Use were evaluated in accordance with ISO 10993-1:2018 for the body contact category of "External

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communication device - Blood path indirect" with a contact duration of "Limited (< 24 hours)". The following tests were performed, as recommended:

CytotoxicityISO 10993-5: 2009
Skin sensitizationISO 10993-10: 2010
HemolysisISO 10993-4: 2017
Intracutaneous reactivityISO 10993-10: 2010
Acute systemic toxicityISO 10993-11: 2017
PyrogenicityISO 10993-11: 2017

All evaluation acceptance criteria were met.

Particulate matter testing was conducted in accordance with USP <788> Particulate Matter in Injections and met the USP acceptance criteria.

Sterilization and shelf life testing

The sterilization method has been validated to ISO11135, which has thereby determined the routine control and monitoring parameters. The shelf life of the Sterile Hypodermic Needles for Single Use is determined based on stability study which includes ageing test. The shelf-life of the Sterile Hypodermic Needles for Single Use is five (5) years.

Sterilization EvaluationISO11135: 2014
EO residueISO 10993-7:2008
ECH residueISO 10993-7:2008
Bacterial Endotoxin testingUSP42-NF37<85>
Sterile barrier packaging testing &Shelf Life EvaluationSeal Strength ASTM F88/F88M-15Dye Penetration ASTM F1929-15Creep/Burst TestingASTMF1140/F1140M-13Gross Leakage ASTM F2096-11

Antibacterial Testing DIN 58953-6:2010

Performance testing

Freedom from defects, Lubricant)

Performance testing is performed according to the following standards:

ISO 7864: 2016
CleanlinessClause 4.3 of ISO 7864: 2016
Limits for acidity or alkalinityClause 4.4 of ISO 7864: 2016
Limits for extractable metalsClause 4.5 of ISO 7864: 2016
Tubular needle designationClause 4.6 of ISO 7864: 2016
Colour codingClause 4.7 of ISO 7864: 2016
Needle hubClause 4.8 of ISO 7864: 2016, ISO
80369-7 and ISO 6009
Needle capClause 4.9 of ISO 7864: 2016
Needle tube (Tolerance on length,Clause 4.10 of ISO 7864: 2016

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Needle PointClause 4.11 of ISO 7864: 2016
Bond between Tube and HubClause 4.12 of ISO 7864: 2016
Patency of LumenClause 4.13 of ISO 7864: 2016
>ISO 9626:2016
Surface finish and visual appearanceClause 5.2 of ISO 9626:2016
CleanlinessClause 5.3 of ISO 9626:2016
Limits for acidity and alkalinityClause 5.4 of ISO 9626:2016
Size designationClause 5.5 of ISO 9626:2016
DimensionsClause 5.6 of ISO 9626:2016
StiffnessClause 5.8 of ISO 9626:2016
Resistance to breakageClause 5.9 of ISO 9626:2016
Resistance to corrosionClause 5.10 of ISO 9626:2016
>ISO 80369-7:2016
Dimensional requirements for luerconnectors.Clause 5 of ISO 80369-7: 2021
Fluid leakage (Positive pressure liquidleakage)Clause 6.1.3 of ISO 80369-7: 2021
Sub-atmospheric pressure air leakageClause 6.2 of ISO 80369-7: 2021
Stress crackingClause 6.3 of ISO 80369-7: 2021
Resistance to separation from axial loadClause 6.4 of ISO 80369-7: 2021
Resistance to separation fromClause 6.5 of ISO 80369-7: 2021
unscrewing
Resistance to overridingClause 6.6 of ISO 80369-7: 2021

IX Conclusion

The Sterile Hypodermic Needles for Single Use are substantially equivalent to its predicate device. The non-clinical testing demonstrates that the device is as safe, as effective and performs as well as the legally marketed device.

§ 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).