K Number
K232875
Date Cleared
2023-12-14

(90 days)

Product Code
Regulation Number
880.5440
Panel
HO
Reference & Predicate Devices
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The Vial Adapter is indicated for the transfer of drugs contained in a vial.

Device Description

The Vial Adapter (VA) 20mm is a single-use device that allows for the transfer of drugs contained in a vial. The device is a one-piece polycarbonate molded part with a standard female Luer port for the connection of a syringe. Puncturing the elastomeric closure of a drug vial is achieved by means of an integral plastic cannulated spike located in the center of the Vial Adapter component. The VA 20mm device is supplied with or without an inline filter, based on catalog number. The VA is sterilized utilizing gamma irradiation and is packaged in a Polyethylene Terephthalate Glycol (PETG) blister enclosure. The VA 20mm is packaged in either a Vial First (VF) or a Syringe First (SF) orientation. The device does not contain any medicinal substances or moving parts and is intended for use with standard drug vials having a neck diameter of 20mm.

AI/ML Overview

The provided text describes a 510(k) premarket notification for a medical device called "Vial Adapter 20mm". This is a regulatory submission to the FDA, demonstrating substantial equivalence to a predicate device, rather than a study designed to prove the device meets acceptance criteria in the typical academic or clinical trial sense.

Therefore, many of the requested categories (such as sample size for test/training sets, data provenance, number of experts, adjudication methods, MRMC studies, standalone performance, and ground truth establishment) are not applicable in this context, as they pertain to clinical or AI/algorithm performance studies. This document focuses on bench testing and regulatory comparisons.

Here's a breakdown of the information that can be extracted:

1. A table of acceptance criteria and the reported device performance

The document lists various performance tests conducted. For each test, the acceptance criteria are implicitly defined by the referenced standard or the success of the "in-house test method." The reported device performance is indicated by statements like "meets all applicable design and performance requirements," "conforms to applicable external and internal standards," and "successfully conducted." Specific numerical performance data or detailed results are not provided in this summary.

TestTest Method/StandardImplied Acceptance CriteriaReported Device Performance
Fragmentation TestISO 8536-2:2010 section 6.2.2Compliance with ISO 8536-2:2010 requirementsMeets requirements
Particulate TestingUSP 788Compliance with USP 788 requirements for particulate matterMeets requirements
Internal Diameter Upper SkirtISO 8362-6:2010 Section 4.2Compliance with ISO 8362-6:2010 requirements for dimensionsMeets requirements
Luer Gauging TestISO 594-1:1986 and ISO 594-2:1998Compliance with ISO 594-1:1986 and ISO 594-2:1998 for Luer fittingsMeets requirements
Luer Stability & compliance (fluid leakage)ISO 80369-7:2021; ISO 80369-20:2015, Annex B & CCompliance with ISO 80369-7:2021 and ISO 80369-20:2015 for fluid leakageMeets requirements
Luer Stability & compliance (air leakage)ISO 80369-7:2021; ISO 80369-20:2015, Annex D & CCompliance with ISO 80369-7:2021 and ISO 80369-20:2015 for air leakageMeets requirements
Luer Stability & compliance (stress cracking)ISO 80369-7:2021; ISO 80369-20:2015, Annex E & CCompliance with ISO 80369-7:2021 and ISO 80369-20:2015 for stress crackingMeets requirements
Luer Stability & compliance (axial load)ISO 80369-7:2021; ISO 80369-20:2015, Annex F & CCompliance with ISO 80369-7:2021 and ISO 80369-20:2015 for axial loadMeets requirements
Luer Stability & compliance (resistance separation from unscrewing)ISO 80369-7:2021; ISO 80369-20:2015, Annex G & CCompliance with ISO 80369-7:2021 and ISO 80369-20:2015 for resistance to unscrewingMeets requirements
Luer Stability & compliance (overriding)ISO 80369-7:2021; ISO 80369-20:2015, Annex G & CCompliance with ISO 80369-7:2021 and ISO 80369-20:2015 for overridingMeets requirements
Luer Stability & compliance (dimensions)ISO 80369-7 Table B.2 and B.5Compliance with ISO 80369-7 dimensional requirementsMeets requirements
Residual VolumeIn-house test methodMeeting internal specifications for residual volumeMeets requirements
Device LeakageIn-house test methodMeeting internal specifications for device leakageMeets requirements
Device Leakage under normal useIn-house test methodMeeting internal specifications for device leakage under normal useMeets requirements
Device Total Penetration ForceIn-house test methodMeeting internal specifications for penetration forceMeets requirements
Vial Adapter Detachment ForceIn-house test methodMeeting internal specifications for detachment forceMeets requirements
Product Retention in BlisterIn-house test methodMeeting internal specifications for product retention (packaging)Meets requirements
Device Removal Force from BlisterIn-house test methodMeeting internal specifications for device removal force (packaging)Meets requirements
Tyvek Total Peel TestIn-house test methodMeeting internal specifications for Tyvek peel strengthMeets requirements
Functionality according to IFUIn-house test methodPerforming as intended according to Instructions for UseMeets requirements
Filter EfficiencyIn-house test methodMeeting internal specifications for filter efficiencyMeets requirements
Syringe First OrientationIn-house test methodPerforming as intended in Syringe First orientationMeets requirements
Product Skirt Position on VialIn-house test methodMeeting internal specifications for skirt positionMeets requirements
Injection ForceIn-house test methodMeeting internal specifications for injection forceMeets requirements
Aspiration ForceIn-house test methodMeeting internal specifications for aspiration forceMeets requirements
Label LegibilityIn-house test methodMeeting internal specifications for label legibilityMeets requirements
Packaging IntegrityIn-house test methodMeeting internal specifications for packaging integrityMeets requirements
Biocompatibility (various tests)ISO 10993-5, -4, -10, -11, -12; ASTM F756Compliance with specified ISO and ASTM standards and FDA guidanceSuccessfully conducted, materials are biologically safe
Sterilization (validation)ISO 11137-1, 11137-2, 13004Achieving a Sterility Assurance Level (SAL) of 10-6Validated, SAL of 10-6 achieved
Bacterial Endotoxin TestingLimulus Amebocyte Lysate (LAL)Acceptable levels of bacterial endotoxinsPassed with acceptable levels
Shelf life stabilityASTM F1886Withstanding a shelf life of 5 yearsDetermined to withstand 5 years

2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

  • Sample Size: Not specified in the provided text.
  • Data Provenance: The tests are "non-clinical performance data" and "bench performance tests." The manufacturing facility is in Ra'anana, Israel. The data would be prospective for the purpose of this submission (i.e., new testing done for this device).

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)

  • Not Applicable. This is not a study relying on expert interpretation for ground truth. It's an engineering and regulatory compliance submission based on physical and chemical testing.

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

  • Not Applicable. No human adjudication of results is described for these bench tests; results are objective measurements against 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

  • Not Applicable. This device is a passive, non-electrical, non-software-enabled mechanical component (Vial Adapter), not an AI or imaging device that would involve human readers or AI assistance.

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

  • Not Applicable. As mentioned above, this is a mechanical medical device, not an algorithm.

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

  • The "ground truth" for the performance tests outlined is defined by the specified international and in-house standards (e.g., ISO, USP, ASTM) that the device must comply with. For biocompatibility and sterilization, it's compliance with safety thresholds and validation standards.

8. The sample size for the training set

  • Not Applicable. This is not an AI/machine learning study, so there is no training set.

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

  • Not Applicable. As there is no training set, this question is irrelevant.

§ 880.5440 Intravascular administration set.

(a)
Identification. An intravascular administration set is a device used to administer fluids from a container to a patient's vascular system through a needle or catheter inserted into a vein. The device may include the needle or catheter, tubing, a flow regulator, a drip chamber, an infusion line filter, an I.V. set stopcock, fluid delivery tubing, connectors between parts of the set, a side tube with a cap to serve as an injection site, and a hollow spike to penetrate and connect the tubing to an I.V. bag or other infusion fluid container.(b)
Classification. Class II (special controls). The special control for pharmacy compounding systems within this classification is the FDA guidance document entitled “Class II Special Controls Guidance Document: Pharmacy Compounding Systems; Final Guidance for Industry and FDA Reviewers.” Pharmacy compounding systems classified within the intravascular administration set are exempt from the premarket notification procedures in subpart E of this part and subject to the limitations in § 880.9.