K Number
K232912
Device Name
Facet Aurora Reusable Lancet Base
Date Cleared
2024-01-25

(128 days)

Product Code
Regulation Number
878.4850
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Facet Aurora Reusable Lancet Base (commonly referred to as a lancing device) is a non-sterile reusable device which provides a spring-loaded mechanism to quickly eject and retract a lancet of proprietary design to effect a lancing event for the purpose of obtaining a droplet of capillary blood for diagnostic testing in children, adolescents, and adults in a home setting. The device is designed to be cleaned and disinfected between uses on a single patient.
Device Description
The Facet Aurora Reuseable Lancet Base is a blood sampling device used in conjunction with a lancet blade of proprietary design to obtain a sample of capillary blood for diagnostic purposes, primarily for blood glucose monitoring in diabetic patients. The lancing device has been in commercial distribution in the United States for over 10 years. There have been no significant design changes over the life of the device.
More Information

MDM

Not Found

No
The description focuses on a mechanical lancing device and explicitly states "Mentions AI, DNN, or ML: Not Found".

No
The device is described as a blood sampling device for diagnostic testing, specifically for obtaining a droplet of capillary blood for diagnostic purposes, primarily for blood glucose monitoring. It is not used for treating or curing a medical condition.

No
The device is a blood sampling device used to obtain a sample of capillary blood for diagnostic testing, but it does not perform the diagnostic testing itself.

No

The device description explicitly states it is a "reusable device which provides a spring-loaded mechanism" and mentions "mechanical design verification and validation testing," indicating it is a physical hardware device.

Based on the provided text, the Facet Aurora Reusable Lancet Base is not an IVD (In Vitro Diagnostic).

Here's why:

  • It's a blood sampling device: The text explicitly states its purpose is to "effect a lancing event for the purpose of obtaining a droplet of capillary blood for diagnostic testing." It's the tool used to get the sample, not the test itself.
  • It's used in conjunction with diagnostic testing: The blood obtained is for diagnostic testing, but the lancing device itself doesn't perform the diagnostic analysis.
  • The predicate device is 510(k) Exempt (Product Code MDM): Product Code MDM is for "Manual Lancing Device," which is a Class II device that is exempt from 510(k) premarket notification. These devices are generally considered accessories to IVDs, not IVDs themselves.

An IVD is a device that is intended for use in the collection, preparation, and examination of specimens taken from the human body for the purpose of providing information for the diagnosis, treatment, or prevention of disease. The Facet Aurora Reusable Lancet Base is involved in the collection of the specimen, but it doesn't perform the examination or provide diagnostic information.

N/A

Intended Use / Indications for Use

The Facet Aurora Reusable Lancet Base (commonly referred to as a lancing device) is a non-sterile reusable device which provides a spring-loaded mechanism to quickly eject and retract a lancet of proprietary design to effect a lancing event for the purpose of obtaining a droplet of capillary blood for diagnostic testing in children, adolescents, and adults in a home setting.

The device is designed to be cleaned and disinfected between uses on a single patient.

Product codes

QRL

Device Description

The Facet Aurora Reuseable Lancet Base is a blood sampling device used in conjunction with a lancet blade of proprietary design to obtain a sample of capillary blood for diagnostic purposes, primarily for blood glucose monitoring in diabetic patients.

The lancing device has been in commercial distribution in the United States for over 10 years. There have been no significant design changes over the life of the 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

children, adolescents, and adults

Intended User / Care Setting

home setting.

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

Non-clinical bench testing was performed to ensure predetermined criteria were met and the special controls (21 CFR 878.4850) were satisfied. This includes mechanical design verification and validation testing in order to ensure the risks were appropriately managed in addition to verifying that the mechanical functions of the device are suitable for use over the shelf life of the device.

Summary of Nonclinical Tests Performed:

  • Endcap Removal Force: Test Method - Tensile strength tester. Importance - Ensure cap can be removed easily to insert lancet blade.
  • Endcap Attachment Force: Test Method - Tensile strength tester. Importance - Ensure cap will remain on lancet base during lancing event.
  • Depth of Puncture: Test Method - Calibrated High Speed Video. Importance - Ensure depth of puncture is repeatable for various depth settings.
  • Over-Charging Force: Test Method - Tensile force gauge. Importance - Ensure that device can be charged to engage actuation spring.
  • Charging Force: Test Method - Tensile force gauge. Importance - Ensure device can be charged to engage actuation spring.
  • Lancet Insertion Force: Test Method - Tensile force gauge. Importance - Ensure lancet can be easily inserted.
  • Depth Adjust Torque: Test Method - Torque gauge. Importance - Ensure that depth adjustment can be easily adjusted and that adjustment will not change during use.
  • Button Activation Force: Test Method - Tensile force gauge. Importance - Ensure activation force is within specification.
  • Lancet Rotation: Test Method - Torque gauge. Importance - Ensure lancet does not rotate during device actuation.
  • Drop Test: Test Method - Simulated Use after drop. Importance - Ensure that device can withstand a 1 meter drop to a hard surface and still function.
  • Life Cycle Test: Test Method - Simulated use. Importance - Ensure device can withstand 3 years of expected use.
  • Chemical Test: Test Method - Cleaning and disinfection studies. Importance - Ensure device can withstand recommended cleaning and disinfection over useful life.
  • Storage Temperature Test: Test Method - Simulated Use. Importance - Ensure device can function after exposure to heat and cold cycles.
  • Biocompatibility: Test Method - Cytotoxicity, Sensitization, Irritation or Intracutaneous reactivity, Acute Systemic toxicity (materials mediated pyrogen). Importance - Ensure material of construction are biocompatible for their intended use. Reference: FDA Guidance Use of International Standard 10993-1, "Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process", Sept. 2020, ISO 10993-1, ISO 10993-5, ISO 0993-10, ISO 10993-11.

In summary, the results of nonclinical testing demonstrate that the candidate device is substantially equivalent to the predicate device.

Key Metrics

Not Found

Predicate Device(s)

Facet Aurora Reuseable Lancet Base (Product Code MDM, 510(k) Exempt)

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 878.4850 Blood lancets.

(a)
Single use only blood lancet with an integral sharps injury prevention feature —(1)Identification. A disposable blood lancet intended for a single use that is comprised of a single use blade attached to a solid, non-reusable base (including an integral sharps injury prevention feature) that is used to puncture the skin to obtain a drop of blood for diagnostic purposes. The integral sharps injury prevention feature allows the device to be used once and then renders it inoperable and incapable of further use.(2)
Classification. Class II (special controls). The special controls are:(i) The design characteristics of the device must ensure that the structure and material composition are consistent with the intended use and must include a sharps injury prevention feature.
(ii) Mechanical performance testing must demonstrate that the device will withstand forces encountered during use and that the integral sharps injury prevention feature will irreversibly disable the device after one use.
(iii) The device must be demonstrated to be biocompatible.
(iv) Sterility testing must demonstrate the sterility of any device component that breaches the skin (
e.g., blade).(v) Labeling must include:
(A) Detailed descriptions, with illustrations, of the proper use of the device and its sharps injury prevention feature.
(B) Handwashing instructions for the user before and after use of the device.
(C) Instructions on preparation (
e.g., cleaning, disinfection) of the skin to be pierced.(D) Instructions for the safe disposal of the device.
(E) Labeling must be appropriate for the intended use environment.
(
1 ) For those devices intended for health care settings, labeling must address the health care facility use of these devices, including how these lancets are to be used with personal protective equipment, such as gloves.(
2 ) For those devices intended for use in the home, labeling must be written so that it is understandable to lay users.(vi) Labeling must also include the following statements, prominently placed:
(A) “For use only on a single patient. Discard the entire device after use.”
(B) “Warning: Not intended for more than one use. Do not use on more than one patient. Improper use of blood lancets can increase the risk of inadvertent transmission of bloodborne pathogens, particularly in settings where multiple patients are tested.”
(b)
Single use only blood lancet without an integral sharps injury prevention feature —(1)Identification. A disposable blood lancet intended for a single use that is comprised of a single use blade attached to a solid, non-reusable base that is used to puncture the skin to obtain a drop of blood for diagnostic purposes.(2)
Classification. Class II (special controls). The special controls are:(i) The design characteristics of the device must ensure that the structure and material composition are consistent with the intended use and address the risk of sharp object injuries and bloodborne pathogen transmissions.
(ii) Mechanical performance testing must demonstrate that the device will withstand forces encountered during use.
(iii) The device must be demonstrated to be biocompatible.
(iv) Sterility testing must demonstrate the sterility of any device component that breaches the skin (
e.g., blade).(v) Labeling must include:
(A) Detailed descriptions, with illustrations, of the proper use of the device.
(B) Handwashing instructions for the user before and after use of the device.
(C) Instructions on preparation (
e.g., cleaning, disinfection) of the skin to be pierced.(D) Instructions for the safe disposal of the device.
(E) Labeling must be appropriate for the intended use environment.
(
1 ) For those devices intended for health care settings, labeling must address the health care facility use of these devices, including how these lancets are to be used with personal protective equipment, such as gloves.(
2 ) For those devices intended for use in the home, labeling must be written so that it is understandable to lay users.(vi) Labeling must also include the following statements, prominently placed:
(A) “For use only on a single patient. Discard the entire device after use.”
(B) “Warning: Not intended for more than one use. Do not use on more than one patient. Improper use of blood lancets can increase the risk of inadvertent transmission of bloodborne pathogens, particularly in settings where multiple patients are tested.”
(c)
Multiple use blood lancet for single patient use only —(1)Identification. A multiple use capable blood lancet intended for use on a single patient that is comprised of a single use blade attached to a solid, reusable base that is used to puncture the skin to obtain a drop of blood for diagnostic purposes.(2)
Classification. Class II (special controls). The special controls are:(i) The design characteristics of the device must ensure that:
(A) The lancet blade can be changed with every use, either manually or by triggering a blade storage unit to discard the used blade and reload an unused blade into the reusable base; and
(B) The structure and material composition are consistent with the intended use and address the risk of sharp object injuries and bloodborne pathogen transmissions and allow for validated cleaning and disinfection.
(ii) Mechanical performance testing must demonstrate that the device will withstand forces encountered during use.
(iii) The device must be demonstrated to be biocompatible.
(iv) Sterility testing must demonstrate the sterility of any device component that breaches the skin (
e.g., blade).(v) Validation testing must demonstrate that the cleaning and disinfection instructions are adequate to ensure that the reusable lancet base can be cleaned and low level disinfected.
(vi) Labeling must include:
(A) Detailed descriptions, with illustrations, of the proper use of the device.
(B) The Environmental Protection Agency (EPA) registered disinfectant's contact time for disinfectant use.
(C) Handwashing instructions for the user before and after use of the device.
(D) Instructions on preparation (
e.g., cleaning, disinfection) of the skin to be pierced.(E) Instructions on the cleaning and disinfection of the device.
(F) Instructions for the safe disposal of the device.
(G) Instructions for use must address the safe storage of the reusable blood lancet base between uses to minimize contamination or damage and the safe storage and disposal of the refill lancet blades.
(H) Labeling must be appropriate for the intended use environment.
(
1 ) For those devices intended for health care settings, labeling must address the health care facility use of these devices, including how these lancets are to be used with personal protective equipment, such as gloves.(
2 ) For those devices intended for use in the home, labeling must be written so that it is understandable to lay users.(vii) Labeling must also include the following statements, prominently placed:
(A) “For use only on a single patient. Disinfect reusable components according to manufacturer's instructions between each use.”
(B) “Used lancet blades must be safely discarded after a single use.”
(C) “Warning: Do not use on more than one patient. Improper use of blood lancets can increase the risk of inadvertent transmission of bloodborne pathogens, particularly in settings where multiple patients are tested. The cleaning and disinfection instructions for this device are intended only to reduce the risk of local use site infection; they cannot render this device safe for use for more than one patient.”
(d)
Multiple use blood lancet for multiple patient use —(1)Identification. A multiple use capable blood lancet intended for use on multiple patients that is comprised of a single use blade attached to a solid, reusable base that is used to puncture the skin to obtain a drop of blood for diagnostic purposes.(2)
Classification. Class III (premarket approval).(3)
Date PMA or notice of completion of a PDP is required: A PMA or a notice of completion of a PDP is required to be filed with the Food and Drug Administration on or before May 22, 2024, for any multiple use blood lancet for multiple patient use described in paragraph (d)(1) of this section that was in commercial distribution before May 28, 1976, or that has, on or before May 22, 2024, been found to be substantially equivalent to a multiple use blood lancet for multiple patient use described in paragraph (d)(1) of this section that was in commercial distribution before May 28, 1976. Any other multiple use blood lancet for multiple patient use shall have an approved PMA or a declared completed PDP in effect before being placed in commercial distribution.

0

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

January 25, 2024

Facet Technologies, LLC James Bonds Director Regulatory Affairs 3900 North Commerce Drive Atlanta, Georgia 30344

Re: K232912

Trade/Device Name: Facet Aurora Reusable Lancet Base Regulation Number: 21 CFR 878.4850 Regulation Name: Blood Lancets Regulatory Class: Class II Product Code: QRL Dated: January 5, 2024 Received: January 5, 2024

Dear James Bonds:

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.

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).

1

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 OS 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).

Sincerely, Digitally signed by Mark Mark Trumbore -S Trumbore -S Date: 2024.01.25 13:59:29 -05'00' Mark Trumbore, Ph.D. Assistant Director DHT4A: Division of General Surgery Devices OHT4: Office of Surgical and Infection Control Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K232912

Device Name Facet Aurora Reusable Lancet Base

Indications for Use (Describe)

The Facet Aurora Reusable Lancet Base (commonly referred to as a lancing device) is a non-sterile reusable device which provides a spring-loaded mechanism to quickly eject and retract a lancet of proprietary design to effect a lancing event for the purpose of obtaining a droplet of capillary blood for diagnostic testing in children, adolescents, and adults in a home setting.

The device is designed to be cleaned and disinfected between uses on a single patient.

Type of Use (Select one or both, as applicable)
☐ Prescription Use (Part 21 CFR 801 Subpart D)❌ Over-The-Counter Use (21 CFR 801 Subpart C)

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3

K232912

Facet Aurora Reuseable Lancet Base

510(k) Summary (Reference 21 CFR 807.92)

| Submitted by: | Facet Technologies, LLC
3900 North Commerce Drive
Atlanta, GA 30344-8149
Phone Number: (770) 590-6462
Fax Number: (770) 590-6412 |
|-------------------------|----------------------------------------------------------------------------------------------------------------------------------------------|
| Contact: | James R. Bonds
Director Regulatory Affairs
JBonds@facetmed.com |
| Date of Preparation: | January 5, 2024 |
| Device Trade Name: | Facet Aurora Reuseable Lancet Base |
| Common Name: | Lancing Device |
| Classification Name: | Multiple use blood lancet base for single patient use only |
| Regulation: | 878.4850 |
| Product codes: | QRL (Multiple use blood lancet intended for use on a single
patient use only) |
| Product Classification: | II |
| Panel: | General & Plastic Surgery |
| Predicate Device: | Facet Aurora Reuseable Lancet Base (Product Code MDM,
510(k) Exempt) |

4

Device Description

The Facet Aurora Reuseable Lancet Base is a blood sampling device used in conjunction with a lancet blade of proprietary design to obtain a sample of capillary blood for diagnostic purposes, primarily for blood glucose monitoring in diabetic patients.

The lancing device has been in commercial distribution in the United States for over 10 years. There have been no significant design changes over the life of the device.

Indication for Use

The Facet Aurora Reusable Lancet Base (commonly referred to as a lancing device) is a nonsterile reusable device which provides a spring-loaded mechanism to quickly eject and retract a lancet of proprietary design to effect a lancing event for the purpose of obtaining a droplet of capillary blood for diagnostic testing in children, adolescents, and adults in a home setting.

The device is designed to be cleaned and disinfected between uses on a single patient.

Technological Characteristics

The primary technological characteristics and intended use of the Facet Aurora Reuseable Lancet Base are substantially equivalent to the predicate device.

As indicated in, the Facet Aurora Reuseable Lancet Base is substantially equivalent to characteristics of the identified predicate device, the Facet Aurora Reuseable Lancet Base previously marketed as a 510(k) exempt device.

As indicated in Table 1, the Facet Aurora Reuseable Lancet Base is substantially equivalent to characteristics of the identified predicate device, the Facet Aurora Reuseable Lancet Base previously marketed as a 510(k) exempt device.

5

CharacteristicPredicate DeviceSubject Device
Indication for UseThe Facet Aurora
Reusable Lancet Base
(commonly referred to
as a lancing device) is
a non-sterile reusable
device which provides
a spring-loaded
mechanism to quickly
eject and retract a
lancet of proprietary
design to effect a
lancing event for the
purpose of obtaining a
droplet of capillary
blood for diagnostic
testing in children,
adolescents, and adults
in a home setting.
The device is designed
to be cleaned and
disinfected between
uses on a single
patient.Same
ManufacturerFacet Technologies,
LLCSame
510(k) NumberN/AK232912
Product CodeMDMQRL
SterilityNon-sterile, can be
cleaned and low-level
disinfected between
usesSame
Penetration
Adjustment Depths7 depth settings
0.5mm-2.75mm, with
each change of the
depth setting being
approximately 0.3 mmSame
MaterialsPolycarbonate, ABS
(acrylonitrile-butadiene-
styrene), present
separately and as
copolymersSame

Comparison of Subject Device and Predicate Device Table 1:

6

Non-clinical Testing Summary and Conclusions

Non-clinical bench testing was performed to ensure predetermined criteria were met and the special controls (21 CFR 878.4850) were satisfied. This includes mechanical design verification and validation testing in order to ensure the risks were appropriately managed in addition to verifying that the mechanical functions of the device are suitable for use over the shelf life of the device.

Property/CharacteristicTest MethodImportanceReference
Endcap Removal ForceTensile strength
testerEnsure cap can be
removed easily to
insert lancet bladeN/A
Endcap Attachment
ForceTensile strength
testerEnsure cap will
remain on lancet
base during lancing
eventN/A
Depth of PunctureCalibrated High
Speed VideoEnsure depth of
puncture is
repeatable for
various depth
settingsN/A
Over-Charging ForceTensile force gaugeEnsure that device
can be charged to
engage actuation
springN/A
Charging ForceTensile force gaugeEnsure device can
be charged to
engage actuation
springN/A
Lancet Insertion ForceTensile force gaugeEnsure lancet can be
easily insertedN/A
Depth Adjust TorqueTorque gaugeEnsure that depth
adjustment can be
easily adjusted and
that adjustment will
not change during
useN/A
Button Activation ForceTensile force gaugeEnsure activation
force is within
specificationN/A
Lancet RotationTorque gaugeEnsure lancet does
not rotate during
device actuationN/A

Summary of Nonclinical Tests Performed Table 2:

7

Property/CharacteristicTest MethodImportanceReference
Drop TestSimulated Use after
dropEnsure that device
can withstand a 1
meter drop to a hard
surface and still
functionN/A
Life Cycle TestSimulated useEnsure device can
withstand 3 years of
expected useN/A
Chemical TestCleaning and
disinfection studiesEnsure device can
withstand
recommended
cleaning and
disinfection over
useful lifeN/A
Storage Temperature
TestSimulated UseEnsure device can
function after
exposure to heat and
cold cyclesN/A
BiocompatibilityCytotoxicity,
Sensitization,
Irritation or
Intracutaneous
reactivity, Acute
Systemic toxicity
(materials mediated
pyrogen)Ensure material of
construction are
biocompatible for
their intended useFDA Guidance Use
of International
Standard 10993-1,
"Biological evaluation
of medical devices -
Part 1: Evaluation
and testing within a
risk management
process", Sept.
2020,
ISO 10993-1, ISO
10993-5, ISO 0993-
10, ISO 10993-11

In summary, the results of nonclinical testing demonstrate that the candidate device is substantially equivalent to the predicate device.

. Conclusion

The intended use, technology, non-clinical testing, and functionality of the Facet Aurora Reuseable Lancet Base demonstrate a substantially equivalent safety and effectiveness profile to the predicate device and should perform as well as the predicate in the specified use conditions.