K Number
K241190
Date Cleared
2024-05-29

(30 days)

Product Code
Regulation Number
880.5860
Panel
HO
Reference & Predicate Devices
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

PLPT LDV (Low Dead Volume) LC(Luer-Cone) Sterile Syringe / PLPT LDV (Low Dead Volume) LL(Luer-Lock) Sterile Syringe is intended for use by health care professionals for general purpose aspiration of fluid from vials, ampoules and liquid injection below the surface of the skin.

Device Description

PLPT LDV LC Sterile Syringe / PLPT LDV LL Sterile Syringe is a device intended to inject fluids into, or withdraw fluids from, parts of the body below the skin. The device consists of a calibrated barrel (cylinder) with a plunger, and metal tube that is sharpened at one end and at the other end joined to a female connector (hub). This device is intended for various medical applications and is not dedication administration. The distal end of the barrel has a Luer-Cone or Luer-lock connector for the attachment to a hypodermic needle or an administration set. The attached needle is covered by the protective cap which is intended to provide physical protection to the needle tube. The attached needle may have a safety guard that protects the user after use. This product is packed by sterile paper and sterilized by EO gas, and is a single-use device.

AI/ML Overview

This document is a 510(k) summary for the PLPT LDV (Low Dead Volume) LC (Luer-Cone) Sterile Syringe and PLPT LDV (Low Dead Volume) LL (Luer-Lock) Sterile Syringe. It outlines the performance data and equivalence comparison to a predicate device.

1. Table of Acceptance Criteria and Reported Device Performance:

The document primarily relies on compliance with established ISO standards and USP requirements rather than defining specific acceptance criteria values with corresponding measured performance values in a single table. Instead, it states that tests were "passed" or "met requirements." This is typical for medical device submissions demonstrating substantial equivalence to a predicate device by adhering to recognized consensus standards.

Here's a summary of the acceptance criteria (standards/test criteria) and reported performance:

Test ItemTest Method / Test CriteriaReported Device Performance
BiocompatibilityAll evaluation acceptance criteria were met.
Cytotoxicity TestWhen tested accordingly to ISO 10993-5, tests for in vitro cytotoxicity - Test on extracts method, it should satisfy the requirements.Pass
Hemolysis TestWhen tested accordingly to ISO 10993-4, Selection of tests for interactions with blood - evaluation of hemolytic properties of medical devices and medical device materials, it should satisfy the requirements.Pass
Intracutaneous Reactivity TestWhen tested accordingly to ISO 10993-10, Tests for irritation and skin sensitization - Animal intracutaneous (Intradermal) reactivity test, it should satisfy the requirements.Pass
Skin Sensitization TestWhen tested accordingly to ISO 10993-10, Tests for irritation and skin sensitization - Guinea pig maximization test (GPMT), it should satisfy the requirements.Pass
Acute Systemic Toxicity TestWhen tested accordingly to ISO 10993-11, Tests for systemic toxicity - Acute systemic toxicity, it should satisfy the requirements.Pass
Pyrogen TestWhen tested accordingly to ISO 10993-11, Tests for systemic toxicity - Information on material-mediated pyrogens, it should satisfy the requirements.Pass
LAL TestUSP39 , Bacterial Endotoxins TestPass
Particulate Matter InjectionUSP , Particulate Matter for Injections (Method 1 Light Obscuration Particle Count Test). Test result should satisfy the requirements described in the USP .Pass
Sterility and LAL Test
LAL testUSP39 , Bacterial Endotoxins Test (Unit : EU/Device)Pass
E.O sterilization validationAccording to ISO 11135:2014 E.O 30%, CO2 70% Temperature: 50 ± 7°C Exposure time: 5 hoursPass
Sterility testAccording to ISO 11737-2Pass
E.O Residual testUnder the conditions of ISO 10993-7:2008, Ethylene oxide sterilization residuals, the test articles should meet the test requirements.Pass
Needle Injury Test
Needle penetration forceISO 23908: 2011 Sharps injury protectionPass
Pull-out forceISO 23908: 2011 Sharps injury protectionPass
Needle cap removal forceISO 23908: 2011 Sharps injury protectionPass
Activation (locking) forceISO 23908: 2011 Sharps injury protectionPass
Unlocking forceISO 23908: 2011 Sharps injury protectionPass
Mechanical PerformanceComplies with ISO 7886-1:2017 Sterile hypodermic syringes for single use - Part 1: Syringes for manual use.Complies
Needle Performance RequirementsISO 7864:2016 Sterile hypodermic needles for single use - Requirements and test methods.
ISO 9626:2016 Stainless steel needle tubing for the manufacture of medical devices - Requirements and test methods.Complies
Safety Feature Performance SpecsISO 23908:2011 Sharps Injury Protection - Requirements And Test Methods - Sharps Protection Features For Single-Use Hypodermic Needles, Introducers For Catheters And Needles Used For Blood Sampling.Complies
Dead Space Specification (Syringe)≤ 0.023mL with 95% confidence/95% reliability≤ 0.023mL
Dead Space Specification (Needle)≤ 0.0054ml (No specific confidence/reliability mentioned for needle, but implied to meet this target)≤ 0.0054ml
Shelf LifeISO 11607-1:2006 and ISO 11607-2:2006 compliance for 5 years.Validated for 5 years

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

The document mentions "Bench tests for the device's performance were conducted." and "Performance testing was conducted for this change". However, it does not specify the sample sizes used for the test sets for any of the performance or biocompatibility evaluations.

The data provenance is not explicitly stated in terms of country of origin, but the manufacturer is "Poonglim Pharmatech Inc." located in "Gunsan, 54001, Republic of Korea." The nature of the tests (bench, biocompatibility, sterility) implies prospective testing on manufactured devices, not retrospective data analysis.

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

This information is not applicable and not provided in the document. The tests performed are objective, laboratory-based physical, chemical, and biological tests governed by international standards (ISO, USP). They do not require interpretation by a panel of human experts in the way clinical diagnostic or AI-based image analysis studies might.

4. Adjudication Method for the Test Set:

This information is not applicable as the tests are objective, laboratory-based evaluations against predetermined criteria. There is no human subjective assessment that requires adjudication.

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 information is not applicable and not provided. This document pertains to the market clearance of a sterile syringe, which is a physical medical device. It does not involve any artificial intelligence (AI) component or human diagnostic interpretation that would warrant an MRMC study.

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

This information is not applicable and not provided. This device is a physical syringe and does not have an algorithm or AI component.

7. The Type of Ground Truth Used:

The "ground truth" for the performance criteria and biocompatibility assessments is based on established international consensus standards (ISO) and pharmacopeial monographs (USP). For instance, cytotoxicity is evaluated against requirements of ISO 10993-5, sterility against ISO 11737-2, and mechanical properties against ISO 7886-1 and ISO 23908. These standards define the acceptable limits and methodologies, which serve as the "ground truth" for compliance.

8. The Sample Size for the Training Set:

This information is not applicable and not provided. This device is a physical syringe and does not involve machine learning or a training set.

9. How the Ground Truth for the Training Set was Established:

This information is not applicable and not provided as there is no training set for this type of device.

§ 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).