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510(k) Data Aggregation

    Why did this record match?
    Applicant Name (Manufacturer) :

    Berpu Medical Technology Co., Ltd.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Sterile Safety Hypodermic Needles for Single Use are intended to be used with a luer slip or luer lock syringe for aspiration and injection of fluids for medical purpose. After withdrawal of the needle from the body, the attached needle safety shield can be manually activated to cover the needle immediately after use to minimize risk of accidental needlestick.

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

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

    Device Description

    The proposed devices are provided in two types of configurations; one type is a Sterile Safety Hypodermic Needles for Single Use, the other is Sterile Hypodermic Needles for Single Use. The Sterile Hypodermic Needles also divided into two types, one type is an ordinary disposable needle contained in a sterility maintenance package, the other is self-sealing hypodermic needle with an end cap, the protective cap and end cap form a sterility maintenance package.

    The Sterile Safety Hypodermic Needles for Single Use are intended for single use only, which consists of a hypodermic needle with a safety sheath attached to the needle hub. The proposed device is available in 28-34 gauge and 4-32 mm lengths. The safety sheath will be manually activated to cover the needle immediately after use to minimize risk of accidental needle sticks.

    The Sterile Hypodermic Needles for Single Use are intended for single use only. The proposed device is available in 18-34 gauge and 2-40 mm lengths.

    The proposed devices are sterilized by Ethylene Oxide Gas to achieve a SAL of 10-6 and are supplied in a sterility maintenance package which could maintain the sterility of the device during the shelf life of five years.

    AI/ML Overview

    The provided text describes the 510(k) summary for hypodermic needles and does not contain information about an AI/ML-enabled medical device. Therefore, I cannot address the specific points regarding acceptance criteria and study details for such a device. The document primarily focuses on demonstrating substantial equivalence to a predicate device through non-clinical testing for physical, mechanical, chemical, biocompatibility, and sterilization properties of the needles.

    • No AI/ML device: The document pertains to "Sterile Safety Hypodermic Needles for Single Use" and "Sterile Hypodermic Needles for Single Use-Disposable Needles," and "Sterile Hypodermic Needles for Single Use-Self-sealing Hypodermic Needles." These are physical medical devices, not AI/ML-enabled software.
    • No AI/ML performance data: Consequently, there are no acceptance criteria or study details related to the performance of an AI/ML algorithm (e.g., sensitivity, specificity, AUC) or its impact on human reader performance.
    • Non-clinical tests: The document lists numerous non-clinical tests conducted to prove the device meets standards like ISO 7864, ISO 9626, and ISO 80369-7, as well as biocompatibility tests (cytotoxicity, irritation, sensitization, systemic toxicity, hemolysis, pyrogen). It also mentions a "Simulated Clinical Study" and "Safety Feature Test" for the sharps injury prevention feature, though details on the study design or sample size are not provided beyond stating that pre-established criteria were met.

    Therefore, I cannot generate the table or information requested as it is not present in the provided text.

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    K Number
    K221045
    Date Cleared
    2022-11-03

    (209 days)

    Product Code
    Regulation Number
    880.5860
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Berpu Medical Technology Co., Ltd

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Insulin Syringes without needle is intended for medical purpose in conjunction with sterile needle for the manual aspiration and injection of U100 insulin into subcutaneous tissues.

    Device Description

    The Insulin Syringes without needle is a sterile and single use syringe intended for injection of U-100 insulin into the body, in conjunction with a sterile needle. The proposed device is available in 1 ml. The proposed device is sterilized by Ethylene Oxide to achieve a SAL of 10-6 and supplied in immediate package to maintain the sterility of the device during the shelf life of 5 years.

    AI/ML Overview

    This document is a 510(k) Summary for a medical device called "Insulin Syringes without needle" (K221045) from Berpu Medical Technology Co., Ltd. It compares the proposed device to a predicate device (K162180) to demonstrate substantial equivalence.

    Here's an analysis of the acceptance criteria and supporting studies as presented in the document:

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

    The document does not explicitly present acceptance criteria in a table format with corresponding reported device performance for a specific study. Instead, it describes adherence to recognized standards and successful completion of various tests. For the purpose of this request, I will synthesize the information into a table based on the non-clinical testing performed and the standards referenced.

    Acceptance Criteria (Inferred from Standards)Reported Device Performance
    Material Performance
    Compliance with ISO 8537:2016 for insulin syringes (performance, dimensions, etc.)Complied with ISO 8537:2016
    Compliance with ISO 80369-7:2021 for small-bore connectors (Luer lock performance)Complied with ISO 80369-7:2021 (performance test conducted with proposed device)
    Biocompatibility (as per ISO 10993-1 for prolonged contact)
    Absence of CytotoxicityAddressed
    Absence of SensitizationAddressed
    Absence of Intracutaneous ReactivityAddressed
    Absence of Acute Systemic ToxicityAddressed
    Absence of Material-Mediated PyrogenicityAddressed
    Absence of Subchronic/Subacute ToxicityAddressed
    HemocompatibilityAddressed
    Particulate Matter in Injections (USP )Met the USP acceptance criteria
    Sterility & Shelf Life
    Sterilization validated per ISO 11135:2014 (Ethylene Oxide)Validated to achieve a SAL of 10^-6^
    Shelf life of 5 years (validated per ASTM F1980-16)5 years shelf life determined based on stability studies (accelerated aging and simulated shipping)
    EO and ECH residuals within limits (ISO 10993-7:2008)Complied
    Bacterial Endotoxin Limit (USP )Complied
    Packaging Integrity (after accelerated aging, environmental conditioning, transport)
    Visual Inspection (ASTM F1886 / F1886M-16)Performed
    Seal Strength (ASTM F88/F88M-15)Performed
    Dye Penetration (ASTM F1929-15)Performed. "All packaging deemed acceptable for protection of product and sterility maintenance." This implies passing criteria for these tests, although specific numerical results/criteria are not provided in this summary.

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

    The document does not specify sample sizes for "test sets" in the context of clinical studies, as it explicitly states "No clinical study is included in this submission."

    For non-clinical tests (e.g., performance, biocompatibility, sterilization validation, shelf-life, packaging), specific sample sizes used for testing are not provided in this summary. The data provenance would be from the manufacturer's internal testing or contracted laboratories performing tests according to the cited ISO and ASTM standards. This testing is typically prospective, performed on manufactured devices.

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

    Not applicable. No clinical studies were conducted, and therefore, no expert-established ground truth for a clinical test set is relevant to this submission.

    4. Adjudication method for the test set

    Not applicable. No clinical studies were conducted, and therefore, no adjudication method for a clinical test set is relevant to this submission.

    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 an insulin syringe, not an AI-powered diagnostic or assistive tool. No MRMC study was mentioned or would be relevant.

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

    Not applicable. This device is an insulin syringe, not an algorithm or AI system.

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

    For the non-clinical tests, the "ground truth" is established by the specified international (ISO) and national (ASTM, USP) standards. The device is tested against these standards, and its performance is compared to the requirements outlined in those standards. For example, for particulate matter, the ground truth is the maximum particle count allowed by USP . For sterility, the ground truth is a SAL of 10^-6^ as per ISO 11135.

    8. The sample size for the training set

    Not applicable. No AI/machine learning component is involved, so there is no training set in this context.

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

    Not applicable. No AI/machine learning component is involved, so there is no training set or corresponding ground truth establishment in this context.

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    K Number
    K220061
    Date Cleared
    2022-08-23

    (225 days)

    Product Code
    Regulation Number
    880.5860
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Berpu Medical Technology Co., Ltd.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Safety Insulin Syringe is a sterile, single use and non-reusable syringe intended for injection of U-100 insulin into the body, while reducing the risk of sharps injuries and the potential for insulin syringe reuse.

    Device Description

    The Safety Insulin Syringe is a sterile, single use and non-reusable syringe with a permanently attached needle, which is intended for injection of U-100 insulin into the body, while reducing the risk of sharps injuries and the potential for insulin syringe reuse. The proposed device is available in 0.3ml, 0.5ml, 1ml volumes with a 26G-34G gauge needle. The safety feature will be manually activated to cover the needle immediately after use to minimize risk of accidental needle sticks.

    AI/ML Overview

    The provided text describes a 510(k) premarket notification for a medical device, the "Safety Insulin Syringe," not an AI/ML medical device. Therefore, the information required to populate the fields related to AI/ML acceptance criteria and study design (such as training sets, test sets, expert adjudication, MRMC studies, etc.) is not present in the document.

    The document focuses on demonstrating substantial equivalence to a predicate device through non-clinical testing of the physical, chemical, and performance characteristics of the syringe itself, as well as its safety features.

    However, I can extract the acceptance criteria and performance data that are relevant to this type of medical device submission.

    Here's a summary based on the provided text, focusing on the available information:

    Acceptance Criteria and Device Performance (for a non-AI/ML medical device)

    The device, a "Safety Insulin Syringe," is evaluated based on its physical, chemical, and safety performance. The acceptance criteria are typically compliance with recognized international standards and demonstration of specific functional parameters.

    Acceptance Criteria CategorySpecific Acceptance CriteriaReported Device Performance
    Needle PerformanceCompliance with ISO 9626 (Stainless steel needle tubing for the manufacture of medical devices - Requirements and methods) and ISO 7864:2016 (Sterile hypodermic needles for single use - Requirements and test methods).Device demonstrated to be in conformance with ISO 9626 and ISO 7864:2016.
    Syringe PerformanceCompliance with ISO 8537:2016 (Sterile single-use syringes, with or without needle, for insulin).Device demonstrated to be in conformance with ISO 8537:2016.
    Safety Feature PerformanceCompliance with ISO 23908-First edition: Sharps Injury Protection - Requirements and Test Methods - Sharps protection features for single-use hypodermic needles. Specific parameters:
    • Force to activate the safety mechanism: less than 5N.
    • Force that the safety mechanism is destroyed (resist force): greater than 20N. | The safety feature performance test for the proposed device was evaluated, and the test result conforms to requirements of ISO 23908:2011 standards.
    • "The force to activate the safety mechanism is less than 5N" was met.
    • "The force that the safety mechanism is destroyed is greater than 20N" was met. |
      | Biocompatibility | Compliance with ISO 10993-1 for Externally Communicating Device, Blood Path Indirect, Prolonged Contact (>24 hours to 30 days). Testing includes: Cytotoxicity, Sensitization, Irritation or intracutaneous reactivity, Acute systemic toxicity, Pyrogenicity, Hemocompatibility, Subacute Systemic Toxicity. | Biocompatibility evaluated and results comply with ISO 10993 requirements. Specific tests conducted were: Cytotoxicity, Sensitization, Irritation or intracutaneous reactivity, Acute systemic toxicity, Pyrogenicity, Hemocompatibility, and Subacute Systemic Toxicity. |
      | Particulate Matter | Compliance with USP . | Testing performed and results not explicitly stated but implied to be compliant through lack of identified issue. |
      | Sterilization & Residues | Validation of sterilization per ISO 11135. Compliance with ISO 10993-7:2008 for EO and ECH (Ethylene Chlorohydrin) residue limits. Compliance with USP for Bacterial Endotoxin Limit. | Sterilization method validated per ISO 11135. Device found to be compliant with ISO 10993-7:2008 for EO and ECH residue and USP for Bacterial Endotoxin Limit. |
      | Shelf Life & Packaging Integrity | Shelf life of 5 years. Evaluation using physical, mechanical, chemical, and package tests on aging samples (validated using ASTM F1980-16 for accelerated aging). Simulated Transportation Test (ASTM D4169-16). Sterile Barrier Packaging Testing: Visual Inspection (ASTM F1886 / F1886M-16), Seal Strength (ASTM F88/F88M-15), Dye Penetration (ASTM F1929-15). | 5-year shelf life determined based on stability studies including accelerated aging. Simulated transportation test conducted according to ASTM D4169-16. Sterile barrier packaging tests performed: Visual Inspection (ASTM F1886 / F1886M-16), Seal Strength (ASTM F88/F88M-15), and Dye Penetration (ASTM F1929-15) – all implied to be compliant. |
      | Simulated Clinical Use (for Sharps Injury Prevention) | Evaluation of the safety mechanism according to FDA Guidance, "Guidance for Industry and FDA Staff: Medical Device with Sharps Injury Prevention Feature" (August 9, 2005) and ISO 23908. Pre-established criteria for safe and effective activation and protection. | A simulated clinical use study was performed on 500 device samples. The results demonstrated that the proposed device met the pre-established criteria. |

    Since this is not an AI/ML device, the following points are not applicable and are listed as "N/A":

    1. Sample size used for the test set and the data provenance:

      • Test Set Sample Size: N/A (for AI/ML test sets). For simulated clinical use of the physical device, 500 device samples were used.
      • Data Provenance: N/A (for AI/ML test sets, as no image/data input is being classified). The physical device performance testing was performed by the manufacturer, Berpu Medical Technology Co., Ltd. (China). The tests are non-clinical (laboratory/bench testing) and simulate real-world use.
    2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts: N/A (no ground truth based on expert review of data is established for this type of device).

    3. Adjudication method (e.g. 2+1, 3+1, none) for the test set: N/A.

    4. 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: N/A.

    5. If a standalone (i.e. algorithm only without human-in-the loop performance) was done: N/A.

    6. The type of ground truth used (expert consensus, pathology, outcomes data, etc): N/A (for AI/ML ground truth). The "ground truth" for this medical device is adherence to physical/performance standards (e.g., ISO, ASTM, USP) and functional testing parameters for its mechanical safety features.

    7. The sample size for the training set: N/A.

    8. How the ground truth for the training set was established: N/A.

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    K Number
    K213158
    Date Cleared
    2022-07-21

    (296 days)

    Product Code
    Regulation Number
    880.5860
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Berpu Medical Technology Co., Ltd.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Syringe with permanently attached needle 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

    The Syringe with permanently attached needle is intended for single use only. The proposed device is available in 0.3ml, 0.5ml, 1ml volumes with a 20G-34G gauge needle. The product is for single use and provided sterile (EtO). The shelf-life of the product is five-years. The proposed syringes are available in different combination of syringe volumes and/or needle sizes.

    AI/ML Overview

    The provided document is a 510(k) summary for a "Syringe with permanently attached needle" and does not contain information about acceptance criteria for an AI/ML powered device, nor a study proving such a device meets those criteria.

    The document describes a traditional medical device (a syringe) and its substantial equivalence to a predicate device based on non-clinical performance testing against established ISO and ASTM standards. Therefore, most of the requested information regarding AI/ML device performance and testing is not applicable to this submission.

    Here's an analysis based on the information provided, noting where the requested AI/ML specific information is absent:

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

    The document does not present acceptance criteria in a formal table with reported performance in the way typically expected for an AI/ML diagnostic or prognostic device. Instead, it states that "Non clinical tests were conducted to verify that the proposed device met all design specifications as was Substantially Equivalent (SE) to the predicate device."

    The non-clinical tests performed are listed as compliance with various ISO and ASTM standards. The acceptance criteria for these standards are implicit within the standards themselves, and the document explicitly states the device "complies" with them and that "The test results demonstrated that the proposed device is as safe and as effective as the predicate device."

    • Example from document:
      • Acceptance Criteria (implicit in standard): Sterile hypodermic syringes for single use must meet requirements of ISO 7886-1:2017.
      • Reported Device Performance: "Syringe performance: ISO 7886-1 [Compliant]" (from Table 2) and "Test results demonstrated that the proposed device complies with... ISO 7886-1:2017".

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

    This information is not applicable/not provided as this is not an AI/ML device and no diagnostic test set or data provenance is mentioned beyond general non-clinical device testing.

    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)

    This information is not applicable/not provided as this is not an AI/ML device and no expert-adjudicated ground truth is established. The "ground truth" for a syringe is its physical and functional properties meeting specifications.

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

    This information is not applicable/not provided as this is not an AI/ML device and no adjudication method is relevant.

    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

    There was no MRMC comparative effectiveness study done. This is not an AI/ML device designed to assist human readers. "No clinical study is included in this submission" (Section VIII).

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

    This information is not applicable/not provided as this is not an AI/ML device and therefore no standalone algorithm performance was assessed.

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

    The "ground truth" for the device's performance is established by compliance with recognized international and national standards (e.g., ISO, ASTM) for the physical and biological properties of the syringe and needle, along with material specifications for biocompatibility. For instance, sterility is confirmed by SAL (Sterility Assurance Level) compliance, and material safety by ISO 10993 series standards.

    8. The sample size for the training set

    This information is not applicable/not provided as this is not an AI/ML device and therefore no training set was used.

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

    This information is not applicable/not provided as this is not an AI/ML device and therefore no training set ground truth was established.

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    K Number
    K213811
    Date Cleared
    2022-05-12

    (156 days)

    Product Code
    Regulation Number
    880.5860
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Berpu Medical Technology Co., Ltd.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Sterile Hypodermic Syringes for Single Use are intended to be used for medical purposes on adult and pediatric population to inject fluids into or withdraw fluids from the body.

    Device Description

    The Sterile Hypodermic Syringe for Single Use is intended for single use only, which consists of barrel, plunger and piston. The proposed device is available in a variety syringe volume. The syringe is available in luer slip and luer lock two connector types which are intended to be connected with a hypodermic needle.

    AI/ML Overview

    The provided text is a 510(k) summary for a medical device (Sterile Hypodermic Syringe for Single Use) and does not contain information about acceptance criteria and study details as typically found for AI/ML-based medical devices. The document focuses on demonstrating substantial equivalence to a predicate device based on non-clinical performance, material comparisons, and adherence to recognized standards.

    Therefore, I cannot provide a table of acceptance criteria and reported device performance, nor details about sample sizes for test sets, data provenance, expert ground truth establishment, adjudication methods, MRMC studies, standalone performance, or training set specifics, as these are not discussed in the provided text.

    The document primarily outlines:

    1. Device Description: Sterile Hypodermic Syringe for Single Use, consisting of a barrel, plunger, and piston, available in various volumes and luer slip/luer lock connector types.
    2. Indication for Use: Intended for medical purposes on adult and pediatric populations to inject fluids into or withdraw fluids from the body.
    3. Predicate Device: K210227, Sterile syringe for single use with/without needle.
    4. Comparison to Predicate: Differences noted include volume specifications, piston material (Polyisoprene Rubber vs. Silicone Rubber), patient population explicit mention, and shelf-life (5 years vs. 3 years). These differences are argued not to affect safety and effectiveness.
    5. Non-Clinical Test Performance Testing: The device was tested for conformance with:
      • ISO 7886-1:2017 (Sterile hypodermic syringes for single use)
      • ISO 80369-7: 2016 (Small-bore connectors for liquids and gases in healthcare applications)
      • Biocompatibility Testing (ISO 10993-1): Cytotoxicity, Sensitization, Intracutaneous Reactivity Test, Acute Systemic Toxicity, Hemocompatibility, Pyrogenicity.
      • Particulate Matter Testing: USP .
      • Sterile Barrier Packaging Test: Visual inspection (ASTM F1886/F1886M-16), seal strength (ASTM F88/F88-15), and dye penetration test (ASTM F1929-15).
      • Sterilization and Shelf Life Test: Validated per ISO 11135, including EO residue, ECH residue (ISO 10993-7:2008), Bacteria Endotoxin Limit (USP ), and Shelf Life Evaluation (physical, mechanical, chemical, package tests on aging samples).

    The document declares that the device is substantially equivalent to the predicate based on these non-clinical tests and comparisons. It does not involve AI/ML components or the types of studies typically associated with such technologies.

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    K Number
    K212514
    Date Cleared
    2022-04-29

    (262 days)

    Product Code
    Regulation Number
    880.5570
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Berpu Medical Technology Co., Ltd.

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Safety Pen Needle for Single Use is intended for use with pen injector devices for the subcutaneous injection of insulin.

    The Insulin Pen Needle is intended for use with pen injector devices for the subcutaneous injection of insulin.

    Device Description

    The devices are provided in two types of configurations: Safety Pen Needle for Single Use and Insulin Pen Needle.

    The Safety Pen Needle for Single Use is intended for use with pen injector devices for the subcutaneous injection of insulin. It consists of a needle cap, needle hub, safety protective cover, self-destruction seat and sealed paper. The safety protective cover is manually activated to cover the needle immediately after use to minimize risk of accidental needle sticks.

    The Insulin Pen Needle is intended for use with pen injector devices for the subcutaneous injection of insulin. It consists of protective cap, needle tube, needle protective cover and sealed paper.

    AI/ML Overview

    The provided document describes a 510(k) premarket notification for a medical device, specifically Safety Pen Needles for Single Use and Insulin Pen Needles. It focuses on demonstrating substantial equivalence to a predicate device (K181447) rather than presenting a study for general acceptance criteria alone.

    Therefore, the response will be structured to address the acceptance criteria as derived from the comparative and standalone testing performed to establish substantial equivalence.

    Here's an analysis based on the provided text:


    1. Table of acceptance criteria and the reported device performance

    The document lists numerous non-clinical tests and standards that the proposed device was tested against. The acceptance criteria are implicit in compliance with these standards and the comparisons to the predicate device. The performance is stated as "complied with" or "met the requirements".

    Acceptance Criteria (Standard / Test)Reference Clause/StandardReported Device Performance
    Biocompatibility
    CytotoxicityISO 10993-5: 2009No cytotoxicity
    Irritation/Intracutaneous ReactivityISO 10993-10: 2010No intracutaneous reactivity
    SensitizationISO 10993-10: 2010No skin sensitization
    Systemic ToxicityISO 10993-11: 2017No systemic toxicity
    HemolysisASTM F756-17No Hemolysis
    PyrogenUSPNo Pyrogen
    Subacute ToxicityNot explicitly listed in table, but mentioned in textNo adverse effect
    Sterilization & Endotoxin
    EO Residue (EO, ECH)ISO 10993-7:2008Did not exceed limit
    Bacterial Endotoxins LimitUSPDid not exceed 20 EU/device
    Sterility Assurance Level (SAL)Not explicitly listed in table, but mentioned in text10^-6
    Packaging & Shelf Life
    Seal Integrity (Visual)ASTM F1886 / F1886M-16Deemed acceptable
    Seal StrengthASTM F88/F88M-15Complied with requirements
    Dye Penetration (Seal Leaks)ASTM F1929-15Complied with requirements
    Shelf Life (5 years)Physical, Mechanical, Chemical, Package TestsMaintain its performance
    Physical & Mechanical (General Needles)
    DimensionsISO 11608-2:2012 Cl. 4.2, ISO 9626:2016 Cl. 5.6Complied with requirements
    Flow RateISO 11608-2:2012 Cl. 4.3Complied with requirements
    Bond (Hub & Needle Tube)ISO 11608-2:2012 Cl. 4.4, ISO 7864:2016 Cl. 4.12Complied with requirements
    Needle PointsISO 11608-2:2012 Cl. 4.5, ISO 7864:2016 Cl. 4.11Complied with requirements
    Freedom from DefectsISO 11608-2:2012 Cl. 4.6Complied with requirements
    LubricationISO 11608-2:2012 Cl. 4.7Complied with requirements
    Dislocation of Measuring PointISO 11608-2:2012 Cl. 4.8Complied with requirements
    Functional Compatibility with Pen SystemsISO 11608-2:2012 Cl. 4.9Complied with requirements
    Ease of Assembly/DisassemblyISO 11608-2:2012 Cl. 4.10Complied with requirements
    CleanlinessISO 7864:2016 Cl. 4.3, ISO 9626:2016 Cl. 5.3Complied with requirements
    Acidity/AlkalinityISO 7864:2016 Cl. 4.4, ISO 9626:2016 Cl. 5.4Complied with requirements
    Extractable MetalsISO 7864:2016 Cl. 4.5Complied with requirements
    Size DesignationISO 7864:2016 Cl. 4.6, ISO 9626:2016 Cl. 5.5Complied with requirements
    Color CodingISO 7864:2016 Cl. 4.7Complied with requirements
    Needle HubISO 7864:2016 Cl. 4.8Complied with requirements
    Needle CapISO 7864:2016 Cl. 4.9Complied with requirements
    Needle TubeISO 7864:2016 Cl. 4.10Complied with requirements
    Lumen PatencyISO 7864:2016 Cl. 4.13Complied with requirements
    Surface Finish & AppearanceISO 9626:2016 Cl. 5.2Complied with requirements
    StiffnessISO 9626:2016 Cl. 5.8Complied with requirements
    Resistance to BreakageISO 9626:2016 Cl. 5.9Complied with requirements
    Resistance to CorrosionISO 9626:2016 Cl. 5.10Complied with requirements
    Particulate TestingUSPComplied with requirements
    Specific Safety Pen Needle Features
    Safety Feature PerformanceISO 23908:2011 & FDA GuidanceMet pre-established criteria
    Safety Feature Activation Forces(Compared to Predicate)Average at 3.71N (Predicate: 3.73N)

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

    The document does not specify the exact sample sizes for each test in the acceptance criteria. It broadly states "Non-clinical tests were conducted..." and "Physical, Mechanical, and Chemical testing listed in following table were performed on the proposed device."
    Regarding data provenance, the manufacturer is Berpu Medical Technology Co., Ltd. in Wenzhou, Zhejiang, China. Therefore, the data provenance is China, and the data is prospective as it involves direct testing of the proposed devices.

    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 as the document describes non-clinical laboratory and performance testing for a medical device (pen needles), not a diagnostic algorithm requiring expert ground truth for interpretation of images or other data. The "ground truth" here is defined by compliance with established international and ASTM standards.

    4. Adjudication method for the test set

    This section is not applicable for the same reasons as point 3. The evaluation is based on objective measurements against specified standard criteria, not subjective expert judgment requiring 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 section is not applicable. The device is a physical medical device (pen needle), not an AI-powered diagnostic tool, and therefore, no MRMC study or AI assistance evaluation was performed or is relevant.

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

    This section is not applicable as the device is a physical medical instrument, not an algorithm or software. The non-clinical tests described are "standalone" in the sense that they evaluate the device's intrinsic properties against standards, without human interaction influencing the core performance metrics being measured (e.g., flow rate, bond strength).

    7. The type of ground truth used

    The "ground truth" for the non-clinical tests and the product's performance is established by international and national standards (e.g., ISO, ASTM, USP) and the specifications derived from these standards. For example, the criteria for cytotoxicity or sterility assurance level (SAL) are defined by the respective ISO and USP standards. The "pre-established criteria" mentioned for the simulated clinical study and safety feature test would also fall under this category, likely derived from the relevant standards (ISO 23908:2011) and FDA guidance.

    8. The sample size for the training set

    This section is not applicable. The document describes the testing of a physical medical device. There is no "training set" in the context of an AI/ML algorithm. The training in device manufacturing typically refers to process validation and quality control, not data training.

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

    This section is not applicable for the same reason as point 8; there is no training set mentioned in the context of this device's approval process.


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    K Number
    K181447
    Date Cleared
    2019-03-12

    (284 days)

    Product Code
    Regulation Number
    880.5570
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Berpu Medical Technology Co., Ltd

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The safety insulin needle for single use is intended for use with pen injector devices for the subcutaneous injection of insulin.

    Device Description

    The proposed device, Safety insulin needle for single use is intended for use with pen injector devices for the subcutaneous injection of insulin. It consists of needle tube, hub, safety protective cover, self-destruction seat, spring, hub sheath, safety seat and sealed paper.

    The Safety insulin needle for single use is offered in various gauge sized and length.

    The proposed device is available in EO sterilized to achieve a Sterility Assurance Level (SAL) of 10°.

    AI/ML Overview

    The provided text is a 510(k) Summary for a medical device (Safety insulin needle for single use) seeking substantial equivalence to a predicate device. It details non-clinical tests conducted to support this claim, but it does not contain information about acceptance criteria or a study proving the device meets those criteria in the way typically associated with performance metrics like sensitivity, specificity, or accuracy for an AI/diagnostic device.

    The "acceptance criteria" discussed are compliance with various ISO and ASTM standards and the "study" is a compilation of non-clinical tests demonstrating adherence to these standards and the substantial equivalence to a predicate device. There is no AI component, nor is there a multi-reader multi-case study, stand-alone algorithm performance, or human-in-the-loop analysis mentioned.

    Let's break down what is available in the text according to your requested categories:

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

    The provided document doesn't present acceptance criteria in the form of performance metrics (like sensitivity/specificity) for a diagnostic device. Instead, it refers to compliance with established international standards for medical devices and biocompatibility.

    Acceptance Criteria CategorySpecific Criteria/Standard (Implicit Acceptance)Reported Device Performance
    Mechanical PerformanceISO 7864:2016 (Sterile hypodermic needles for single use)Complied with (implicitly, tested and met requirements)
    ISO 9626:2016 (Stainless steel needle tubing)Complied with (implicitly, tested and met requirements)
    ISO 11608-2:2012 (Needle-based injection systems)Complied with (implicitly, tested and met requirements)
    Material PerformanceISO 10993-1, -4, -5, -10, -11 (Biological evaluation of medical devices)Complied with (implicitly, patient-contact materials conform to series of standards)
    ASTM F88/F88M-15 (Seal Strength of Flexible Barrier Materials)Complied with (implicitly, tested and met requirements)
    ASTM F1929-15 (Detecting Seal Leaks in Porous Medical Packaging)Complied with (implicitly, tested and met requirements)
    USP Bacterial Endotoxins TestComplied with (No pyrogen, Endotoxin Limit 20EU per device)
    BiocompatibilityCytotoxicity standards (e.g., ISO 10993-5)No cytotoxicity
    Irritation standards (e.g., ISO 10993-10)No intracutaneous reactivity
    Sensitization standards (e.g., ISO 10993-10)No skin sensitization
    Systemic Toxicity standards (e.g., ISO 10993-11)No systemic toxicity
    Hemolysis standards (e.g., ISO 10993-4)No Hemolysis
    Pyrogen standards (e.g., USP )No Pyrogen (Endotoxin Limit 20EU per device)
    SterilizationISO 11135 (Ethylene Oxide Sterilization)Sterilization parameter established to achieve SAL of 10^-6
    ISO 10993-7 (Ethylene Oxide Sterilization Residuals)Complied with (implicitly, tested and met requirements)
    SAL (Sterility Assurance Level)10^-6
    OtherSingle Use confirmationYes
    Labeling compliance (21 CFR part 801)Complied with

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

    The document does not specify sample sizes for individual tests. It states that "Non-clinical tests were conducted to verify that the proposed device met all design specifications" and that "all the needle sizes of proposed device have been tested" and "all the needle lengths of the proposed device have been validated and tested". The data provenance is not explicitly stated beyond the manufacturer being Berpu Medical Technology Co., Ltd in China. These are laboratory/physical tests, not clinical data sets in the typical sense.

    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 device is a physical medical instrument (safety insulin needle), not an AI/diagnostic software. Ground truth in this context would refer to objective measurements of physical properties and biological responses according to established standards, not expert interpretation of data.

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

    Not applicable. See point 3.

    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

    No. The device is a physical safety insulin needle. There is no AI component or human reader interaction in the way an MRMC study would assess.

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

    No. This is not an algorithm or AI device.

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

    For the non-clinical tests, the "ground truth" is defined by the requirements and test methods outlined in the cited ISO and ASTM standards. This involves objective measurements of physical properties (e.g., needle dimensions, seal strength), chemical residues (e.g., EO residuals), and biological responses (e.g., cytotoxicity tests in cell cultures, systemic toxicity in animal models per ISO 10993 series).

    8. The sample size for the training set

    Not applicable. There is no mention of a training set as this is not an AI/machine learning device.

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

    Not applicable. See point 8.

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    Why did this record match?
    Applicant Name (Manufacturer) :

    BERPU MEDICAL TECHNOLOGY CO., LTD

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Self-destruction Safety Syringes for Single Use are intended to be used for medical purposes to inject fluid into or withdraw fluid from body. Its secondary intended use is to retract inside the safety barrel, contain the contaminated needle and aid in the prevention of accidental needle stick injuries.

    The Sterile Hypodermic Syringes for Single Use are intended to be used for medical purpose to inject fluid into or withdraw fluid from body.

    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.

    The Sterile Safety Hypodermic Needles for Single Use are intended to be used with a luer slip or luer slip syringe for aspiration and injection of fluids for medical purpose. After withdrawal of the needle from the body, the attached needle safety shield can be manually activated to cover the needle immediately after use to minimize risk of accidental needlestick.

    Device Description

    The Self-destruction Safety Syringes for Single Use are intended for single use only. The proposed device is available in 1mL, 3mL, 5mL, 10mL volumes with a 25 gauge, 25mm needle. The safety feature will be manually activated to retract the needle immediately after use to minimize risk of accidental needle sticks.

    The Sterile Hypodermic Syringes for Single Use are intended for single use only, which consists of barrel, plunger and piston. The proposed device is available in 1mL, 2mL, 5mL, 10mL, 20mL, 30mL and 50mL volumes. The syringe is available in luer lock connector types which are intended to be connected with a hypodermic needle.

    The Sterile Safety Hypodermic Needles for Single Use are intended for single use only, which consists of a hypodermic needle with a safety sheath attached to the needle hub. The proposed device is available in 18-27 gauge and 6-50 mm lengths. The safety sheath will be manually activated to cover the needle immediately after use to minimize risk of accidental needle sticks.

    The Sterile Hypodermic Needles for Single Use are intended for single use only. The proposed device is available in 14-30 gauge and 6-60 mm lengths.

    AI/ML Overview

    The provided text is an FDA 510(k) summary for various medical devices, including "Self-destruction Safety Syringes for Single Use" and "Sterile Safety Hypodermic Needles for Single Use," which incorporate safety features to prevent accidental needle stick injuries. The summary describes the non-clinical tests performed to demonstrate substantial equivalence to predicate devices, focusing on physical, mechanical, chemical properties, sterility, shelf-life, and biocompatibility.

    However, the provided document does not describe a study involving an AI-powered device or a multi-reader multi-case (MRMC) comparative effectiveness study. Instead, it focuses on the performance and safety of physical medical devices (syringes and needles). Therefore, I cannot extract the requested information related to acceptance criteria and study proving AI device performance, sample sizes for test and training sets, expert ground truth establishment, adjudication methods, or effects of AI assistance on human readers.

    The section "Simulated Clinical Use" on page 8 of 13 does mention "pre-established criteria" and a study on 500 device samples for the safety features of the syringes and needles, but these are related to the physical device's function, not an AI or imaging diagnostic performance.

    In summary, the provided document does not contain the information required to answer the prompt's specific questions about an AI device's acceptance criteria and performance study.

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    K Number
    K162180
    Date Cleared
    2016-12-29

    (147 days)

    Product Code
    Regulation Number
    880.5860
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    BERPU MEDICAL TECHNOLOGY CO., LTD

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The disposable insulin syringe is intended for medical purposes for the manual aspiration of U-100 insulin, and for the injection of insulin into parts of the body below the surface skin.

    Device Description

    The proposed device is a syringe with fixed needle tube which is intended for injection the manual aspiration of insulin, and for the injection of insulin into parts of the body below the surface skin. The insulin is injected to subcutaneous tissue by pushing force generated through pushing plunger rod of the insulin syringe. The proposed devices are provided sterile, single use.

    The proposed device is available in 0.3ml, 0.5ml and 1ml volumes.

    AI/ML Overview

    This document describes the premarket notification (510(k)) for the Disposable Insulin Syringe (K162180) by Berpu Medical Technology Co., Ltd. The submission aims to demonstrate substantial equivalence to a predicate device (K072739).

    Here's an analysis of the acceptance criteria and study information provided:

    1. Table of Acceptance Criteria and Reported Device Performance

    The device performance is demonstrated by compliance with various international standards for medical devices and specific tests. The table below summarizes these, acting as both acceptance criteria and reported performance (as the tests were performed to verify compliance).

    Acceptance Criteria (Standard & Clause)Reported Device Performance
    For materials (ISO 9626:1991/AMD-1:2001)
    Clause 3: MaterialsComplies
    Clause 4: Surface finishComplies
    Clause 5: CleanlinessComplies
    Clause 6: Limits for acidity and alkalinityComplies
    Clause 7: Size designationComplies
    Clause 8: DimensionsComplies
    Clause 9: StiffnessComplies
    Clause 10: Resistance to breakageComplies
    Clause 11: Resistance to corrosionComplies
    For sterility/cleanliness (ISO 7864:1993)
    Clause 4: CleanlinessComplies
    Clause 5: Limits for acidity or alkalinityComplies
    Clause 6: Limits for extractable metalsComplies
    Clause 7: Size designationComplies
    Clause 8: Colour codingComplies
    Clause 9: Needle hubComplies
    Clause 10: SheathComplies
    Clause 11: Needle tubeComplies
    Clause 12: Needle pointComplies
    Clause 13: PerformanceComplies
    For insulin syringes (ISO 8537:2007)
    Clause 5: Freedom from extraneous matterComplies
    Clause 6: Limits for extraneous matterComplies
    Clause 7: Lubrication of syringes and needlesComplies
    Clause 8: Range of sizeComplies
    Clause 9: Graduated scaleComplies
    Clause 10: BarrelComplies
    Clause 11: Piston/plunger assemblyComplies
    Clause 13: Needle tubing and needlesComplies
    Clause 14: Performance of assembled syringeComplies
    Clause 9.1: Dose Accuracy testingComplies
    Sterile Barrier Packaging Testing
    ASTM F88/F88-09: Seal strengthComplies
    ASTM F1140/F1140M-13: Internal pressureComplies
    ASTM F1929-12: Dye penetrationComplies
    Sterilization and Shelf Life Testing
    SAL: 10-6Achieved SAL 10-6
    Validation method: ISO 11135:2014Validation performed
    EO residue: ISO 10993-7:2008Complies with ISO 10993-7:2008
    ECH residue: ISO 10993-7:2008Complies with ISO 10993-7:2008
    Bacteria Endotoxin Limit: USP 38-NF 33Complies (No evidence of pyrogens)
    LAL Pyrogen Test: ISO 10993-11:2006Complies (No evidence of pyrogens)
    Shelf Life Evaluation (Physical, Mechanical, Chemical, Package, Sterility)Tests performed on accelerated aging samples to verify claimed shelf life
    Biocompatibility Testing (ISO 10993 standards)
    CytotoxicityNo cytotoxicity
    IrritationNo irritation reactivity
    SensitizationNo significant evidence of skin sensitization
    Systemic ToxicityNo significant evidence of systemic toxicity
    HemolysisNo evidence of hemolysis
    Pyrogen (mentioned again in comparison table)No evidence of pyrogens

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

    The document does not specify the exact sample sizes for each of the physical, mechanical, chemical, packaging, sterilization, or biocompatibility tests. It broadly states that "Non clinical tests were conducted to verify that the proposed device met all design specifications." The data provenance is implied to be from internal testing conducted by Berpu Medical Technology Co., Ltd in China, as they are the sponsor. The studies are prospective in the sense that they are conducted on the device being submitted for approval.

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

    This information is not provided. The ground truth for these types of device performance tests is typically established by compliance with international standards and validated testing methodologies, rather than expert consensus on individual cases.

    4. Adjudication method for the test set

    This information is not provided, as the studies are device performance tests against pre-defined standards, not typically involving adjudication of subjective outcomes by experts.

    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

    A MRMC comparative effectiveness study was not done. This device is a disposable insulin syringe, not an AI-powered diagnostic or assistive tool for human readers.

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

    This is not applicable to a disposable insulin syringe, which is a physical medical device and not an algorithm. Therefore, no standalone algorithm performance study was conducted.

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

    The ground truth for the performance of the Disposable Insulin Syringe is largely based on compliance with established international and national standards (ISO 9626, ISO 7864, ISO 8537, ISO 11135, ISO 10993-7, ISO 10993-11, USP 38-NF 33 , ASTM F88/F88-09, ASTM F1140/F1140M-13, ASTM F1929-12). These standards define acceptable ranges, limits, and methodologies for evaluating the physical, mechanical, chemical, and sterility properties of such devices.

    8. The sample size for the training set

    This is not applicable. The device is a physical medical instrument, not an AI model, and therefore does not have a "training set" in the context of machine learning.

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

    This is not applicable, as there is no training set for this device.

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