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510(k) Data Aggregation

    K Number
    K201634
    Date Cleared
    2021-03-26

    (283 days)

    Product Code
    Regulation Number
    880.5725
    Reference & Predicate Devices
    Why did this record match?
    Applicant Name (Manufacturer) :

    Chengdu Shifeng Medical Technology Co., Ltd.

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

    The RG 3ml Medication Cartridge is designed for use in hospitals and outpatient care environments with the CADD-MS®3 Ambulatory Infusion Pump for subcutaneous infusion of medication in adults.

    Device Description

    The RG 3ml Medication Cartridge is a sterile, single-use, non-pyrogenic, 3.0 ml piston syringe intended for use with the Smiths Medical MD, Inc. CADD-MS®3 Ambulatory Infusion Pump. The CADD-MS®3 Ambulatory Infusion Pump requires use of a 3 ml medication cartridge and an infusion set. The RG 3ml Medication Cartridge consists of a hollow barrel, movable plunger with O-rings for sealing and a male Luer lock fitting at the distal end. The male Luer lock fitting of the cartridge is connected to the female Luer fitting of an infusion set. The reservoir is placed in the CADD-MS®3 Ambulatory Infusion Pump to achieve its intended use. The RG 3ml Medication Cartridge is available with a 0.7mm (22G) x 12.5mm (1/2in.) needle and cap. The needle is attached to the end of the RG 3ml Medication Cartridge and operates as a syringe to withdraw medication from a vial.

    After the medication is filled in the RG 3ml Medication Cartridge, the plunger stopper is removed to allow the RG 3ml Medication Cartridge to fit inside the Smiths CADD-MS®3 Infusion Pump. A cartridge cap from the Smiths CADD-MS®3 Infusion Pump secures the RG 3ml Medication Cartridge into place. An infusion set is then attached to the luer lock fitting of the RG 3ml Medication Cartridge.

    AI/ML Overview

    The provided text describes the regulatory clearance of the RG 3ml Medication Cartridge and outlines studies conducted to demonstrate its substantial equivalence to a predicate device, primarily focusing on non-clinical performance testing.

    Here's an analysis based on your request, highlighting what information is available and what is not:

    1. Table of acceptance criteria and the reported device performance

    Acceptance Criteria CategorySpecific Test/StandardReported Device Performance
    BiocompatibilityISO 10993-1:2009 (Use of International Standard ISO 10993 Biological Evaluation of Medical Devices Part 1: Evaluation and Testing within a Risk Management Process) and relevant guidance- Cytotoxicity per ISO 10993-5:2009 - Dermal Sensitization per ISO 10993-10:2010 - Intracutaneous Irritation Test per ISO 10993-10:2010 - Acute Systemic Toxicity per ISO 10993-11:2017 - Subacute Toxicity per ISO 10993-11:2017 - Pyrogenicity per ISO 10993-11:2017 - Hemolysis (Direct Contact and Indirect Contact) per ISO 10993-4:2017
    Result: Complied with biocompatibility requirements and are considered biocompatible.
    Sterility & Shelf LifeSterility Validation per FDA recognized standard ISO 11135:2014 (Ethylene oxide sterilization), Shelf-life testingResult: A sterility assurance level (SAL) was validated to 10⁻⁶. The device demonstrated a 2-year shelf life, supported by sterility, packaging, and performance testing.
    Packaging IntegrityASTM F2096 (Bubble Test), ASTM F1929 (Dye Penetration Test), ASTM F1886 (Visual Inspection), ASTM D4169 (Simulated Shipping), ISO 11607-2 (General Packaging Standard), Seal strength testingResult: Packaging testing was conducted via these FDA recognized standards.
    Functional Performance (with CADD-MS®3 Ambulatory Infusion Pump)ISO 7886-2:2020 (Flow rate testing), Occlusion Alarm Testing, Cartridge Loading and Detection Testing, Cartridge Volume Alarm TestingResult: The RG 3ml Medication Cartridge, when used with the CADD-MS®3 Ambulatory Infusion Pump, passed all testing required in ISO 7886-2 and flow rate testing within pump specifications, demonstrating adequate performance and compatibility.

    Important Note: The document specifies that "differences between the intended use and technological characteristics of the subject device compared to the predicate do not raise different questions of safety and effectiveness." This implies that the acceptance criteria for the new device were primarily demonstrated through equivalency testing against established standards and the performance of the predicate device.

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

    The document describes non-clinical performance testing for a medical device (a medication cartridge). Such tests typically involve specific numbers of units (samples) of the device and may use standardized test fluids or conditions. However, the exact sample sizes used for each test (e.g., how many cartridges for flow rate testing, how many animals for biocompatibility) are NOT specified in this document.

    The data provenance is from non-clinical laboratory testing and is not tied to human subjects, countries of origin, or retrospective/prospective studies in the way clinical trials would be.

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

    This information is not applicable to the type of testing described. The "ground truth" for non-clinical performance testing is established by recognized international standards (e.g., ISO, ASTM) and the specifications of the compatible medical device (the CADD-MS®3 Ambulatory Infusion Pump). These are objective measurements against defined criteria, not subjective expert interpretations.

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

    This is not applicable to the type of testing described, as there is no subjective interpretation or consensus among experts required for the results of the performance tests. The tests yield objective measurements against predefined acceptance criteria.

    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

    An MRMC comparative effectiveness study is designed for evaluating diagnostic tools where human interpretation is involved, often with AI assistance (e.g., radiology images). This information is not applicable as the device is a medication cartridge, not an AI-powered diagnostic tool.

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

    This is not applicable. The device is a physical medical component, not a software algorithm.

    7. The type of ground truth used

    The ground truth used for evaluating the RG 3ml Medication Cartridge performance includes:

    • International Standards: e.g., ISO 10993 series for biocompatibility, ISO 11135 for sterilization, ISO 7886-2 for flow rate, ASTM standards for packaging.
    • Predicate Device Specifications: The CADD-MS®3 Ambulatory Infusion Pump's specifications for compatible cartridges and its performance characteristics served as a benchmark for comparison.
    • Defined Acceptance Criteria: Each test had specific pass/fail criteria derived from these standards and specifications.

    8. The sample size for the training set

    This is not applicable. The device is a physical product, not a machine learning model that requires a training set. The tests performed are engineering and biological validations, not algorithm training.

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

    This is not applicable for the same reason as point 8.

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