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510(k) Data Aggregation
(179 days)
HTL-Strefa S.A.
droplet® personal lancets are sterile, single-use medical devices intended to be used with a lancing device by lay users for capillary blood sampling.
droplet® personal lancet is made of steel needle placed inside the plastic body lancet with plastic protective cap.
The lancet remains sterile until the cap is removed. There are two versions of droplet® personal lancets which differ in the needle diameter: 28G and 30G. These two versions differ in lancet body color. The version 28G is available in pink and blue colors, and version 30G is available in violet version.
The provided FDA 510(k) Clearance Letter for droplet® personal lancets
outlines the device's technical characteristics and studies performed. However, it does not contain detailed acceptance criteria tables, specific performance metrics, sample sizes, or information typically associated with AI/software-based medical devices (such as clinical study design, ground truth establishment, expert adjudication, or MRMC studies).
The document states: "Clinical data is not required." and focuses on non-clinical performance data for physical device characteristics and compatibility.
Therefore, the following response is based solely on the information available in the provided text, and will highlight what is present while explicitly stating what information is not provided as per the request.
Acceptance Criteria and Study Proving Device Meets Criteria for droplet® personal lancets
The droplet® personal lancets
are mechanical medical devices (blood lancets) and as such, the acceptance criteria and study data relate to physical and functional attributes rather than diagnostic or analytical performance metrics typical of AI/software devices. The provided 510(k) summary focuses on demonstrating substantial equivalence to a predicate device through non-clinical performance data.
1. Table of Acceptance Criteria and Reported Device Performance
The document describes the types of tests performed and states that "All tests were passed and met the predefined acceptance criteria." However, it does not provide a specific table of these "predefined acceptance criteria" or the quantitative reported performance values. It lists the categories of tests conducted.
Acceptance Criteria Category | Reported Device Performance |
---|---|
Product Specifications: | |
Color and aesthetics | Passed (met predefined criteria) |
Presence of one raw needle | Passed (met predefined criteria) |
Orientation of raw needle | Passed (met predefined criteria) |
Point sharpness | Passed (met predefined criteria) |
Lancet length (raw needle protrusion) | Passed (met predefined criteria) |
Lancing Device Compatibility: | |
Installation in lancing device | Evaluated for compatibility with selected lancing devices; results used to establish compatible device list. |
Stability in lancing device | Evaluated for compatibility with selected lancing devices; results used to establish compatible device list. |
Proper closing of lancing device | Evaluated for compatibility with selected lancing devices; results used to establish compatible device list. |
Loading and activating lancing device | Evaluated for compatibility with selected lancing devices; results used to establish compatible device list. |
Lancet rotation when twisting off cap | Evaluated for compatibility with selected lancing devices; results used to establish compatible device list. |
Needle protrusion from lancing device | Evaluated for compatibility with selected lancing devices; results used to establish compatible device list. |
Needle retraction from lancing device | Evaluated for compatibility with selected lancing devices; results used to establish compatible device list. |
Other Non-Clinical Data: | |
Biocompatibility | Conforms to ISO 10993-1 (stated as a technological characteristic) |
Sterilization (SAL) | SAL=10^-6 (stated as a technological characteristic) |
Shelf life | 5 years (stated as a technological characteristic) |
Transport tests (shipper, primary boxes integrity, product integrity after hazards) | All components complete; product not poured out; product meets predefined requirements; device not damaged; did not lose technological performance. |
2. Sample Size Used for the Test Set and Data Provenance
The document does not specify the sample sizes used for any of the non-clinical performance tests.
- Data Provenance: The tests were conducted internally by HTL-Strefa S.A.'s quality control and presumably in their home country (Poland), as indicated by the company's address. The data is retrospective in the sense that the tests were completed prior to the 510(k) submission.
3. Number of Experts Used to Establish Ground Truth and Qualifications
This information is not applicable/provided. The droplet® personal lancets
are physical medical devices, and their performance evaluation relies on engineering, material science, and functional testing, not expert interpretation of outputs like in AI/imaging devices. Ground truth for properties like sharpness or needle protrusion would be established via metrology and physical testing methods, not human expert consensus.
4. Adjudication Method for the Test Set
This information is not applicable/provided. Adjudication methods (e.g., 2+1, 3+1) are typically used for establishing consensus ground truth in clinical evaluations, particularly for subjective assessments or borderline cases, which is not relevant to the described non-clinical testing of a lancet.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
A MRMC study was not conducted and is not applicable. This type of study is relevant for evaluating the impact of AI assistance on human reader performance in diagnostic tasks, typically within imaging or pathology. The droplet® personal lancets
are standalone devices used for blood sampling, not for diagnostic interpretation by human readers.
6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study
A standalone performance study of an algorithm was not conducted and is not applicable. This device does not involve an algorithm. The reported non-clinical performance data represents the "standalone" performance of the physical device on its own against specified criteria.
7. Type of Ground Truth Used
The "ground truth" for the non-clinical tests appears to be based on:
- Manufacturer's Predefined Product Specifications: For physical attributes like color, aesthetics, needle presence, orientation, sharpness, and length.
- Engineering/Functional Test Standards: For compatibility with lancing devices (e.g., proper fit, function, retraction).
- International Standards: For biocompatibility (ISO 10993-1) and sterilization (SAL).
- Simulated Environmental Conditions: For transport tests.
It is not based on expert consensus, pathology, or outcomes data in a clinical diagnostic sense.
8. Sample Size for the Training Set
This information is not applicable. The device is a physical product and does not involve AI/machine learning, therefore, there is no "training set."
9. How the Ground Truth for the Training Set Was Established
This information is not applicable. As there is no training set for an AI/ML model, there is no ground truth established for it.
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(126 days)
HTL-Strefa S.A.
Sterile, single use medical devices intended for capillary blood sampling.
DropSafe/droplet Safety Lancets are sterile, single use medical devices intended for capillary blood sampling. The devices have similar design and are gamma sterilized. DropSafe/droplet Safety Lancets comprise needle or blade and are offered with different gages and lengths (different skin penetration depths after puncture). DropSafe/droplet Safety Lancets are sterile until protective cap is removed. DropSafe/droplet Safety Lancets are push-button activated or activated by pressing the device against the puncture site (contact activation). Regardless of the activation mechanism, the devices are designed to minimize the risk form accidental needle/blade sticks with a used needle/blade by application sharps prevention feature. Following use, the needle/blade retracts into the housing which prevents reuse and accidental sticks. The devices are packed in various quantities in boxes. DropSafe/droplet Safety Lancets share the same technological design and principle of operation. The selected models comprise a needle or a blade. The only differences relate to the shape of the outer housing of the devices and the method of their activation.
I am sorry, but the provided text does not contain the specific information required to answer your request about acceptance criteria and the study proving the device meets them.
The document is an FDA 510(k) clearance letter and summary for a medical device (safety lancets). While it discusses safety and effectiveness studies, it does not provide:
- A table of acceptance criteria with reported device performance.
- Sample sizes for test sets, data provenance, number of experts, expert qualifications, or adjudication methods for test sets.
- Information about multi-reader multi-case (MRMC) comparative effectiveness studies or the effect size of AI assistance.
- Information about standalone (algorithm-only) performance.
- The specific type of ground truth used (beyond implying it relates to sharps injury prevention and compliance with product specifications).
- Sample size for the training set or how ground truth for the training set was established.
The non-clinical performance data section mentions internal quality control tests and compliance with established requirements as per product specifications, but it doesn't detail the acceptance criteria for these specific tests. It also mentions biocompatibility, sterilization, and transport tests, which likely have acceptance criteria based on relevant standards, but these are not explicitly stated in the provided text.
The clinical performance data section mentions simulated clinical use studies for sharps injury prevention features conducted in the USA between 2018 and 2019, referencing an FDA guidance document. It states that "all of tested types of the DropSafe/droplet Safety Lancets passed the sharps injury prevention study." However, it does not provide the specific acceptance criterion used to determine "passed" or the detailed results.
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(59 days)
HTL-Strefa S.A.
The DROPLET® PEN NEEDLES 30G & 33G are intended for use with pen injector devices for the subcutaneous injection of drugs.
DROPLET® PEN NEEDLES 30G & 33G 4G are sterile, single use needles intended for use with pen injector devices for the subcutaneous injection of drugs. The pen needles are OTC devices. The pen needle assembly consists of a double-ended cannula that is assembled into an injection molded hub using adhesive. The hub has internal threads, which allow it to be screwed onto the pen injector device. This allows the cartridge end of the cannula to penetrate through the rubber septum of the cartridge. The patient end and the cartridge end of the cannula are lubricated using a silicone -based lubricant for ease of injection and rubber septum penetration. There is an inner needle shield assembled over the patient end of the cannula to protect the needle point from damage and accidental needle sticks. There is also an outer cover. Each pen needle assembly is protected with a peel away seal to provide a sterility barrier.
The provided document is a 510(k) Premarket Notification for a medical device: Droplet Pen Needle 30G & 33G.
This document describes a submission for a new medical device seeking to demonstrate substantial equivalence to a previously cleared predicate device, not a study proving the device meets acceptance criteria for an AI/ML powered device. Therefore, much of the requested information regarding AI/ML device performance metrics, such as ground truth establishment with experts, MRMC studies, and training/test set details, is not applicable to this document.
However, I can extract the acceptance criteria and non-clinical performance data for this specific medical device, which are based on compliance with an international standard (ISO 11608-2:2012) and biocompatibility testing.
Here's a breakdown of the information that can be extracted and what cannot:
Information that can be extracted from the document:
- Acceptance Criteria (as defined by standard compliance) and Reported Device Performance: This is derived from the "Non-Clinical Performance Data" section.
- Sample size for the test set: Not explicitly stated as "test set" in the context of AI, but the non-clinical tests would have involved samples of the device. The document does not specify the number of units tested for each parameter.
- Data Provenance: The tests were performed by HTL-Strefa S.A. (Poland). The data is non-clinical, related to device performance in laboratory settings, not patient data.
- Type of Ground Truth: For this type of device, the "ground truth" is defined by the technical specifications and requirements outlined in the ISO standard and the results of various physical, chemical, and biological tests.
Information that CANNOT be extracted from the document (as it's not an AI/ML device submission):
- Number of experts used to establish ground truth
- Qualifications of those experts
- Adjudication method for the test set
- Multi-Reader Multi-Case (MRMC) comparative effectiveness study
- Standalone (algorithm only) performance
- Sample size for the training set
- How the ground truth for the training set was established
Acceptance Criteria and Study Proving Device Meets Acceptance Criteria for Droplet Pen Needle 30G & 33G
As this is a submission for a physical medical device (hypodermic needle) and not an AI/ML powered device, the "acceptance criteria" are defined by compliance with relevant international standards and successful completion of non-clinical performance and biocompatibility testing. There is no AI model or human-in-the-loop performance measurement.
1. Table of Acceptance Criteria and Reported Device Performance
The device performance is demonstrated by its compliance with the requirements of ISO 11608-2:2012 Needle-based injection systems for medical use -- Requirements and test methods -- Part 2: Needles.
Test Parameter | Clause no. & Requirement of ISO 11608-2:2012 | Acceptance Criteria (Met if "Meets requirements") | Reported Device Performance |
---|---|---|---|
Materials | 4.1 The needle shall be made of tubing materials specified in ISO 9626. | Meets requirements | Meets requirements |
Dimensions | 4.2 The needles shall fit the test apparatus specified in item 7.3 of ISO 11608-2. | Meets requirements | Meets requirements |
Determination of flow rate through the needle | 4.3 The needle was tested in accordance with Annex A to ISO 11608-2 to determine flow rate through the needle. | Meets requirements | Meets requirements |
Bond between hub and needle tube | 4.4 The union of the hub and needle tube shall not break when tested in accordance with Clause 9 of ISO 11608-2. | Meets requirements | Meets requirements |
Needle points | 4.5 When examined under a magnification of x2.5, needle points shall appear sharp and free from feather edges, burrs and hooks. | Meets requirements | Meets requirements |
Freedom from defects | 4.6 The needle tube shall fulfill the requirements of ISO 7864, 11.3. | Meets requirements | Meets requirements |
Lubrication | 4.7 The needle tube should be lubricated at both the patient end and the cartridge end. The lubricant shall not, under normal or corrected-to-normal vision, be visible as droplets of fluid on the outside surface of the needle tube. | Meets requirements | Meets requirements |
Dislocation of measuring point at patient end | 4.8 Dislocation of the cannula point at the patient end shall be in accordance with Table 2 below when tested as per Clause 8 (of ISO 11608-2). | Meets requirements | Meets requirements |
Determination of functional compatibility with needle-based injection systems | 4.9 Compatibility with any NIS shall be claimed only after testing in accordance with Clause 11. | Meets requirements | Meets requirements |
Ease of assembly and disassembly | 4.10 Attachment of the needle shall be possible without removing the needle from its opened unit packaging. Compliance is checked according to the requirements of Clause 11. | Meets requirements | Meets requirements |
Sterility | 4.11 The needle in its unit packaging shall has been subjected to a validated sterilization process. | Meets requirements (SAL = 10^-6) | Meets requirements |
Pre-conditioning of needles | 6 All requirements of the standard related to preconditioning of needles were met. | Meets requirements | Meets requirements |
Biocompatibility Testing:
The device also successfully passed all required biocompatibility tests according to the 2016 FDA guidance Use of International Standard ISO 10993-1. These tests included:
- Cytotoxicity
- Sensitization
- Irritation or Intracutaneous Reactivity
- Acute Systemic Toxicity
- ISO Two Week Systemic Toxicity Study in the Rat, Repeated Parenteral Administration of Two Extracts
- Material-Mediated Pyrogenicity
- Hemocompatibility
Reported Biocompatibility Performance: Did not show any adverse biological/biocompatibility reactions.
2. Sample size used for the test set and the data provenance
- Sample Size for Test Set: The document does not specify the exact number of units tested for each parameter within the non-clinical performance and biocompatibility testing. This information is typically detailed in the full test reports, which are summarized here.
- Data Provenance: The testing was conducted by HTL-Strefa S.A. based in Poland (ul. Adamówek 7, 95-035 Ozorków, POLAND). The data pertains to non-clinical laboratory testing of the physical device, not patient data, and is thus "prospective" in the sense that the new device was manufactured and then subjected to these tests.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
- Not applicable for this type of medical device submission. Ground truth for physical device performance is established by standardized testing methods and international standards, not by human expert consensus or annotation of data. The qualifications of the personnel conducting the tests would be subject to internal quality system requirements (e.g., ISO 13485).
4. Adjudication method for the test set
- Not applicable for this type of medical device submission. Adjudication methods like 2+1 or 3+1 are used in subjective assessments (e.g., image interpretation) where there might be disagreement among human readers or annotators. For objective physical device tests, results are typically measured and compared against defined thresholds.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
- Not applicable. This device is a physical hypodermic needle, not an AI-powered device. Therefore, no MRMC study, human reader improvement, or AI assistance is relevant.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Not applicable. This device does not involve any algorithm.
7. The type of ground truth used
- The "ground truth" for this device is defined by the technical specifications and performance requirements outlined in the ISO 11608-2:2012 standard and the established biocompatibility criteria from ISO 10993-1. Performance is measured objectively against these established standards.
8. The sample size for the training set
- Not applicable. There is no "training set" as this is a physical device, not an AI model.
9. How the ground truth for the training set was established
- Not applicable. There is no "training set" or need for "ground truth establishment" in the AI/ML sense for this device.
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(263 days)
HTL-Strefa S.A
The DROPLET® PEN NEEDLE 34G is intended for use with pen injector devices for the subcutaneous injection of drugs.
DROPLET® PEN NEEDLES 34G are sterile, single use needles intended for use with pen injector devices for the subcutaneous injection of drugs. The pen needles are OTC devices. The pen needle assembly consists of a double-ended into an injection molded hub using adhesive. The hub has internal threads, which allow it to be screwed onto the pen injector device. This allows the cartridge end of the cannula to penetrate through the rubber septum of the cartridge. The patient end of the cannula are lubricated using a siliconebased lubricant for ease of injection and rubber septum penetration. There is an inner needle shield assembled over the cannula to protect the needle point from damage and accidental needle sticks. There is also an outer cover. Each pen needle assembly is protected with a peel away seal to provide a sterility barrier.
The provided text is a 510(k) Summary for the DROPLET® PEN NEEDLE 34G. It details the device's characteristics and compares it to predicate devices to establish substantial equivalence, rather than describing a study proving the device meets specific acceptance criteria in the context of diagnostic performance or clinical outcomes.
Therefore, many of the requested elements for describing "acceptance criteria and the study that proves the device meets the acceptance criteria" are not applicable or cannot be extracted directly from this document. The document focuses on regulatory clearance based on substantial equivalence to existing devices, primarily through non-clinical performance and scientific rationale, rather than a clinical trial demonstrating diagnostic or treatment effectiveness against specific performance metrics.
However, I can extract the acceptance criteria related to non-clinical performance and the "study" (bench testing and validations) that demonstrates compliance with those criteria.
1. A table of acceptance criteria and the reported device performance
Test Parameter / Acceptance Criteria (from ISO 11608-2:2012) | Reported Device Performance |
---|---|
Materials: Needle shall be made of tubing materials specified in ISO 9626. | Meets requirements |
Dimensions: Needles shall fit the test apparatus specified in item 7.3 of ISO 11608-2. | Meets requirements |
Determination of flow rate through the needle: Tested in accordance with Annex A to ISO 11608-2. | Meets requirements |
Bond between hub and needle tube: Union of the hub and needle tube shall not break when tested in accordance with Clause 9 of ISO 11608-2. | Meets requirements |
Needle points: When examined under a magnification of x2.5, needle points shall appear sharp and free from feather edges, burrs and hooks. | Meets requirements |
Freedom from defects: Needle tube shall fulfill the requirements of ISO 7864, 11.3. | Meets requirements |
Lubrication: Lubricant shall not, under normal or corrected-to-normal vision, be visible as droplets of fluid on the outside surface of the needle tube. | Meets requirements |
Dislocation of measuring point at patient end: Dislocation of the cannula point at the patient end shall be in accordance with Table 2 of ISO 11608-2, when tested as per Clause 8. | Meets requirements |
Determination of functional compatibility with needle-based injection systems: Compatibility with any NIS shall be claimed only after testing in accordance with Clause 11. | Meets requirements |
Ease of assembly and disassembly: Attachment of the needle shall be possible without removing the needle from its opened unit packaging. Compliance is checked according to the requirements of Clause 11. | Meets requirements |
Sterility: Needle in its unit packaging shall have been subjected to a validated sterilization process (SAL = 10^-6). | Meets requirements (validated per ISO 11135-7:2014, SAL = 10^-6) |
Pre-conditioning of needles: All requirements of the standard related to preconditioning of needles were met. | Meets requirements |
Biocompatibility (ISO 10993-1): Cytotoxicity, Sensitization, Irritation/Intracutaneous Reactivity, Acute Systemic Toxicity, Subacute/subchronic Toxicity, Material-Mediated Pyrogenicity, Hemocompatibility. | Did not show any adverse biological / biocompatibility reactions. |
Sterilization Residuals: Ethylene Oxide residuals | 0.0268 mg/device (acceptable level) |
Package Integrity: Seal strength, Dye penetration, Bubble leak after environmental conditioning, simulated transportation, and accelerated aging. | All packaging deemed acceptable for protection of product and sterility maintenance. |
Shelf Life: | 5 years (validated using FDA recognized standard for Accelerated Aging) |
2. Sample size used for the test set and the data provenance
The document does not specify the exact sample sizes (N numbers) for each individual non-clinical test (e.g., how many needles were tested for flow rate, or how many units for package integrity). It refers to compliance with ISO standards which typically involve specific sampling plans. The data provenance is internal testing performed by HTL-STREFA S.A. (manufacturer located in Poland). The studies are non-clinical (bench testing, lab validations).
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
Not applicable. This is a non-clinical device clearance based on engineering and material performance standards. There is no "ground truth" established by medical experts for diagnostic or clinical performance. Compliance with standards like ISO 11608-2:2012 is generally assessed by qualified technicians and engineers.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable. This is not a clinical study involving human reader interpretation. Test results are objective measurements against defined standards.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
Not applicable. This is a medical device (pen needle) and the submission is for non-clinical performance and substantial equivalence, not an AI-powered diagnostic or assistive technology.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. This is not an algorithm or AI device.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
For non-clinical performance, the "ground truth" is adherence to established international standards and specifications (e.g., ISO 11608-2:2012 for needle performance, ISO 10993-1 for biocompatibility, ISO 11135-7:2014 for sterilization). These standards define acceptable limits and methodologies.
8. The sample size for the training set
Not applicable. There is no "training set" as this is not a machine learning model.
9. How the ground truth for the training set was established
Not applicable. There is no "training set" as this is not a machine learning model.
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(264 days)
HTL-STREFA S.A.
Droplet® Pen Needles are intended for use with pen injector devices for the subcutaneous injection of drugs.
The Droplet® Pen Needles are sterile, single use needles intended for use with pen injector devices for the subcutaneous injection of drugs. Pen needles are used by consumers, caregivers and healthcare professionals.
The pen needle assembly consists of a double-ended cannula that is assembled into an injection molded hub using adhesive. The hub has internal threads, which allow it to be screwed onto the pen injector device. This allows the cartridge end of the cannula to penetrate through the rubber septum of the cartridge. The patient end and the cartridge end of the cannula are lubricated using a silicone based lubricant for ease of injection and rubber septum penetration.
There is an inner needle shield assembled over the patient end of the cannula to protect the needle point from damage and accidental needle sticks. There is also an outer cover. Each pen needle assembly is protected with a peel away seal to provide a sterility barrier.
This is a 510(k) summary for a medical device (pen needles), not an AI/ML device. Therefore, the requested information about acceptance criteria, study sizes, expert involvement, and ground truth establishment is not applicable in the context of AI/ML device evaluation.
The document describes non-clinical performance data for the pen needles as part of the substantial equivalence determination process for a Class II medical device.
Here's a breakdown of the relevant sections from the document that align with your request (non AI/ML related):
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Table of Acceptance Criteria and Reported Device Performance: This information is available in the "Non-Clinical Performance Data" section on pages 7-9. It outlines the requirements from ISO 11608-2:2012 for various test parameters and states that the device met these requirements.
Test Parameter Requirement - ISO 11608-2:2012 Reported Device Performance Materials The needle shall be made of tubing materials specified in ISO 9626. Requirement met Dimensions The needles shall fit the test apparatus specified in item 7.3 of ISO 11608-2. Requirement met Determination of flow rate through the needle (not required by the standard) The needle was tested in accordance with Annex A to ISO 11608-2 to determine flow rate through the needle. Requirement met Bond between hub and needle tube The union of the hub and needle tube shall not break when tested in accordance with Clause 9 of ISO 11608-2. Requirement met Freedom from defects The needle tube shall fulfill the requirements of ISO 7864, clause11.3. Requirement met Lubrication The needle tube should be lubricated at both the patient end and the cartridge end. The lubricant shall not, under normal or corrected-to-normal vision, be visible as droplets of fluid on the outside surface of the needle tube. Requirement met Dislocation of measuring point at patient end Dislocation of the cannula point at the patient end shall be in accordance with Table 2 when tested in accordance with Clause 8 (of ISO 11608-2). Requirement met Determination of functional compatibility with needle-based injection systems Compatibility with any NIS (Needle-based Injection System) shall be claimed only after testing in accordance with Clause 11. Requirement met Ease of assembly and disassembly Attachment of the needle shall be possible without removing the needle from its opened unit packaging. Compliance is checked according to the requirements of Clause 11. Requirement met Pre-conditioning of needles All requirements of the standard related to preconditioning of needles were met. Requirement met Biocompatibility Test Summary:
Test method Compliance with Result Cytotoxicity Study Using the ISO Elution Method ISO 10993-5 - Biological evaluation of medical devices - Part 5: Tests for in vitro cytotoxicity The test article showed no evidence of causing cell lysis or toxicity. ISO Guinea Pig Maximization Sensitization Test ISO 10993-10 - Biological evaluation of medical devices -- Part 10: Tests for irritation and skin sensitization The test article extracts showed no evidence of causing delayed dermal contact sensitization in the guinea pig. The test article was not considered a sensitizer in the guinea pig maximization test. ISO Intracutaneous Study in Rabbits ISO 10993-10 - Biological evaluation of medical devices -- Part 10: Tests for irritation and skin sensitization The test article met the requirements of the test. ASTM Hemolysis Study ASTM F756, Standard Practice for Assessment of Hemolytic Properties of Materials and ISO 10993-4 - Biological evaluation of medical devices -- Part 4: Selection of tests for interactions with blood Both the test article in direct contact with blood and the test article extract were non-hemolytic. ISO Two Week Toxicity Study in the Rat, Repeated Parenteral Administration of Two Extracts ISO 10993-11 - Biological evaluation of medical devices -- Part 11: Tests for systemic toxicity There were no microscopic changes considered to be a test article related response. Parenteral administration of the test article extract did not produce systemic toxicity in rats. ISO Systemic Toxicity Study in Mice ISO 10993-11 - Biological evaluation of medical devices -- Part 11: Tests for systemic toxicity There was no mortality or evidence of systemic toxicity from the extracts injected into mice. Each test article met the requirements of the study. USP Rabbit Pyrogen Study, Material-mediated ISO 10993-11 Biological evaluation of medical devices -- Part 11: Tests for systemic toxicity The total rise of rabbit temperatures during the 3 hour observation period was within acceptable USP limits. The test article was judged as non-pyrogenic. USP Pyrogen Study - Material Mediated USP, General Chapter , Pyrogen Test as recommended by ISO 10993-11 Biological evaluation of medical devices -- Part 11: Tests for systemic toxicity The test article was judged as nonpyrogenic. -
Sample size used for the test set and the data provenance: This information is not specified in the document beyond the tests being performed in accordance with the listed ISO standards. The document doesn't provide details on the number of pen needles used for each specific test or the country of origin of the testing data. It only states the device "successfully passed all the required non-clinical testing." The nature of these tests (mechanical and biological safety testing) often does not involve human subjects, thus "retrospective or prospective" is not applicable in the typical sense.
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Number of experts used to establish the ground truth for the test set and the qualifications of those experts: This is not applicable to the non-clinical performance and biocompatibility testing described for a physical medical device like a pen needle. The "ground truth" for these tests is defined by the objective performance criteria outlined in the ISO and ASTM standards.
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Adjudication method for the test set: Not applicable. The tests involve objective measurements against established technical standards.
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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 document is not about AI/ML or diagnostic imaging that involves human readers.
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If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: Not applicable. This is not an algorithm.
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The type of ground truth used: For the non-clinical performance data, the ground truth is the objective technical specifications and safety requirements defined by international standards (ISO 11608-2:2012, ISO 9626, ISO 7864) and biocompatibility standards (ISO 10993 parts 5, 10, 11; ASTM F756; USP General Chapter ).
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The sample size for the training set: Not applicable, as this is not an AI/ML device that undergoes training.
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How the ground truth for the training set was established: Not applicable.
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(253 days)
HTL-Strefa S.A.
The DropSafe Safety Pen Needles are sterile, single-use safety needles intended for use with pen injector devices for the injection of drugs.
DropSafe Safety Pen Needles are sterile, single-use safety needles intended for use with pen injector devices for the injection of drugs. DropSafe Safety Pen Needles are OTC devices intended to be used by clinical and non-clinical users. DropSafe Safety Pen Needles are offered in one gage - 31 G and in two lengths: 6mm and 8 mm. DropSafe Safety Pen Needles are gamma sterilized, non-toxic single use devices.
The device is designed to minimize the risk from accidental needle sticks with a used needle by application of a sharps injury prevention feature. Following use, the needle is locked out preventing reuse. The shield also serves to hide the needle before and after injection.
Each DropSafe safety pen needle is individually packaged in a sealed container. The DropSafe safety pen needle is used by removing the seal and attaching it to the pen injector device to administer a drug subcutaneously. While inserting the needle into the skin at a 90° angle, the slides into the shield. While the slider glides into the shield, the safety feature is activated. Following injection, the slider glides back into its initial position, completely covering the needle where it remains locked.
The red safety lock indicator tells the user that the safety lock has been activated. Once the safety pen needle is in the locked mode, it cannot be reused. The safety pen needle is detached from the pen injector device and disposed of into a sharps container.
The pen needle assembly consists of a double-ended cannula that is assembled into an injection molded hub using an adhesive. The hub has internal threads which allows it to be screwed onto the pen injector device. This allows the cartridge end of the needle to penetrate through the rubber septum of the cartridge. The patient-end and the cartridge end of the cannula are lubricated using a silicone-based lubricant for ease of injection and rubber septum penetration. An injection molded inner shield is assembled over the patient end of the cannula to prevent needle point damage and accidental needle-sticks. This needle assembly is inserted into a protective injection molded container and sealed with a peel away medical grade paper tab which provides a sterility barrier and tamper evident seal.
The provided text describes a 510(k) premarket notification for a medical device called "DropSafe Safety Pen Needles." This type of submission focuses on demonstrating substantial equivalence to a legally marketed predicate device, rather than proving novel safety and effectiveness through extensive clinical trials. Therefore, the information provided primarily addresses design verification and validation testing of the device's physical properties and safety features, and not a study proving the device meets high-level acceptance criteria through, for instance, a multi-reader multi-case clinical study or algorithm-only performance.
Based on the provided text, here's a breakdown of the requested information, highlighting what is present and what is not applicable or not detailed for this type of submission:
1. A table of acceptance criteria and the reported device performance:
The document lists "Non-Clinical Performance Data" and "Clinical Performance Data" which serve as acceptance criteria based on established standards and guidance.
Test parameter | Requirement – ISO 11608-2:2012 / FDA Guidance | Reported Device Performance (Result) |
---|---|---|
Non-Clinical Performance Data (ISO 11608-2:2012) | ||
Materials | The needle shall be made of tubing materials specified in ISO 9626. | Meets standard |
Dimensions | The needles shall fit the test apparatus specified in clause 7.3 of ISO 11608-2. | Meets standard |
Determination of flow rate through the needle | The needle was tested in accordance with Annex A to ISO 11608-2 to determine flow rate through the needle. | Meets standard |
Bond between hub and needle tube | The union of the hub and needle tube shall not break when tested in accordance with Clause 9 of ISO 11608-2. | Meets standard |
Freedom from defects | The needle tube shall fulfill the requirements of ISO 7864, clause 11.3. | Meets standard |
Lubrication | The needle tube should be lubricated at both the patient end and the cartridge end. The lubricant shall not, under normal or corrected-to-normal vision, be visible as droplets of fluid on the outside surface of the needle tube. | Meets standard |
Dislocation of measuring point at patient end | Dislocation of the cannula point at the patient end shall be in accordance with Table 2 [not included in excerpt] when tested in accordance with Clause 8 (of ISO 11608-2). | Meets standard |
Determination of functional compatibility with needle-based injection systems | Compatibility with any NIS shall be claimed only after testing in accordance with Clause 11. | Meets standard |
Ease of assembly and disassembly | Attachment of the needle shall be possible without removing the needle from its opened unit packaging. Compliance is checked according to the requirements of clause 11. | Meets standard |
Pre-conditioning of needles | All requirements of the standard related to preconditioning of needles were met. | Meets standard |
Clinical Performance Data (FDA GUIDANCE Medical Devices with Sharps Injury Prevention Features, August 9, 2005) | ||
Function of safety feature in simulated clinical environment | Evaluate the function of the safety feature with participation of both clinical and non-clinical users. | "As evidenced in the study, the use of this device does not affect the injection technique or the functionality of the pen injector and is safe and effective when used as per the Instructions for Use." |
Validation of Instructions For Use (IFU) | Validate IFU with participation of clinical and non-clinical users. | "As evidenced in the study, the use of this device does not affect the injection technique or the functionality of the pen injector and is safe and effective when used as per the Instructions for Use." |
2. Sample size used for the test set and the data provenance:
- Test Set Sample Size: The document does not specify the numerical sample sizes for the non-clinical performance tests (e.g., number of needles tested for flow rate, bond strength, etc.) nor for the "Simulated Use Study" involving clinical and non-clinical users. It merely states that "Testing was performed" and "All testing met the applicable requirements."
- Data Provenance: The tests are described as being conducted in compliance with ISO standards and FDA guidance. The manufacturer, HTL-Strefa S.A., is located in Poland. The text doesn't explicitly state the location of the testing, but it can be inferred to have been conducted by or for the manufacturer. The studies described are likely prospective tests performed specifically for this 510(k) submission.
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 and not provided. For this type of device (a hypodermic needle), "ground truth" is established through engineering and performance testing against objective standards (ISO 11608-2:2012) and simulated user studies. Expert consensus or ground truth derived from a panel of medical specialists (like radiologists) is not relevant for this device's validation. The "Simulated Use Study" involved "clinical and non-clinical users," but their number or specific qualifications (beyond being "clinical users") are not detailed.
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set:
Not applicable. Adjudication methods are typically used in studies where human readers are interpreting images or data, and their disagreements need to be resolved to establish ground truth. For the physical and functional tests of a pen needle, objective measurements against established standards are the norm, not 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:
Not applicable. This device is a mechanical medical device (a safety pen needle), not an AI-powered diagnostic tool. Therefore, an MRMC comparative effectiveness study involving human readers and AI assistance is not relevant or performed for this product.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
Not applicable. This device is not an algorithm or AI system. Its performance is inherent to its physical design, manufacturing, and user interaction.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
The "ground truth" for this device's performance is established by:
- Compliance with international standards (ISO 11608-2:2012) for physical and functional properties (e.g., materials, dimensions, flow rate, bond strength, lubrication, compatibility).
- Compliance with FDA guidance for sharps injury prevention features, validated through a "Simulated Use Study" to confirm the safety feature's function and IFU effectiveness with users.
- The primary ground truth is the ability of the device to meet specified engineering and performance requirements for safe and effective use, rather than a clinical diagnosis.
8. The sample size for the training set:
Not applicable. This is a mechanical device, not an AI model requiring a training set.
9. How the ground truth for the training set was established:
Not applicable, as there is no training set for a mechanical device.
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(206 days)
HTL-STREFA S.A.
The Droplet® Pen Needles are intended for use with pen injector device for the subcutaneous injection of insulin.
The Droplet® Pen Needles are sterile, single use needles designed to be used with commercially available pen-injectors for the subcutaneous injection of insulin. Pen needles are used by consumers, caregivers and healthcare professionals. The pen needle assembly consists of a double-ended cannula that is assembled into an injection molded hub using adhesive. The hub has internal threads, which allow it to be screwed onto the pen injector device. This allows the cartridge end of the cannula to penetrate through the rubber septum of the cartridge. The patient end and the cartridge end of the cannula are lubricated using a silicone based lubricant for ease of injection and rubber septum penetration. There is an inner needle shield assembled over the patient end of the cannula to protect the needle point from damage and accidental needle sticks. There is also an outer protective container. Each pen needle assembly is protected with a peel away seal to provide a sterility barrier. To use a pen needle, the user needs to remove the seal, remove the outer protective cap and attach it to the pen injector. Then the user removes the inner protective cap to expose the needle and make an injection. Following the injection the user inserts the used pen needle into the outer cap to remove the pen needle from the pen injector and dispose of it immediately. The pen needle is individually packaged and sterilized with Gamma radiation. It is intended for single use only. Droplet® Pen Needles are available in the following lengths and gauges: 4 mm x 32G, 5 mm x 32G, 6 mm x 32G, 8 mm x 32G, 5 mm x 31G, 6 mm x 31G, 8 mm x 31G, 10 mm x 29G, 12 mm x 29G.
Here's a breakdown of the acceptance criteria and study information for the Droplet® Pen Needles, extracted from the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
Test Parameter | Acceptance Criteria (from ISO 11608-2:2012) | Reported Device Performance |
---|---|---|
Materials | The needle shall be made of tubing materials specified in ISO 9626. | Meets standard |
Dimensions | The needles shall fit the test apparatus specified in item 7.3 of ISO 11608-2. | Meets standard |
Determination of flow rate through the needle | The needle was tested in accordance with Annex A to ISO 11608-2 to determine flow rate through the needle. | Meets standard |
Bond between hub and needle tube | The union of the hub and needle tube shall not break when tested in accordance with Clause 9 of ISO 11608-2. | Meets standard |
Freedom from defects | The needle tube shall fulfill the requirements of ISO 7864, 11.3. | Meets standard |
Lubrication | The needle tube should be lubricated at both the patient end and the cartridge end. The lubricant shall not, under normal or corrected-to-normal vision, be visible as droplets of fluid on the outside surface of the needle tube. | Meets standard |
Dislocation of measuring point at patient end | Dislocation of the cannula point at the patient end shall be in accordance with Table 2 (not provided in this document) below when tested as per Clause 8 (of ISO 11608-2). | Meets standard |
Determination of functional compatibility with needle-based injection systems | Compatibility with any NIS shall be claimed only after testing in accordance with Clause 11. | Meets standard |
Ease of assembly and disassembly | Attachment of the needle shall be possible without removing the needle from its opened unit packaging. Compliance is checked according to the requirements of Clause 11. | Meets standard |
Pre-conditioning of needles | All requirements of the standard related to preconditioning of needles were met. | Meets standard |
Biocompatibility - Cytotoxicity | Based on ISO 10993-1 requirements. | Passed |
Biocompatibility - Sensitization | Based on ISO 10993-1 requirements. | Passed |
Biocompatibility - Intracutaneous Reactivity | Based on ISO 10993-1 requirements. | Passed |
Biocompatibility - Haemocompatibility | Based on ISO 10993-1 requirements. | Passed |
Biocompatibility - System toxicity (acute) | Based on ISO 10993-1 requirements. | Passed |
Biocompatibility - Subchronic toxicity (subacute toxicity) | Based on ISO 10993-1 requirements. | Passed |
Sterility (Gamma Radiation) | To ensure sterility of the device over its shelf life, relevant sterility testing is conducted. (Validated in accordance with ISO 11137-1 to achieve SAL 10-6) | Passed all relevant sterility tests successfully. |
2. Sample Size Used for the Test Set and Data Provenance
The document does not explicitly state the numerical sample sizes used for each specific test in the "Non-Clinical Performance Data" section. It broadly states that "Verification/Validation testing was done according to the requirements of ISO 11608-2:2012 as summarized below. All testing met the applicable requirements." Similarly, for biocompatibility, it states "The selection of biocompatibility tests was made based on the requirements of ISO 10993-1. All the tests have been successfully passed." The sterility testing states "Droplet® Pen Needles have passed all relevant sterility tests successfully."
The data provenance is for a manufacturing company located in Poland (HTL-Strefa S.A.). The data would be considered prospective as it's generated for the purpose of a 510(k) submission, meaning the tests were conducted specifically for this device to demonstrate its performance.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
This information is not provided in the document. The tests performed are primarily engineering and laboratory-based, adhering to international standards (ISO), rather than relying on human expert assessment for "ground truth" in the way clinical studies or image interpretations might.
4. Adjudication Method for the Test Set
This information is not applicable/not provided. The testing described is objective, standards-based, and performed in a laboratory/technical setting, rather than through expert human 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
There was no MRMC comparative effectiveness study done. This document describes a medical device (pen needles) that does not involve AI or human readers in an interpretive capacity.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done
There was no standalone (algorithm only) performance study done. This device is a physical medical instrument, not a software algorithm.
7. The Type of Ground Truth Used
The ground truth used for the performance data in this submission is based on established international standards and objective measurement criteria. For example:
- Physical and mechanical properties are compared against the specifications in ISO 11608-2:2012 (e.g., materials per ISO 9626, bond strength per Clause 9, freedom from defects per ISO 7864).
- Biocompatibility is evaluated against the requirements of ISO 10993-1.
- Sterility is validated according to ISO 11137-1.
8. The Sample Size for the Training Set
This information is not applicable/not provided. This device is a physical medical product, not an AI/machine learning model that requires a training set.
9. How the Ground Truth for the Training Set Was Established
This information is not applicable/not provided, as there is no training set for this type of device.
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