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510(k) Data Aggregation

    K Number
    K223678
    Date Cleared
    2023-02-09

    (63 days)

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

    Sterile Syringes for Single Use are sterile, single-use, disposal, without needle and manually operated syringes intended to use with a 6% conical fitting device for injection of drug into the body. The syringes are intended for use immediately after filling and are not intended to contain the fluid/medication for extended periods of time.

    Device Description

    KDL Sterile Syringes for Single Use are composed of barrel, plunger, and a moveable piston. The plunger does not contact any part of the fluid path, rather the plunger which attaches to the piston and the barrel are fluid path components. Materials of construction for the components have been shown to meet the applicable requirements of ISO 10993-1. Additionally, there is a small amount of lubricant for moving the plunger smoothly along the inside surface of the barrel. The connector is a universal luer threaded style connector. The device is used in general medicine in clinical, hospital, or other settings of healthcare professionals. The Sterile Syringes for Single Use have different specifications, include 1ml, 3ml, 10ml, 20ml and 30ml.

    AI/ML Overview

    The provided text is a 510(k) summary for the "Sterile Syringes for Single Use". This document describes the device, its intended use, and the studies conducted to demonstrate its substantial equivalence to a predicate device.

    Here's an analysis of the acceptance criteria and the studies that prove the device meets them, based on the provided text:

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

    The document does not explicitly present a table of acceptance criteria with corresponding performance metrics in a pass/fail format. Instead, it describes compliance with recognized international standards (ISO and ASTM) and specific tests conducted. The "Performance" column in the table below represents the device's conformance to these standards and the completion of the described tests.

    Acceptance Criteria (as implied by standards and tests conducted)Reported Device Performance (Conformance/Results)
    Conformance to ISO 7886-1:2017 (Sterile hypodermic syringes for manual use)Confirmed conformance to ISO 7886-1:2017
    Conformance to ISO 80369-7:2016 (Small-bore connectors for intravascular/hypodermic applications)Confirmed conformance to ISO 80369-7:2016
    Biocompatibility (ISO 10993-1 and FDA Guidance)Conformance demonstrated for:
        - CytotoxicityTested and conformed
        - SensitizationTested and conformed
        - IrritationTested and conformed
        - Acute Systemic ToxicityTested and conformed
        - Material-Mediated PyrogenicityTested and conformed
        - HemolysisTested and conformed
    Particulate Testing (USP <788>)Tested and conformed
    Sterilization (ISO 11135)Evaluated for sterility using ISO 11135
    Packaging Integrity (ASTM F88/F88M-15 & ASTM F1929-15)Tested using ASTM F88/F88M-15 and ASTM F1929-15 (Seal Strength, Dye Penetration)
    Simulated Shipping (ISTA 3A:2018)Tested using ISTA 3A:2018
    Shelf-life (5 years)Validated using ASTM F1980-16 for 5 years

    2. Sample size 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 the sample sizes used for any of the performance tests. It only states that the device was "tested" and "evaluated."

    Regarding data provenance: The testing appears to be conducted by the manufacturer, Shanghai Kindly Enterprise Development Group Co., Ltd. within China, or by a testing facility on their behalf. The studies are prospective as they are conducted specifically to support this regulatory submission for the proposed device (non-clinical 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 section is not applicable to this device and the type of studies conducted. The device is a sterile syringe, and the studies are primarily non-clinical performance and biocompatibility tests against established international standards. "Ground truth" in the context of expert consensus (like in AI/medical imaging studies) is not relevant here. The "ground truth" is defined by the technical specifications and performance requirements of the ISO and ASTM standards.

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

    This section is not applicable. Adjudication methods like 2+1 or 3+1 are typically used in clinical studies involving multiple human readers interpreting results, especially in complex diagnostic scenarios or AI performance evaluation. The studies for this device are non-clinical, laboratory-based performance tests against 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

    This is not applicable. The device is a disposable, manually operated syringe, not an AI-powered diagnostic tool. Therefore, no MRMC study or evaluation of human reader improvement with AI assistance was conducted or warranted.

    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 device (syringe), not an algorithm or software. Therefore, the concept of "standalone algorithm performance" does not apply.

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

    The "ground truth" for the non-clinical tests is based on established international standards and validated testing methodologies described within those standards (e.g., ISO 7886-1, ISO 80369-7, ISO 10993 series, USP <788>, ISO 11135, ASTM F88/F88M-15, ASTM F1929-15, ISTA 3A:2018, ASTM F1980-16). These standards define acceptable performance limits and test procedures.

    8. The sample size for the training set

    This is not applicable. As a physical medical device, there is no "training set" in the context of machine learning or deep learning algorithms.

    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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    K Number
    K220185
    Date Cleared
    2022-07-11

    (168 days)

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

    The Sterile Safety Insulin Syringes For Single Use are a sterile, single-use, disposable and non-reusable, manual retractable safety insulin syringe intended for injection of U40 or U100 insulin into the body, the sliding sleeve helps protect against needle puncture once activated.

    Device Description

    KDL Sterile safety insulin syringes have a sliding sleeve which is designed to shield the injection needle to protect the user from needle puncture and the sliding sleeve helps protect against needle puncture once activated. The sliding sleeve can be activated manually.

    AI/ML Overview

    The provided text is a 510(k) summary for a medical device (Sterile Safety Insulin Syringes for Single Use) and primarily focuses on demonstrating substantial equivalence to a predicate device, rather than presenting a study proving the device meets specific acceptance criteria in the format requested.

    The document outlines conformity to various ISO standards and other regulatory requirements but does not detail a specific study with an acceptance criteria table, sample sizes for test/training sets, expert qualifications, or MRMC study results as one might expect for a diagnostic AI/imaging device. Instead, it describes a series of non-clinical tests to verify design specifications and compliance with recognized standards.

    Therefore, many sections of your request cannot be directly answered from the provided text.

    Here's what can be extracted and inferred:

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

    The document lists several ISO standards that the device "complies with" or "conforms to." These standards inherently contain acceptance criteria, and the statement of compliance/conformance indicates that the device met these criteria. However, specific numerical acceptance criteria and reported device performance values are not explicitly stated in a consolidated table format in this document. Instead, compliance with the standard is the reported performance.

    Acceptance Criteria (Standard Compliance)Reported Device Performance
    ISO 8537:2016 (Sterile single-use syringes, with or without needle, for insulin)Conforms to ISO 8537
    ISO 7864:2016 (Sterile hypodermic needles for single use-Requirements and test method)Conforms to ISO 7864
    ISO 9626:2016 (Stainless steel needle tubing for medical device-Requirements and test method)Conforms to ISO 9626
    ISO 23908:2011 (Sharps Injury Protection-Requirements and test methods)Conforms to ISO 23908
    ISO 10993-1:2018 (Biological evaluation - Part 1: Evaluation and testing)Complies with ISO 10993-1
    ISO 10993-4:2017 (Biological evaluation - Part 4: Interactions with blood)Complies with ISO 10993-4
    ISO 10993-5:2009 (Biological evaluation - Part 5: In vitro cytotoxicity)Complies with ISO 10993-5
    ISO 10993-7:2008 (Biological evaluation - Part 7: Ethylene oxide sterilization residuals)Complies with ISO 10993-7
    ISO 10993-10:2010 (Biological evaluation - Part 10: Irritation and skin sensitization)Complies with ISO 10993-10
    ISO 10993-11:2017 (Biological evaluation - Part 11: Systemic toxicity)Complies with ISO 10993-11
    USP <788> (Particulate Matter for injection)Conforms to USP <788>
    Labeling requirements of 21 CFR Part 801Meets the requirements of 21 CFR Part 801

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

    The document states "Non-clinical tests were conducted to verify that the proposed device met all design specifications." However, specific sample sizes for these tests are not provided. The data provenance (e.g., country of origin, retrospective/prospective) is also not specified.

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

    This type of information is generally relevant for studies involving human interpretation or subjective assessment, particularly in AI or imaging diagnostics. For a non-clinical device like a syringe, "ground truth" is established through physical and chemical testing against defined standards. Therefore, this information is not applicable and not provided in the document.

    4. Adjudication method for the test set

    Similarly, adjudication methods (e.g., 2+1, 3+1) are common in studies where multiple human readers interpret data that is then arbitrated. This is not applicable to the non-clinical testing of a syringe and therefore not provided.

    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 study is relevant for evaluating the impact of AI assistance on human performance, typically in diagnostic tasks. This document describes a physical medical device (syringe) and its non-clinical testing. Therefore, an MRMC comparative effectiveness study is not applicable and not performed/reported.

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

    This question is also related to AI algorithm performance. As this document concerns a physical syringe, a standalone algorithm performance study is not applicable and not performed/reported. The non-clinical tests served as the "standalone" evaluation of the device's physical properties.

    7. The type of ground truth used

    For this device, the "ground truth" used for testing would be the specifications and requirements defined by the various ISO standards and USP <788>. This includes physical dimensions, material properties, sterility, particulate matter limits, and biocompatibility criteria.

    8. The sample size for the training set

    This question is relevant for AI/machine learning models. For the non-clinical testing of a physical medical device, there is no "training set" in the AI sense. This information is not applicable and not provided.

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

    Again, this is relevant for AI/machine learning. For this device's non-clinical testing, there is no training set. The "ground truth" for evaluating the device's conformance to standards is established by the scientific and regulatory consensus embodied in the ISO standards and USP monographs themselves. This information is not applicable and not provided.

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