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510(k) Data Aggregation

    K Number
    K142435
    Date Cleared
    2015-02-20

    (175 days)

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

    The 3S Safety Syringe with/without Needle is a sterile, single-use, disposable and non-reusable, manual retractable safety syringe intended for injection of fluids into the body, while reducing the risk of sharps injuries and the potential for syringe reuse.

    Device Description

    The 3S Safety Syringe with/without Needle is an integrated needle and piston syringe with an innovative anti-needle-stick mechanism. The design incorporates the ideal features desired in a safety syringe. No special techniques are required to use the safety mechanism. The mechanism allows clear visualization of the injection site at all times. The mechanism clearly shows the needle is contained within the syringe barrel. After standard techniques for injection, the plunger is withdrawn, snapped off and used syringe is discarded into a sharps container per regulatory provision.

    AI/ML Overview

    This document is primarily a 510(k) summary for a medical device (3S Safety Syringe). It focuses on establishing substantial equivalence to a predicate device rather than detailing extensive clinical study results as one might find in a PMA or a more comprehensive clinical trial report.

    Therefore, many of your requested items, particularly those related to AI algorithm performance, sample sizes for test/training sets in an AI context, expert ground truth establishment for AI, MRMC studies, and standalone AI performance, are not applicable to this document as it describes a physical safety syringe, not an AI/software device.

    However, I can extract the acceptance criteria and performance related to the physical device.


    1. Table of Acceptance Criteria and Reported Device Performance

    For the 3S Safety Syringe, the acceptance criteria are generally based on conformity to international standards and regulations. The "reported device performance" is essentially a statement of this conformity.

    Acceptance Criteria (Standard/Requirement)Reported Device Performance (Conformity)
    ISO 7864 (Sterile hypodermic needles)Conforms to ISO 7864
    ISO 7886 (Sterile hypodermic syringes)Conforms to ISO 7886
    ISO 10993 (Biological evaluation of medical devices)Conforms to ISO 10993
    21 CFR Part 801 (Labeling requirements)Meets the requirements of 21 CFR Part 801
    Sharps Injury Prevention FeaturesManual Retractable (similar to predicate)
    Intended UseIntended for injection, reducing sharps injuries, and preventing reuse (similar to predicate)
    Material CompatibilityMaterials (PP, Silicone, Stainless Steel) are consistent with predicate and suitable for medical use.

    Note: This table reflects the information present in the provided document, which is a 510(k) summary. It asserts equivalence to established standards rather than providing raw performance data or a detailed study report.


    Information Not Applicable or Not Provided in the Document:

    The following information is not contained within the provided 510(k) summary, as it pertains to AI/software device studies or detailed clinical trial breakdowns not typically required for a Class II physical medical device 510(k) submission focused on substantial equivalence.

    1. Sample size used for the test set and the data provenance: Not applicable for this type of physical device submission. Performance is assessed against engineering standards, not a data test set in the AI sense.
    2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable. Ground truth for a physical syringe's performance is established by engineering testing against standards (e.g., fluid leakage, plunger force, sterility, biocompatibility), not by expert consensus on data interpretation.
    3. Adjudication method for the test set: Not applicable.
    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: Not applicable, as this is not an AI device.
    5. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: Not applicable.
    6. The type of ground truth used: For a physical device like a syringe, "ground truth" refers to the objective physical and chemical properties and performance characteristics measured against established international standards (ISO, biological safety) and regulatory requirements (CFR). It's not an "expert consensus" or "pathology" in the diagnostic sense.
    7. The sample size for the training set: Not applicable, as there is no AI training set.
    8. How the ground truth for the training set was established: Not applicable.
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    K Number
    K142436
    Date Cleared
    2015-02-19

    (174 days)

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

    The 3S Safety Insulin Syringe a sterile, single-use, disposable and non-reusable, manual retractable safety insulin syringe intended for injection of insulin into the body, while reducing the risk of sharps injuries and the potential for insulin syringe reuse.

    Device Description

    The 3S Safety Insulin Syringe is an integrated needle and piston syringe with an innovative antineedle-stick mechanism. The design incorporates the ideal features desired in a safety syringe. No special techniques are required to use the safety mechanism. The mechanism allows clear visualization of the injection site at all times. The mechanism clearly shows the needle is contained within the syringe barrel. After standard techniques for injection, the plunger is withdrawn, snapped off and used syringe is discarded into a sharps container per regulatory provision.

    The 3S safety syringe with/without Needle will be available in numerous sizes and combinations between the smallest (0.3cc/ml + 31G) and the largest (1cc/ml + 27G )

    AI/ML Overview

    The provided text describes a 510(k) premarket notification for the "3S Safety Insulin Syringe." The document focuses on demonstrating substantial equivalence to a predicate device, rather than presenting a detailed study with acceptance criteria and performance data for a novel device or AI algorithm.

    Therefore, the requested information regarding "acceptance criteria and the study that proves the device meets the acceptance criteria" cannot be fully provided in the format requested. The document does not describe a performance study with specific acceptance criteria, sample sizes, expert ground truth, adjudication methods, or AI comparative effectiveness.

    However, I can extract the information related to the device's characteristics and the basis for its substantial equivalence, as presented in the document.

    Here's a breakdown of what can be inferred or directly stated from the provided text, and what cannot:

    1. Table of Acceptance Criteria and Reported Device Performance:

    The document doesn't provide a table of acceptance criteria for a performance study. Instead, it presents a Safety Syringe Comparison Table showing the characteristics of the submitted device against a predicate device to demonstrate substantial equivalence. The "performance" aspect is generally referred to as "Conforms to ISO7864 ISO8537" and "Conforms to ISO10993" for biocompatibility. These are general standards, not specific acceptance criteria for a performance study in the context of device function or efficacy.

    Element of ComparisonSubmission Device (3S Safety Insulin Syringe)Predicate Device (InsoSAFE BakSNAP Retractable Insulin Safety Syringe)
    Intended UseA sterile, single-use, disposable and non-reusable, manual retractable safety insulin syringe intended for injection of insulin into the body, while reducing the risk of sharps injuries and the potential for insulin syringe reuse.A sterile, single-use, disposable and non-reusable, manual retractable safety insulin syringe intended for injection of insulin into the body, while reducing the risk of sharps injuries and the potential for insulin syringe reuse.
    Principle of OperationNormalNormal
    Syringe CapacityVarious SizesVarious Sizes
    Nozzle TypeN.AN.A
    Lubricant for BarrelSilicone OilSilicone Oil
    Barrel TransparencyTransparent and ClearTransparent and Clear
    Gradations LegibilityLegibleLegible
    Barrel MaterialPPPP
    Plunger MaterialPPPP
    Piston MaterialTPETPE
    Needle Hub MaterialPPPP
    Needle MaterialStainless SteelStainless Steel
    Needle Sheath MaterialPPPP
    Needle Gauge and LengthVarious SizesVarious Sizes
    Lubricant for NeedleSilicone OilSilicone Oil
    Sharps Injury Prevention MethodManual RetractableManual Retractable
    Performances StatusConforms to ISO7864 ISO8537Conforms to ISO7864 ISO8537
    Biocompatibility StatusConforms to ISO10993Conforms to ISO10993
    Labeling StatusMeet the requirements of 21 CFR Part 801Meet the requirements of 21 CFR Part 801

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

    • Sample Size: Not specified in the document.
    • Data Provenance: Not specified in the document. The document refers to a comparison to a predicate device and conformance to ISO standards, but no details of original test data are provided.

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

    • Not applicable/Not specified. This document pertains to a medical device (syringe), not an AI/imaging diagnostic device requiring expert interpretation for ground truth.

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

    • Not applicable/Not specified.

    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 not an AI/imaging diagnostic device.

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

    • Not applicable. This is not an AI/algorithm.

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

    • Not applicable/Not specified. The assessment relies on conformity to established international standards (ISO7864, ISO8537 for performance; ISO10993 for biocompatibility) and comparison of physical/material characteristics with a predicate device.

    8. The sample size for the training set:

    • Not applicable. This is not an AI/algorithm-based device.

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

    • Not applicable.

    Summary of the Study/Basis for Acceptance (as per the document):

    The "study" in this context is a substantial equivalence determination based on a comparison between the 3S Safety Insulin Syringe and a legally marketed predicate device (InsoSAFE BakSNAP Retractable Insulin Safety Syringe, K050131).

    The core of the "proof" is the "Safety Syringe Comparison Table" in Section 6, which argues that the "materials, performance, and operational features of both the submitted device and the predicate device are substantially equivalent."

    The performance aspects are addressed by stating that the device "Conforms to ISO7864 ISO8537" (likely for sterile hypodermic syringes and needles) and "Conforms to ISO10993" (for biological evaluation of medical devices). This implies that standard tests dictated by these ISO norms were conducted and passed, but the specifics of those tests, their acceptance criteria, and specific data are not detailed in this 510(k) summary.

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