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510(k) Data Aggregation

    K Number
    K243936
    Manufacturer
    Date Cleared
    2025-04-03

    (104 days)

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

    StaClear, INC.

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

    The StaClear Syringe is intended to inject fluids into, or withdraw fluids from, the body. The StaClear Syringe is indicated for intravitreal use.

    Device Description

    The StaClear Syringe is a single-use piston syringe intended for use by healthcare professionals for general-purpose fluid aspiration/injection. Its operation is manual. The StaClear Syringe is single use only, non-toxic, non-pyrogenic, and sterilized by ethylene oxide gas. It uses standard syringe components with a low-particulate gas plasma crosslinked silicone coating called TriboLink-Si. The StaClear Syringe is suitable for ophthalmic use.

    The StaClear Syringe is offered in the following configurations:

    • SC250AN – Consisting of a 0.25 mL graduated barrel, plunger, plunger stopper, needle, needle shield, and plunger cap.
    • SC250LS – Consisting of a 0.25 mL graduated barrel with an ISO 80369-7-compliant luer-slip connector, plunger, and plunger stopper.
    • SC250LL – Consisting of a 0.25 mL graduated barrel with an ISO 80369-7-compliant luer-lock connector, plunger, and plunger stopper.
    AI/ML Overview

    The provided document is an FDA 510(k) clearance letter for the StaClear Syringe, which is a medical device, not an AI/ML algorithm. Therefore, many of the requested fields, such as "number of experts used to establish the ground truth," "adjudication method," "MRMC comparative effectiveness study," "standalone algorithm performance," "type of ground truth," and information about training sets, are not applicable to this type of device and therefore not present in the document.

    The document primarily focuses on demonstrating substantial equivalence to a predicate device through adherence to established performance standards for syringes.

    Here's the information that can be extracted from the provided text regarding acceptance criteria and performance:

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

    The document lists various ISO and USP standards as the basis for performance evaluation. The "Acceptance Criteria" are implied to be compliance with these standards, and the "Reported Device Performance" is stated as "Identical" or "Compliant" with these standards.

    Attribute/TestAcceptance Criteria (Implied)Reported Device Performance
    Syringe Performance (ISO 7886-1)Compliance with ISO 7886-1:2017Identical to predicate; Device maintains performance per ISO 7886-1 after 5-years of aging.
    - CleanlinessPassIdentical
    - Acidity and AlkalinityPassIdentical
    - Extractable MetalsIOL limits per ISO 11979-5Identical
    - LubricantPassIdentical
    - Tolerance on GraduationsPassIdentical
    - Stopper DetachmentPassIdentical
    - Dead SpacePassIdentical
    - Air and Liquid Leakage Past StopperPassIdentical
    - Plunger ForcePassIdentical
    - Fit of StopperPassIdentical
    Needle Performance (SC250AN only) (ISO 7864 & ISO 9626)Compliance with ISO 7864:2016 & ISO 9626:2016Identical to predicate; Device maintains performance per ISO 7864, ISO 9626 after 5-years of aging.
    - CleanlinessPassIdentical
    - Acidity and AlkalinityPassIdentical
    - Extractable MetalsIOL limits per ISO 11979-5Identical
    - Tolerance on LengthPassIdentical
    - Tube DefectsPassIdentical
    - LubricantPassIdentical
    - Point DefectsPassIdentical
    - Needle Penetration ForcePassIdentical
    - Bond Between Tube and HubPassIdentical
    - Patency of LumenPassIdentical
    - MaterialsPassIdentical
    - Surface FinishPassIdentical
    - Size DesignationPassIdentical
    - Outside DiameterPassIdentical
    - StiffnessPassIdentical
    - Resistance to BreakagePassIdentical
    - Resistance to CorrosionPassIdentical
    Luer Connector Performance (SC250LS and SC250LL only) (ISO 80369-7)Compliance with ISO 80369-7:2021Compliant with established performance standards; Device maintains performance per ISO 80369-7 after 5-years of aging.
    - MaterialsPassCompliant
    - Dimensional RequirementsPassCompliant
    - Fluid LeakagePassCompliant
    - Air LeakagePassCompliant
    - Stress CrackingPassCompliant
    - Separation ForcePassCompliant
    Luer-Lock only (ISO 80369-7)Compliance with ISO 80369-7:2021Compliant with established performance standards.
    - Unscrewing TorquePassCompliant
    - Resistance to OverridingPassCompliant
    Particulate TestingCompliance with USP & USPIdentical to predicate; Device performs as intended.
    - Particulate Matter in Injections (USP )PassIdentical
    - Particulate Matter in Ophthalmic Solutions (USP )PassIdentical
    BiocompatibilityCompliance with ISO 10993-1 for external communicating device with prolonged tissue contactBiocompatible for intended use.
    SterilitySterilized to SAL 10⁻⁶; Endotoxin per USP with IOL limits; Sterility per USPSterilized to SAL 10⁻⁶; Endotoxin levels meet IOL limits; Device maintains sterility per USP after 5-years of aging.
    Shelf LifeMaintain performance and sterility for 5 yearsTesting demonstrates performance and sterility maintained over 5 years after accelerated aging.
    PackagingCompliance with ISO 11607-1:2019 for sterile barrierCompliant with established requirements per ISO 11607-1:2019. (For Tyvek Pouch packaging)
    - Sterile Barrier IntegrityPass (e.g., using bacterial aerosol followed by sterility tests per USP )Maintained.

    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 the sample sizes used for testing each attribute. The data provenance (country of origin, retrospective/prospective) is also not provided. The testing is described as "non-clinical testing" and "performance testing performed as per the design control system," suggesting in-house, prospective 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)

    Not applicable. This is a physical medical device, not an AI/ML algorithm requiring expert ground truth for image interpretation or diagnosis. The "ground truth" for the device's performance is objective measurements against established engineering and biocompatibility standards.

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

    Not applicable. This is a physical medical device, not an AI/ML algorithm requiring adjudication of interpretations.

    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 physical medical device and does not involve AI assistance for human readers.

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

    Not applicable. This is a physical medical device, not an algorithm. The "standalone" performance refers to the device's adherence to specified standards in direct testing.

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

    The "ground truth" for this device's performance is adherence to recognized international and national standards for medical devices, specifically:

    • ISO standards (e.g., ISO 7886-1, ISO 7864, ISO 9626, ISO 80369-7, ISO 10993-1, ISO 11607-1) which define performance characteristics, materials, and testing methodologies.
    • USP standards (e.g., USP , USP , USP , USP ) which define testing for particulate matter, sterility, and endotoxins.
    • ASTM standards (e.g., ASTM D4169, ASTM F1980) for packaging and accelerated aging.

    These standards provide objective, measurable criteria.

    8. The sample size for the training set

    Not applicable. This is a physical medical device and does not involve a training set as would an AI/ML algorithm.

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

    Not applicable. This is a physical medical device and does not involve a training set.

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