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510(k) Data Aggregation
(104 days)
The Disposable Safety Lancets is intended to be used in a hospital or at home to obtain capillary blood samples from the fingertip for tests using small amounts of blood. The device contains a sharp injury protection feature.
The Disposable Safety Lancets consists 7 parts, include a lancet cap, body, slide, lancet, tip cover, spring and bottom. The models of the Disposable Safety Lancets are 18G; 21G; 23G; 26G; 28G; 30G; 32G; 33G. The Disposable Safety Lancets is intended to be used in a hospital or at home to obtain capillary blood samples from the fingertip for tests using small amounts of blood. The device contains a sharp injury protection feature. The lancet is hit by pressure, and once the device strikes, the lancet needle can puncture the skin. Used Gamma sterilization, and are products for single use.
The provided document describes a 510(k) premarket notification for "Disposable Safety Lancets" by Suzhou Kyuan Medical Apparatus Co., Ltd. This document primarily focuses on demonstrating substantial equivalence to a predicate device rather than presenting a clinical study of AI performance. Therefore, many of the requested details related to an AI-driven device's acceptance criteria and study proving its performance (e.g., MRMC studies, training set details, expert ground truth) are not applicable to this submission.
However, the document does contain information about performance testing for the mechanical and biological aspects of the lancet. I will extract the relevant information for the acceptance criteria and performance of the device itself (the lancet), not a hypothetical AI component, as well as indicating where information is not present or not applicable based on the nature of the submission.
Acceptance Criteria and Device Performance (Non-AI Device)
1. Table of Acceptance Criteria and Reported Device Performance
| No. | Testing Item | Acceptance Criteria (Specification) | Reported Device Performance (Result) |
|---|---|---|---|
| 01 | Appearance | Disposable Safety Lancets the surface should be smooth without edge, no dirt and damage, deformation and other poor appearance. | Pass |
| 02 | Launch Length | The length of the needles in the Disposable Safety Lancet is different in different genders and ages. The launch length of the needle is determined according to the length of the purchase, and the general emission length is 1.2mm-2.8mm. | Pass |
| 03 | Sharpness | Penetration force ≤1.00N. | Pass |
| 04 | Feature (Safety) | The tip of the needle can shrink quickly after firing, and the tip of the needle is not exposed. | Pass |
| 05 | Feature (Single Use) | Disposable Safety Lancets Only one launch, not another. | Pass |
| 06 | Initial Bioburden | Initial bioburden of the device shall be less than 100CFU/g | Pass |
| 07 | Sterile | The sterile blood lancet shall be sterile | Pass |
Biocompatibility Testing:
| Item | Test Method | Acceptance Criteria (Implicit: No adverse reaction) | Reported Device Performance (Result) |
|---|---|---|---|
| Cytotoxic test | ISO 10993-5:2009 | No Cytotoxicity | No Cytotoxicity |
| Skin sensitization test | ISO 10993-10:2010 | No Skin sensitization | No Skin sensitization |
| Intracutaneous test | ISO 10993-10:2010 | No irritation | No irritation |
| Acute systemic toxicity test | ISO 10993-11:2017 | No Acute Systemic Toxicity | No Acute Systemic Toxicity |
| Hemolysis test | ISO 10993-4:2017 | No Hemolysis | No Hemolysis |
| Pyrogen Test | USP <151> | Non-pyrogenic | Non-pyrogen |
Sterilization and Shelf Life Testing:
- Irradiation sterilization validation: Per ISO 11173-1 and ISO 11173-3 (Pass, implied by conclusion of substantial equivalence).
- Pyrogen testing: Per USP <151> (Pass, as listed in biocompatibility).
- Simulated shipping: Per ASTM D4169 (Pass, implied by conclusion of substantial equivalence).
- Shelf life: 5 years determined based on stability study which includes ageing test (Pass, implied by conclusion of substantial equivalence).
2. Sample size used for the test set and the data provenance
The document does not specify the exact sample sizes (number of units tested) for each of the performance or biocompatibility tests. It broadly states "The following performance data were provided in support of the substantial equivalence determination." This is common for 510(k) summaries where detailed protocols and raw data are part of the full submission but not typically presented in this summary format.
Data Provenance: Not explicitly stated beyond "non-clinical testing." It's generally assumed these tests were conducted at the manufacturer's or contracted labs (often in China, given the manufacturer's location in Suzhou, P.R.China) as part of their quality system requirements. These are laboratory tests of device properties, not clinical data from patients.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
This is not applicable as this is a submission for a physical medical device (lancet), not an AI device that requires expert-established ground truth for image or data interpretation. The "ground truth" for the lancet specifications is based on physical measurements, mechanical properties testing, and standardized biological/chemical tests performed in a lab setting, not human expert consensus.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
This is not applicable as there is no human interpretation or subjective assessment that would require an adjudication method for this type of device testing.
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. This is not an AI-assisted device.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
This is not applicable. This is not an AI device.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
The "ground truth" for this device's performance is based on pre-defined engineering specifications, material properties, and standardized biological safety endpoints (e.g., a penetration force <= 1.00N, sterility, no cytotoxicity). These are objective measurements and test results, not subjective expert consensus or clinical outcomes data in a broad sense.
8. The sample size for the training set
This is not applicable. This is not an AI device and does not involve a training set.
9. How the ground truth for the training set was established
This is not applicable. This is not an AI device and does not involve a training set.
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(188 days)
The product is intended to be used in a hospital or at home to obtain capillary blood samples from the fingertip for tests using small amounts of blood. The lancet is intended to be assembled with a lancing device, such that once the lancing device is launched, the needle of the lancet can prick the skin.
The Disposable Blood Lancets consists of a needle, a body and a cap. The models of the Disposable Blood Lancets are 18G; 21G; 23G; 26G; 28G; 30G; 32G; 33G. Disposable Blood Lancets are used to collect blood samples for hospital clinic test. It is sterilized by Irradiation and is a single-use product.
The provided document (K220387 510(k) summary for Disposable Blood Lancets) details acceptance criteria and the results of a study to demonstrate substantial equivalence to a predicate device, rather than a study proving significant improvement over human readers or standalone performance. The document focuses on performance testing against defined specifications for the device itself.
Here's a breakdown of the requested information based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
| No. | Testing Item | Acceptance Criteria (Specification) | Reported Device Performance (Result) |
|---|---|---|---|
| 01 | Appearance | Lancet should have the same color, no bubble, no flash, no slip. | Pass |
| 02 | Launch Length | The length of the needles in the Disposable Blood Lancets is different in different gauge. The general depth is 3.2mm. | Pass |
| 03 | Sharpness | Penetration force ≤1.00N. | Pass |
| 04 | Exterior | The connection between needle and needle body should be firm. | Pass |
| 05 | Cap twist | Cap twist should be smooth. | Pass |
| 06 | Initial bioburden | Initial bioburden of the device shall be less than 100CFU/g. | Pass |
| 07 | Sterile | The sterile blood lancet shall be sterile. | Pass |
In addition to these direct performance tests, biocompatibility, sterilization validation, and shelf life testing were also performed, with implied "Pass" results for substantial equivalence:
Biocompatibility Testing (Evaluated in accordance with ISO 10993-1:2018):
- Cytotoxic test (ISO 10993-5:2009)
- Skin sensitization test (ISO 10993-10:2010)
- Intracutaneous test (ISO 10993-10:2010)
- Acute systemic toxicity test (ISO 10993-11:2017)
- Hemolysis test (ISO 10993-4:2017)
- Pyrogen Test (USP <151>)
Sterilization and Shelf Life Testing:
- Irradiation sterilization validation per ISO 11173-1 and ISO 11173-3.
- Pyrogen testing per USP <151>.
- Simulated shipping per ASTM D4169.
- Stability study (including aging test) for a 5-year shelf life.
2. Sample Size Used for the Test Set and Data Provenance
The document does not explicitly state the specific sample sizes used for each individual test (e.g., how many lancets were tested for sharpness or appearance). It only reports "Pass" for each criterion.
The data provenance is from non-clinical testing performed by the manufacturer, Suzhou Kyuan Medical Apparatus Co., Ltd., in China. The study is a retrospective evaluation of the device's adherence to established performance and safety standards, typical for a 510(k) submission.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications
This type of information is not applicable to the provided document. The "ground truth" for this device's performance is based on objective, quantifiable engineering and biological test standards (e.g., penetration force of 1.00N, bioburden < 100CFU/g, ISO and USP standards). Experts would be involved in designing and conducting these tests, but not in establishing a subjective "ground truth" through consensus, as might be the case for image interpretation AI.
4. Adjudication Method for the Test Set
Not applicable. Adjudication methods like "2+1" or "3+1" are typically used in studies involving subjective human interpretations (e.g., radiology reads) to establish a consensus ground truth. For the objective performance tests of a blood lancet, the results are typically binary (Pass/Fail) against a defined specification.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done
No, an MRMC comparative effectiveness study was not done. This type of study would compare human performance with and without AI assistance, which is irrelevant for a physical medical device like a blood lancet. The study focuses on the device's intrinsic physical and biological properties.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
Not applicable. This question pertains to AI/algorithm performance. The device is a physical blood lancet, not an algorithm. The "standalone performance" here refers to the device's ability to meet its specifications independently, which is what the non-clinical testing demonstrated.
7. The Type of Ground Truth Used
The "ground truth" for the Disposable Blood Lancets is established by:
- Engineering specifications: Quantifiable physical parameters (e.g., launch length, penetration force, connection firmness).
- Biological/Chemical standards: Bioburden levels, sterility test results, biocompatibility test results (cytotoxicity, sensitization, etc.) as defined by international standards (ISO, ASTM) and pharmacopeial standards (USP).
- Regulatory compliance: Adherence to predicate device characteristics and general safety/effectiveness principles as required for 510(k) clearance.
8. The Sample Size for the Training Set
Not applicable. The concept of a "training set" applies to machine learning or AI models. This submission is for a physical medical device, not an AI product. The assessment is based on physical and biological testing of the manufactured device.
9. How the Ground Truth for the Training Set Was Established
Not applicable. As a physical medical device, there is no "training set" or corresponding ground truth established in the context of machine learning. The device's design and manufacturing process are validated against established engineering and biological standards.
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