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510(k) Data Aggregation

    K Number
    K231161
    Date Cleared
    2023-07-21

    (88 days)

    Product Code
    Regulation Number
    880.5200
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    0.9% Sodium Chloride Injection, USP BD PosiFlush™ SF Saline Flush Syringe

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

    The 0.9% Sodium Chloride Injection, USP, BD PosiFlush™ SF Saline Flush Syringes are intended to be used only for the flushing of indwelling vascular access devices.

    Device Description

    0.9% Sodium Chloride Injection, USP, BD PosiFlush™ SF Saline Flush Syringe is a polypropylene syringe intended to flush indwelling vascular access devices. It is a sterile, single use syringe prefilled with 0.9% sodium chloride injection, USP, and sealed with a tip cap. The device is packaged in a film-on-film blister pack and sterilized by gamma irradiation. External sterility of the device enables it to be used in the sterile field. The subject device is available only in 10mL syringe configuration.

    AI/ML Overview

    This document pertains to the 510(k) premarket notification for the "0.9% Sodium Chloride Injection, USP BD PosiFlush™ SF Saline Flush Syringe," a medical device, not an AI/ML-driven device or an imaging system. Therefore, the questions regarding AI/ML performance metrics, expert consensus for ground truth, MRMC studies, or training/test set details are not applicable to this submission.

    This submission focuses on demonstrating substantial equivalence to a predicate device (K153481) through bench performance testing, packaging integrity, and biocompatibility tests. The "acceptance criteria" here refer to the specifications for these non-clinical tests, rather than diagnostic performance metrics of an AI model.

    Here's the information extracted that aligns with the request, re-interpreting "acceptance criteria" and "study" in the context of this device's submission:

    1. Table of Acceptance Criteria and Reported Device Performance

    TestPurposeAcceptance CriteriaResult
    Performance/Design Verification Tests
    Tip Cap Removal TorqueMeasure the torque required to remove the tip cap from the syringeTip Cap can be twisted off as per BD validated forcePass
    RefluxMeasure the potential blood reflux into the catheter from PosiFlush™ SF syringeReflux greater than BD validated internal valuePass
    Tip Cap LeakageEvaluate the resistance to leakage between the barrel Luer and the tip cap for pre-filled syringesNo evidence of Tip Cap leakagePass
    Leakage past StopperEvaluate the resistance to leakage between the barrel and stopper ribsNo leakage of solution past the stopper ribsPass
    Breakloose forceMeasure the initial maximum force required to move the plunger rod/stopper in the syringe barrelForce to move plunger rod/stopper is less than the BD validated forcePass
    Breakout ForceMeasure the maximum force required to move the plunger rod/stopper in the syringe barrel a short time after initially moving the plunger rod/stopperForce to move plunger rod/stopper is less than the BD validated forcePass
    Sustaining ForceMeasure the average force required to move the plunger rod/stopper in the syringe barrelForce to move plunger rod/stopper is less than the BD validated forcePass
    Retaining Ring ForceMeasure the force necessary to remove the plunger rod/stopper assembly from the syringe barrel after assemblyForce to move plunger rod/stopper is greater than the BD validated forcePass
    Expelled VolumeMeasure the volume of saline solution expelled from the syringeUSP43-NF38 Container Content for InjectionsPass
    NaCl AssayMeasure the NaCl concentration saline solution in syringe samples0.9% NaCl Injection USP MonographPass
    pHMeasure the pH of saline solution in syringe samples0.9% NaCl Injection USP Monograph and USP43-NF38 pHPass
    IronMeasure the amount of iron in saline solution0.9% NaCl Injection USP Monograph and USP43-NF38 IronPass
    Heavy MetalsMeasure the heavy metals such as Cadmium, Arsenic, Cobalt, Vanadium, Copper, Lead, Nickel, Lithium, Antimony and Mercury in saline solutionUSP43-NF38 Elemental Impurities - LimitsPass
    NaCl solution weight lossMeasure the weight loss of saline solution in pre-filled saline syringesUSP43-NF38 Containers Performance TestingPass
    UV AnalysisMeasure the UV absorbance between 220-360 nm for pre-filled saline syringesBacterial Endotoxins TestPass
    SterilityTo verify 10-6 SAL in the fluid path.Sterile; No growthPass
    Surface SterilityTo verify 10-6 SAL on all surface of syringe and inside surface of primary packagingSterile; No growthPass
    Particulate MatterMeasure the number of particulates in saline pre-filled syringesUSP43-NF38 Particular Matter in InjectionsPass
    Appearance and Solution Clarity/Barrel TransparencyExamine the appearance, solution clarity and barrel transparency in pre-filled saline syringesSolution and components are clearPass
    Primary Package Integrity TestsEvaluates the sterile barrier system of the pre-filled syringe throughout shelf lifeNo leaks when tested by Vacuum Bubble Leak (ASTM F2096-11)Pass
    Non-porousPass
    Seal strength and width value as per BD validated force and width measurements respectivelyPass
    No defects in packaging seals when visually inspectedPass
    Clean peel of blister pack with no foreign matterPass
    Biocompatibility Tests
    CytotoxicityISO 10993-5:2009 Biological evaluation of medical devices - Part 5: Tests for in vitro cytotoxicityGrade ≤ 2Pass
    SensitizationISO 10993-10:2021 Biological Evaluation of Medical Devices - Part 10: Tests for Skin SensitizationNon-SensitizerPass
    IrritationISO 10993-23:2021 Biological Evaluation of Medical Devices - Part 23: Tests for IrritationFinal Test Sample Score ≤ 1Pass
    Acute Systemic ToxicityISO 10993-11:2017 Biological evaluation of medical devices — Part 11: Tests for systemic toxicityNo significantly greater biological reaction than the controlPass
    Material Mediated PyrogenicityISO 10993-11:2017 Biological evaluation of medical devices — Part 11: Tests for systemic toxicity / USP43-NF38 Pyrogen Test (USP Rabbit Test)No temperature rise ≥ 0.5° CPass
    HemocompatibilityISO 10993-4:2017 Biological evaluation of medical devices Part 4: Selection of tests for interactions with blood / ASTM F756-17 Standard Practice for Assessment of Hemolytic Properties of Materials≤ 5% hemolysisPass
    GenotoxicityISO 10993-3: 2014 Biological evaluation of medical devices – Part 3: Tests for genotoxicity, carcinogenicity and reproductive toxicityNon-mutagenicPass
    LAL EndotoxinUSP 43-NF38 Medical Devices – Bacterial Endotoxin / USP43-NF38 Bacterial Endotoxins Test / ANSI AAMI ST72:2019 Bacterial endotoxins - Test methods, routine monitoring, and alternatives to batch testingBelow the Endotoxin Limit 0.5 EU/devicePass
    Extractable and Leachable AnalysisISO 10993-18: 2020 Biological evaluation of medical devices - Part 18: Chemical characterization of materials / ISO 10993-17: 2002 Biological evaluation of medical devices - Part 17: Establishment of allowable limits for leachable substancesUnder the condition of the chemical characterization testing, there were no extractables and leachables identified that indicated significant risk concerns.Note 1

    Note 1: Result is a qualitative statement, not a numerical pass/fail against a specific threshold listed in the table.

    2. Sample Size Used for the Test Set and Data Provenance:

    The document does not specify numerical sample sizes for each of the performance, packaging, or biocompatibility tests. It only states that "appropriate performance tests and biocompatibility tests were performed" and the gamma sterilized test samples were evaluated. The data provenance (country of origin, retrospective/prospective) is also not specified, as these are bench and lab-based tests, not clinical studies involving patient data.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts:

    Not applicable. This submission is for a physical medical device, not an AI/ML imaging device. Ground truth, in this context, refers to the established standards, monograph requirements (e.g., USP, ISO), and validated internal specifications to which the device performance is measured against. Experts here would be the laboratory personnel and engineers performing the tests and
    interpreting results against these defined criteria, but their specific number or detailed qualifications are not provided in the summary.

    4. Adjudication Method for the Test Set:

    Not applicable. Since this is not an AI/ML diagnostic device, there is no "adjudication" of expert opinions on image interpretation. The tests performed are laboratory or bench-based, with results measured against predetermined quantitative or qualitative acceptance criteria.

    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/ML device, and no MRMC study was performed. The device's safety and effectiveness are demonstrated through non-clinical performance, packaging, and biocompatibility testing.

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

    Not applicable. This device is a physical product (saline syringe), not an algorithm or software. No standalone algorithm performance was assessed.

    7. The Type of Ground Truth Used:

    The "ground truth" for this device's evaluation is primarily based on:

    • Established Standards: e.g., ISO 10993 series for biocompatibility, ASTM F2096-11 for vacuum bubble leak, ANSI AAMI ST72:2019 for Bacterial Endotoxins.
    • Pharmacopoeia Monographs: e.g., USP43-NF38 for NaCl Injection, pH, Iron, Heavy Metals, Particulate Matter, Bacterial Endotoxin.
    • Validated Internal Specifications: "BD validated force" or "BD validated internal value" for mechanical/physical properties like tip cap removal torque, reflux, breakout force, sustaining force, retaining ring force, and seal strength.
    • Qualitative Observations: e.g., "No evidence of Tip Cap leakage," "No leakage of solution past the stopper ribs," "Solution and components are clear," "No defects in packaging seals when visually inspected."

    Essentially, the ground truth is defined by recognized industry standards, pharmacopoeial requirements, and the manufacturer's own validated specifications for product performance and safety.

    8. The Sample Size for the Training Set:

    Not applicable. This is not an AI/ML device; there is no "training set."

    9. How the Ground Truth for the Training Set was Established:

    Not applicable. As there is no training set for an AI/ML model, this question does not apply.

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