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510(k) Data Aggregation
(88 days)
0.9% Sodium Chloride Injection, USP BD PosiFlush SF Saline Flush Syringe
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.
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.
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
Test | Purpose | Acceptance Criteria | Result |
---|---|---|---|
Performance/Design Verification Tests | |||
Tip Cap Removal Torque | Measure the torque required to remove the tip cap from the syringe | Tip Cap can be twisted off as per BD validated force | Pass |
Reflux | Measure the potential blood reflux into the catheter from PosiFlush™ SF syringe | Reflux greater than BD validated internal value | Pass |
Tip Cap Leakage | Evaluate the resistance to leakage between the barrel Luer and the tip cap for pre-filled syringes | No evidence of Tip Cap leakage | Pass |
Leakage past Stopper | Evaluate the resistance to leakage between the barrel and stopper ribs | No leakage of solution past the stopper ribs | Pass |
Breakloose force | Measure the initial maximum force required to move the plunger rod/stopper in the syringe barrel | Force to move plunger rod/stopper is less than the BD validated force | Pass |
Breakout Force | Measure the maximum force required to move the plunger rod/stopper in the syringe barrel a short time after initially moving the plunger rod/stopper | Force to move plunger rod/stopper is less than the BD validated force | Pass |
Sustaining Force | Measure the average force required to move the plunger rod/stopper in the syringe barrel | Force to move plunger rod/stopper is less than the BD validated force | Pass |
Retaining Ring Force | Measure the force necessary to remove the plunger rod/stopper assembly from the syringe barrel after assembly | Force to move plunger rod/stopper is greater than the BD validated force | Pass |
Expelled Volume | Measure the volume of saline solution expelled from the syringe | USP43-NF38 Container Content for Injections | Pass |
NaCl Assay | Measure the NaCl concentration saline solution in syringe samples | 0.9% NaCl Injection USP Monograph | Pass |
pH | Measure the pH of saline solution in syringe samples | 0.9% NaCl Injection USP Monograph and USP43-NF38 pH | Pass |
Iron | Measure the amount of iron in saline solution | 0.9% NaCl Injection USP Monograph and USP43-NF38 Iron | Pass |
Heavy Metals | Measure the heavy metals such as Cadmium, Arsenic, Cobalt, Vanadium, Copper, Lead, Nickel, Lithium, Antimony and Mercury in saline solution | USP43-NF38 Elemental Impurities - Limits | Pass |
NaCl solution weight loss | Measure the weight loss of saline solution in pre-filled saline syringes | USP43-NF38 Containers Performance Testing | Pass |
UV Analysis | Measure the UV absorbance between 220-360 nm for pre-filled saline syringes | Bacterial Endotoxins Test | Pass |
Sterility | To verify 10-6 SAL in the fluid path. | Sterile; No growth | Pass |
Surface Sterility | To verify 10-6 SAL on all surface of syringe and inside surface of primary packaging | Sterile; No growth | Pass |
Particulate Matter | Measure the number of particulates in saline pre-filled syringes | USP43-NF38 Particular Matter in Injections | Pass |
Appearance and Solution Clarity/Barrel Transparency | Examine the appearance, solution clarity and barrel transparency in pre-filled saline syringes | Solution and components are clear | Pass |
Primary Package Integrity Tests | Evaluates the sterile barrier system of the pre-filled syringe throughout shelf life | No leaks when tested by Vacuum Bubble Leak (ASTM F2096-11) | Pass |
Non-porous | Pass | ||
Seal strength and width value as per BD validated force and width measurements respectively | Pass | ||
No defects in packaging seals when visually inspected | Pass | ||
Clean peel of blister pack with no foreign matter | Pass | ||
Biocompatibility Tests | |||
Cytotoxicity | ISO 10993-5:2009 Biological evaluation of medical devices - Part 5: Tests for in vitro cytotoxicity | Grade ≤ 2 | Pass |
Sensitization | ISO 10993-10:2021 Biological Evaluation of Medical Devices - Part 10: Tests for Skin Sensitization | Non-Sensitizer | Pass |
Irritation | ISO 10993-23:2021 Biological Evaluation of Medical Devices - Part 23: Tests for Irritation | Final Test Sample Score ≤ 1 | Pass |
Acute Systemic Toxicity | ISO 10993-11:2017 Biological evaluation of medical devices — Part 11: Tests for systemic toxicity | No significantly greater biological reaction than the control | Pass |
Material Mediated Pyrogenicity | ISO 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° C | Pass |
Hemocompatibility | ISO 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% hemolysis | Pass |
Genotoxicity | ISO 10993-3: 2014 Biological evaluation of medical devices – Part 3: Tests for genotoxicity, carcinogenicity and reproductive toxicity | Non-mutagenic | Pass |
LAL Endotoxin | USP 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 testing | Below the Endotoxin Limit 0.5 EU/device | Pass |
Extractable and Leachable Analysis | ISO 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 substances | Under 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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