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510(k) Data Aggregation

    K Number
    K161552
    Date Cleared
    2017-02-02

    (241 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 SP Syringe

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

    The 0.9% Sodium Chloride Injection, USP, BD PosiFlush™ SP Syringe is intended to be used only for the flushing of indwelling vascular access devices. Catalog Number 306547 10 mL BD PosiFlush™ SP Syringes are generally compatible for use with syringe pumps.

    Device Description

    The 0.9% Sodium Chloride Injection, USP, BD PosiFlush™ SP (also referred to as BD PosiFlush™ SP Syringe) is a three-piece, sterile, single use syringe with a 6% (luer) connector prefilled with 0.9% sodium chloride injection, USP, and sealed with a tip cap. The BD PosiFlush™ SP Syringe is provided with a sterile fluid path, which is sterilized via moist heat.

    The change described in this submission is the qualification of a supplier specific formulation for stopper material for 0.9 % Sodium Chloride Injection, USP, BD PosiFlush™ SP Syringes.

    AI/ML Overview

    This document describes a Special 510(k) submission for a medical device called "0.9% Sodium Chloride Injection, USP, BD PosiFlush™ SP Syringe" (K161552). The submission aims to demonstrate substantial equivalence to a previously cleared predicate device (K141311) due to a change in the supplier specific formulation for the stopper material.

    I will focus on the provided information to answer your request, specifically looking for acceptance criteria and the study proving it.

    Here's an analysis based on the document:

    1. Table of Acceptance Criteria and Reported Device Performance:

    The document broadly states that "Design Verification testing was also conducted to ensure the device met the predetermined acceptance criteria for the following tests." It lists the tests but does not provide a specific table enumerating the acceptance criteria values themselves or the quantitative performance measurements obtained for each test. Instead, it states that the device "met predetermined acceptance criteria per BD's internal specification" and "have been verified to meet the established performance criteria above."

    Acceptance Criteria CategoryReported Device Performance
    BiocompatibilityAll tests (Cytotoxicity, Hemolysis, Acute systemic toxicity, Sub-Chronic Toxicity, Intracutaneous reactivity, Occular irritation, Partial thromboplastin Time, Sensitization, Pyrogenicity, Genotoxicity, Chemical extractable analysis) met the requirements of the FDA Guidance Use of International Standard ISO 10993-1.
    Design VerificationMet predetermined acceptance criteria per BD's internal specification for:
    • Container Closure Integrity
    • Break Out/Sustaining force
    • Stopper Separation
    • Leakage
    • Pump Force
    • Ship Test
    • Dead Space
    • Syringe Induced Reflux |

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

    The document does not specify the sample sizes used for any of the tests (biocompatibility or design verification). It also does not mention the country of origin of the data or whether the data was retrospective or prospective. The studies were conducted by Becton, Dickinson and Company.

    3. Number of Experts and Qualifications for Ground Truth:

    This section is not applicable as the clearance is for a pre-filled syringe (a medical device, not an AI or diagnostic tool that requires human expert interpretation for ground truth). The "ground truth" for the performance tests would be based on established engineering and biological standards and verified by internal testing protocols.

    4. Adjudication Method:

    This is not applicable for the same reasons as point 3.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study:

    This is not applicable as the device is a pre-filled syringe, not an AI-assisted diagnostic tool.

    6. Standalone (Algorithm Only) Performance:

    This is not applicable as the device is a pre-filled syringe and does not involve an algorithm.

    7. Type of Ground Truth Used:

    For the performance tests, the "ground truth" would be established by:

    • Established industry standards and regulations (e.g., ISO 10993 for biocompatibility).
    • BD's internal specifications and engineering requirements for device functionality and integrity (e.g., for leakage, break force, dead space).

    8. Sample Size for the Training Set:

    This is not applicable as this is not an AI/machine learning device that requires a training set.

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

    This is not applicable for the same reasons as point 8.

    Study Proving Device Meets Acceptance Criteria:

    The study that proves the device meets the acceptance criteria is detailed across two main categories:

    1. Biocompatibility Testing:

      • Methodology: Evaluated in accordance with FDA Guidance Use of International Standard ISO 10993-1, "Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process," June 16, 2016.
      • Tests Performed: Cytotoxicity (per ISO10993-5), Hemolysis (per ISO10993-4), Acute systemic toxicity (per ISO10993-11), Sub-Chronic Toxicity (Per ISO10993-11), Intracutaneous reactivity (per ISO10993-10), Ocular irritation (per ISO 10993-10), Partial thromboplastin Time (ISO 10993-4), Sensitization (per ISO10993-10), Pyrogenicity (per ISO 10993-11), Genotoxicity (per ISO 10993-3), and Chemical extractable analysis (per ISO 10993-18).
      • Conclusion: The tests confirmed that the device met the requirements outlined in the standards, indicating it is biocompatible.
    2. Design Verification Testing:

      • Methodology: Conducted to ensure the device met "predetermined acceptance criteria per BD's internal specification." The specific methodologies for each test (e.g., how "Container Closure Integrity" was tested) are not detailed but would be standard industry practices for syringe manufacturing.
      • Tests Performed: Container Closure Integrity, Break Out/Sustaining force, Stopper Separation, Leakage, Pump Force, Ship Test, Dead Space, Syringe Induced Reflux.
      • Conclusion: The testing demonstrated that the subject device "met predetermined acceptance criteria."

    Overall Conclusion from the Document:

    The submission concludes that the BD PosiFlush™ SP Syringes "have been verified to meet the established performance criteria above." The results of this design verification and biocompatibility testing "demonstrate that the modifications made to the subject device do not affect the safety and efficacy of the device and demonstrated the same intended use, fundamental scientific technology and operating principles" as the predicate device, thereby proving substantial equivalence.

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    K Number
    K141311
    Date Cleared
    2014-07-25

    (66 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; SP SYRINGE, SF SYRINGE

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

    The 0.9% Sodium Chloride Injection, USP, BD PosiFlush™ SP Syringes and 0.9% Sodium Chloride Injection, USP, BD PosiFlush™ SF Syringes are intended to be used only for the flushing of indwelling vascular access devices. Catalog Number 306547 10 mL 0.9% Sodium Chloride Injection, USP, BD PosiFlush™ SP Syringes are generally compatible for use with syringe pumps.

    Device Description

    The 0.9% Sodium Chloride Injection, USP, BD PosiFlush" SP and SF Syringe (also referred to as BD PosiFlush " SP and SF Syringe) is a three-piece, sterile, single use syringe with a 6% (luer) connector prefilled with 0.9% sodium chloride injection, USP, and sealed with a tip cap. The BD PosiFlush™ SP Syringe is provided with a sterile fluid path, and the BD PosiFlush™ SF Syringe is provided externally sterile for use on a sterile field. Both configurations are sterilized via moist heat. The modified BD PosiFlush™ SP Syringe and BD PosiFlush™ SF Syringe, the subject of this 510(k), includes a new resin material in the barrel of the prefilled syringe.

    AI/ML Overview

    The provided text describes a 510(k) summary for the BD PosiFlush™ SP and SF Syringes, which are prefilled syringes containing 0.9% sodium chloride for flushing vascular access devices. The submission focuses on a change in the resin material for the syringe barrel and asserts substantial equivalence to a predicate device.

    Here's an analysis of the acceptance criteria and the study that proves the device meets them, based on the provided text, while noting the absence of information typically found in AI/algorithm-focused submissions:

    1. Table of Acceptance Criteria and Reported Device Performance

    This product is a medical device (prefilled syringe), not an AI/algorithm. Therefore, the "device performance" here refers to the physical and chemical properties of the syringe and its contents, not a diagnostic accuracy or algorithmic output. The performance is assessed relative to a predicate device or established standards.

    Performance CharacteristicAcceptance CriteriaReported Device Performance
    Functional Testing
    Container Closure IntegrityNo Dye in Solution
    No Leakage in the luer well or tip threads
    No Leakage Past the Stopper Ribs
    No Dye Between Stopper RibsPerformed in an equivalent manner to the predicate device and is safe and effective when used as intended. (Implies all criteria were met. Specific results are not detailed in this summary for each test).
    Break Loose ForceEquivalence to PredicatePerformed in an equivalent manner to the predicate device.
    Break Out ForceEquivalence to PredicatePerformed in an equivalent manner to the predicate device.
    Sustaining ForceEquivalence to PredicatePerformed in an equivalent manner to the predicate device.
    Retaining Ring ForceEquivalence to PredicatePerformed in an equivalent manner to the predicate device.
    Tip Cap Removal ForceEquivalence to PredicatePerformed in an equivalent manner to the predicate device.
    Sodium Chloride Injection, USP, TestingPer USP Monograph, Sodium Chloride InjectionPerformed in an equivalent manner to the predicate device and is safe and effective when used as intended. (Implies all criteria were met. Specific results are not detailed in this summary for each test).
    Bacterial EndotoxinMet USP Monograph requirements.
    Particulate MatterMet USP Monograph requirements.
    Assay of NaClMet USP Monograph requirements.
    Heavy MetalsMet USP Monograph requirements.
    IronMet USP Monograph requirements.
    pHMet USP Monograph requirements.
    Biocompatibility TestingPer ISO10993 Series
    LC/DAD/MS, GC-MS, ICP; acceptable extractable test.Performed in an equivalent manner to the predicate device and is safe and effective when used as intended. (Implies all criteria were met, specifically acceptable extractable test as specified).

    Note: The reported device performance generally states "performed in an equivalent manner to the predicate device and is safe and effective when used as intended" or implies meeting USP Monograph requirements. Specific quantitative results for each test are not detailed in this summary.

    Absent Information (Typical for AI/Algorithm Studies)

    The following information is not applicable or not provided in this 510(k) summary because the device is a physical medical device (syringe with saline), not an AI/algorithm.

    1. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective): Not applicable for a physical device. Testing involves batches of syringes, not a "test set" of data.
    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 physical device testing is based on established engineering and chemical standards.
    3. Adjudication method (e.g. 2+1, 3+1, none) 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 (expert concensus, pathology, outcomes data, etc): For a physical device, ground truth is based on established engineering specifications, chemical analysis standards (e.g., USP Monograph), and biocompatibility standards (e.g., ISO 10993).
    7. The sample size for the training set: Not applicable (no AI/algorithm).
    8. How the ground truth for the training set was established: Not applicable (no AI/algorithm).

    Conclusion of the Study (Non-Clinical Testing)

    The company performed non-clinical testing based on a risk analysis. The results of these tests demonstrated that the modified BD PosiFlush™ SP and SF Syringe performed in an equivalent manner to the predicate device. This equivalence, combined with adherence to established standards (USP Monograph, ISO 10993 series), is deemed sufficient to prove the device's safety and effectiveness.

    Clinical testing was explicitly stated as "not required" for this submission.

    The conclusion is that the device has been validated to meet the established performance criteria based on non-clinical tests, and performs as safely and effectively as the legally marketed predicate devices.

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