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510(k) Data Aggregation
(103 days)
Clickfine Pen Needle, Penfine Classic Pen Needle
The Clickfine and Penfine Classic Pen Needle are intended for use with pen injector devices for subcutaneous injection of fluids, including insulin and exenatide.
The subject devices are sterile, non-pyrogenic, single use pen needles designed to be used with commercially available pen-injectors. The back end of the needle punctures the rubber injection port of the drug reservoir in the pen. When the injection is needed, the needle is inserted into the chosen site and the pen-injector delivers the fluid through the needle. The materials of construction, (siliconized stainless-steel needle encased in a polypropylene hub with a polypropylene protective cap) as well as the sterile packaging (a polypropylene outer protective container and the peel tab) which provides the sterile barrier and the manufacturing (which includes radiation sterilization) are unchanged from the currently marketed devices. They subject devices will be marketed in the same sizes as the predicate devices - 32 and 31 gauges and 4, 4.5, 5, 6, 8, 10, and 12 mm lengths.
This FDA 510(k) summary focuses on the substantial equivalence of a medical device (pen needle) to a predicate device, rather than the performance of an AI/ML algorithm. Therefore, many of the requested categories related to AI/ML studies are not applicable.
Here's an analysis based on the provided text, addressing the applicable points:
1. Table of Acceptance Criteria and Reported Device Performance
Device Modification | Verification Activity | Acceptance Criteria | Results of Verification |
---|---|---|---|
Larger inner diameter of needle on 31 Gauge and 32 Gauge needles | Testing for resistance to breakage was conducted acc. ISO 9626:2016 | When tested acc. Annex C of ISO 9626:2016, the tubing shall not show visible breakage when examined by normal or corrected vision after testing. | All samples tested met the acceptance criteria for resistance to breakage acc. ISO 9626:2016. |
Larger inner diameter of needle on 31 Gauge and 32 Gauge needles | Testing for stiffness was conducted acc. ISO 9626:2016 | The tubing shall show a maximum defined deflection when tested in accordance with annex B of ISO 9626:2016: max. deflection 0.22 mm for 32 G and max. 0.21 mm for 31 G. | All samples tested met the acceptance criteria for stiffness acc. ISO 9626:2016. |
2. Sample size used for the test set and the data provenance
The document does not specify a numerical sample size for the tests. It states "All samples tested" for both breakage and stiffness, implying that a sufficient number was tested to meet the requirements of the specified ISO standards, but the exact number isn't provided. Data provenance is not applicable here as it's a physical device performance test, not a data-driven model.
3. 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 performance is established by standardized measurement methods defined by international standards (ISO). No human expert consensus for "ground truth" in this context is mentioned.
4. Adjudication method for the test set
Not applicable. The tests are pass/fail based on objective measurements against ISO standards. No adjudication method is described.
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.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. This is not an AI/ML device.
7. The type of ground truth used
The ground truth for the device's performance (breakage and stiffness) is defined by the objective measurement criteria and methodologies outlined in the referenced ISO standards (ISO 9626:2016).
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. This is not an AI/ML device; there is no "training set" or corresponding ground truth establishment process.
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(88 days)
Clickfine Pen Needle, Penfine Classic Pen Needle (other trade names anticipated)
The pen needles are intended for use with pen injector devices for subcutaneous injection of fluids, including insulin and exenatide.
All of the subject device pen needles are sterile, non-pyrogenic, single use needles designed to be used with commercially available pen-injectors for the administration of prescribed fluids. Each needle is individually packaged in a sealed protective container with a peel tab. The subject device pen needles are used by peeling back the peel tab. The hub of the currently marketed Clickfine Pen Needle is snapping or screwing onto the threaded end of the pen injector. The modified Penfine Classic Pen Needle is attached to pen injectors with only a "screwing" motion. For all needles the back end of the cannula punctures the rubber injection port of the drug reservoir in the pen-injector. The outer protective cap is then removed. The inner protective cap will remain over the needle until the fluid is ready to be injected. When the injection is needed, the inner protective cap is removed and the needle is inserted into the chosen site. The pen-injector automatically delivers the fluid through the needle. The protective cap is replaced and the needle is then unscrewed for the pen injector, discarded and replaced with a new needle before the next injection.
This FDA 510(k) summary describes the "Clickfine Pen Needle" and "Penfine Classic Pen Needle" by Ypsomed AG. The document details the device's intended use and demonstrates its substantial equivalence to a predicate device.
Here's an analysis of the provided text based on your requested information:
1. Table of Acceptance Criteria and Reported Device Performance
The document lists several tests and associated clauses from international standards (ISO 11608-2, ISO 9626/A1, ISO 7864) which serve as the acceptance criteria. The reported device performance is that "The verifications have shown evidence that the subject device pen needles meet the acceptance criteria of these standards." and "Based on the results it can be concluded that the device performance is acceptable for the product." While the specific quantitative results for all tests are not provided in this summary, the criteria themselves are detailed.
Test / Acceptance Criteria | Reported Device Performance |
---|---|
Needle Assembly Compatibility (ISO 11608-2, Clause 4.2.1) | |
Attachment shall fit and function with needle-based injection systems specified in ISO 11608-1. | Tested on compatibility with needle-based injection systems as specified in ISO 11608-1. (Met Acceptance Criteria) |
Tubing Dimensions (ISO 11608-2, Clause 4.2.2, Table 1) | |
Length of patient end: +/- 1.25 mm | |
Length of cartridge end: 5.7 – 7.0 mm | (Met Acceptance Criteria) |
Flow Rate (ISO 11608-2, Clause 4.3) | |
Measurement of flow rate in accordance with Annex A. | (Met Acceptance Criteria) |
Bond between Hub and Needle Tube (ISO 11608-2, Clause 9 & ISO 7864, Clause 13.1) | |
The union shall not break for at least 5 sec. while a force of at least 22 N is applied. | (Met Acceptance Criteria) |
Needle Points (ISO 11608-2, Clause 4.5) | |
Visually sharp at a 2.5x magnification; designed to minimize coring and fragmentation. | (Met Acceptance Criteria) |
Lubrication (ISO 11608-2, Clause 4.7) | |
No visible droplets on the outside surface of the needle tube. | (Met Acceptance Criteria) |
Dislocation of Measuring Point at Patient-End (ISO 11608-2, Clause 8) | |
4, 6, 8, 10mm +/- 0.9mm, 12mm +/- 1.1mm | (Met Acceptance Criteria) |
Functional Compatibility with Needle Based Injection Systems (ISO 11608-2, Clause 11) | |
Needle assembly torque: 0.07 +/- 0.01 Nm | |
Needle hub removal: less than 0.100 Nm | |
Dose accuracy: for doses ≤ 20 ml, calculated values within ± 0.01 ml of targeted dose; for doses > 20 ml, calculated values within ± 5% of targeted dose. | (Met Acceptance Criteria) |
Tubing Characteristics (ISO 9626/A1, Table 1) | |
Made of austenitic stainless steel according to designated types in Table 1. | (Met Acceptance Criteria) |
Tubing Diameters (ISO 9626/A1, Table 2) | |
Meet outer and inner diameter requirements as defined in Table 2. | (Met Acceptance Criteria) |
Stiffness (ISO 9626, Clause 9) | |
When tested per Annex C, deflection not greater than relevant value in Table 3. | (Met Acceptance Criteria) |
Resistance to Breakage (ISO 9626, Clause 10) | |
When tested per Annex D and Table 4, tubing shall not break. | (Met Acceptance Criteria) |
Limits for Acidity and Alkalinity (ISO 9626, Clause 6) | |
Correction for volume of titrant required for control fluid not more than 0.04 ml NaOH or 0.12 ml HCl. | (Met Acceptance Criteria) |
Resistance to Corrosion (ISO 9626, Clause 11) | |
When tested per Annex E, immersed half of tubing no evidence of corrosion. | (Met Acceptance Criteria) |
Patency of Lumen (ISO 7864, Clause 13.2) | |
A stylet, having a diameter equivalent to 80% ±2% of lumen inner diameter, must pass through freely. | (Met Acceptance Criteria) |
Freedom of Defects (ISO 7864, Clause 11.3) | |
When examined by normal or corrected-to-normal vision, needle shall appear straight and of regular cross-section and wall thickness. | (Met Acceptance Criteria) |
Limits for Extractable Metals (ISO 7864, Clause 6) | |
Content of lead, tin, zinc, iron less than 5mg/l; cadmium content lower than 0.1 mg/l. | (Met Acceptance Criteria) |
Freedom of Defects (ISO 7864, Clause 11.3) | |
(Duplicate in text) When examined by normal or corrected vision, the needle tube shall appear straight and of regular cross-section and wall thickness. | (Met Acceptance Criteria) |
2. Sample Size Used for the Test Set and Data Provenance
The document does not explicitly state the sample sizes used for each specific test or the data provenance (e.g., country of origin, retrospective/prospective). It generally states that "appropriate verification and/or validation activities" were performed.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications
This type of information is not relevant or applicable for the device described (hypodermic single lumen needles). The performance is assessed against engineering and material standards, not against expert interpretation of clinical data.
4. Adjudication Method for the Test Set
Not applicable, as the tests are objective measurements against established engineering and material standards, not subjective interpretations requiring adjudication.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done
No. This type of study is not relevant for a medical device like a pen needle, which is evaluated based on its physical and functional properties against technical standards. MRMC studies are typically used for diagnostic devices that involve human interpretation of images or other data.
6. If a Standalone Study (Algorithm Only Without Human-in-the-Loop Performance) Was Done
Yes, in essence. The studies performed were "standalone" in the sense that they evaluated the device itself against established engineering and material standards. There is no "algorithm" or "human-in-the-loop" aspect for a hypodermic needle's performance. The tests described are laboratory-based assessments of the physical and mechanical properties of the needles.
7. The Type of Ground Truth Used
The ground truth for this device is based on established international engineering and material standards (ISO 11608-2, ISO 9626/A1, ISO 7864). These standards define objective, measurable criteria for the performance, dimensions, and material properties of hypodermic needles.
8. The Sample Size for the Training Set
Not applicable. This device is not an AI/ML-based system that requires "training data." Its performance is evaluated through physical tests and measurements.
9. How the Ground Truth for the Training Set Was Established
Not applicable, as there is no "training set" for this type of device.
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