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510(k) Data Aggregation

    K Number
    K211716
    Manufacturer
    Date Cleared
    2022-01-07

    (218 days)

    Product Code
    Regulation Number
    880.5570
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The DropSafe Safety Pen Needles are sterile, single-use safety needles intended for use with pen injector devices for the injection of drugs.

    Device Description

    DropSafe Safety Pen Needles are sterile, single-use safety needles intended for use with pen injector devices for the injection of drugs. DropSafe Safety Pen Needles are OTC devices intended to be used by clinical and non-clinical users. DropSafe Safety Pen Needles are already offered in one gage - 31 G and in two lengths: 6mm and 8 mm. This submission covers the addition of a new length: 5 mm with the same gage - 31G. DropSafe Safety Pen Needles are gamma sterilized, non-toxic single use devices.

    The device is designed to minimize the risk from accidental needle sticks with a used needle by application of a sharps injury prevention feature. Following use, the needle is locked out preventing reuse. The shield also serves to hide the needle before and after injection. Each DropSafe safety pen needle is individually packaged in a sealed container. The DropSafe safety pen needle is used by removing the seal and attaching it to the pen injector device to administer a drug subcutaneously. While inserting the needle into the skin at a 90° angle, the slider glides into the shield. While the slider glides into the shield, the safety feature is activated. Following injection, the slides back into its initial position, completely covering the needle where it remains locked. The red safety lock indicator tells the safety lock has been activated. Once the safety pen needle is in the locked mode, it cannot be reused. The safety pen needle is detached from the pen injector device and disposed of into a sharps container.

    The pen needle assembly consists of a double-ended cannula that is assembled into an injection molded hub using an adhesive. The hub has internal threads which allows it to be screwed onto the pen injector device. This allows the cartridge end of the needle to penetrate through the rubber septum of the cartridge. The patient-end and the cartridge end of the cannula are lubricated using a silicone-based lubricant for ease of injection and rubber septum penetration.

    An injection molded inner shield is assembled over the patient end of the cannula to prevent needle point damage and accidental needle-sticks. This needle assembly is inserted into a protective injection molded container and sealed with a peel away medical grade paper tab which provides a sterility barrier and tamper evident seal.

    AI/ML Overview

    The provided text describes the 510(k) summary for the DropSafe Safety Pen Needles, specifically focusing on the addition of a new 5mm length. While it details non-clinical performance data and mentions a simulated use study for clinical performance, the structured format of an AI device's acceptance criteria and proven performance based on specific metrics (like sensitivity, specificity, AUC) is not directly present.

    The document primarily demonstrates substantial equivalence to a predicate device (DropSafe Safety Pen Needle K170988) by showing that the new device's technical characteristics, intended use, operation principle, and materials are same, with the only difference being the needle length (5mm vs. 6mm and 8mm for the predicate). The "performance data" presented is largely a compliance check against ISO 11608-2:2012, which covers physical and functional requirements for pen needles.

    Therefore, I cannot extract the information required for a typical AI device's acceptance criteria and study proving its performance in the requested format, as this submission pertains to a mechanical medical device (a safety pen needle) and not an AI/ML powered device.

    However, I can describe the acceptance criteria and proven device performance as they relate to the information provided for this specific device:

    Device Type: Mechanical medical device (Safety Pen Needle), not an AI/ML medical device.

    1. Table of Acceptance Criteria and Reported Device Performance (as per ISO 11608-2:2012 for a mechanical device):

    Parameter and Clause from ISO 11608-2:2012Acceptance Criteria (Requirements)Reported Device Performance (Result)
    4.1 MaterialsThe needle shall be made of tubing materials specified in ISO 9626.Meets standard
    4.2.2 DimensionsNeedles shall fit the test apparatus specified in item 7.3 of ISO 11608-2. Dimensions shall be in accordance with the standard.Meets standard
    4.3 Determination of flow rate through the needleThe flow rate is at the border: min 2.14 ml/min.Meets standard
    4.4 Bond between hub and needle tubeClause 9 of ISO 11608-2 and clause 13.1. The union of the hub and needle tube shall not break for at least 5 sec. while a force of at least 11 N is applied.Meets standard
    4.5 Needle pointsVisually under a magnification of x2.5, needle points shall appear sharp and free from feather edges, burrs and hooks.Meets standard
    4.6 Freedom from defectsVisually inspected by normal or corrected-to-normal vision without magnification under an illuminance of 300 lx to 700 lx, the outer surface of the tubing shall be smooth and free from defects.Meets standard
    4.7 LubricationNo visible droplets on the outside surface of the needle.Meets standard
    4.8 Dislocation of measuring point at patient endClause 8 of ISO 11608-2:2012 maximum allowable dislocation acc. Clause 4.8, Table 2 for 5mm: 0.65m.Meets standard
    4.9 Determination of functional compatibility with needle-basedClause 11 of ISO 11608-2:2012. Needle assembly torque: 0.07 +/- 0.01 Nm. Needle hub removal: less than 0.100 Nm. Dose accuracy: for doses ≤ 20 ml the calculated values were within ± 0.01 ml of the targeted dose; for doses > 20 ml the calculated values were within ± 5 % of the targeted dose.Meets standard
    4.10 Ease of assembly and disassembly(Implicitly covered by 4.9 related to torque and removal, and also by the simulated use study for user interaction).Meets standard
    4.11 SterilityThe needle in its unit packaging has undergone an approved sterilization process. Sterilization method: Gamma irradiation. Sterilization conditions 17.5-40kGy.Meets standard
    6. Pre-conditioning of needlesAll pen safety needles to be tested were preconditioned atmosphere in: a dry-heat, a cold-storage, a cyclical atmosphere. Prepared in accordance with the requirements specified in clauses 6.1, 6.2, 6.3 of ISO 11608-2:2012.Meets standard
    12.2.1 Marking on the unit packagingAny marking on the unit packaging that is essential for the safe use of the NIS shall be visible and easily legible.Meets standard
    12.2.2 Marking on the unit packagingThe marking on the unit packaging shall comprise at least the particulars listed in ISO 11608-2:2012 item 12.2.2.Meets standard
    12.2.3 Marking on the user packagingThe marking on the user packaging shall comprise at least the particulars listed in ISO 11608-2:2012 item 12.2.3.Meets standard
    Simulated Use Study (Clinical Performance)The function of the safety feature should be evaluated in a simulated clinical environment with the participation of both clinical and non-clinical users. The IFU should be validated. The device should not affect injection technique or pen injector functionality, and be safe and effective when used as per IFU.Device does not affect injection technique or functionality and is safe and effective as per IFU.

    As the device is not an AI/ML medical device, the following points are not applicable in their typical sense for an AI/ML context:

    2. Sample size used for the test set and data provenance:
    * The document does not specify a numerical sample size for each performance test listed in the table, nor does it detail data provenance in terms of country of origin or if it's retrospective/prospective outside of the "simulated clinical environment" for the simulated use study. The tests are in vitro compliance tests.

    3. Number of experts used to establish the ground truth for the test set and qualifications of those experts:
    * Not applicable for this type of device and testing. Ground truth for these criteria is based on international standards (ISO 11608-2:2012) and engineering measurements/observations, not expert consensus on medical images or diagnoses.

    4. Adjudication method (e.g., 2+1, 3+1, none) for the test set:
    * Not applicable. Test results are objective measurements against specified standard requirements.

    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-powered device, and no human reader comparative study was performed.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
    * Not applicable. This is a mechanical device, not an algorithm. Its "standalone" performance is measured by its physical compliance to standards.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
    * The "ground truth" for this device's performance is compliance with established international standards (ISO 11608-2:2012) and engineering specifications, along with functional testing for elements like the safety feature. For the 'Simulated Use Study', the ground truth is functional validation and user experience.

    8. The sample size for the training set:
    * Not applicable. There is no "training set" as this is not an AI/ML device.

    9. How the ground truth for the training set was established:
    * Not applicable. There is no "training set."

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