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510(k) Data Aggregation
(207 days)
It is to be used in conjunction with an endoscope to perform endoscopic injections, such as for the treatment of esophageal and gastric varices and for submucosal dye marking in the GI tract.
It is a flexible, sterile, sharp bevel-edged, hollow tubular device intended to be manually-operated through a compatible endoscope to perform needle functions (e.g., injection) during endoscopy. It is designed with appropriate shape, materials and gauge to function through the working channel of an endoscope. This is a single-use device.
The provided document is a 510(k) summary for the "Endoscopic Injection Needles" (K240675) from Promisemed Hangzhou Meditech Co., Ltd. It focuses on demonstrating substantial equivalence to a predicate device (Single Use Injection Needle, K210917) through non-clinical performance testing.
Here's an analysis of the acceptance criteria and study information based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance:
The document doesn't present a formal table of acceptance criteria with specific numerical targets and results in the format requested. Instead, it lists the performance items tested and concludes that the testing "successfully demonstrated essential performance" and that the device "is at least equivalent to the predicate device."
Here's a breakdown of the tested performance items:
| Acceptance Criterion (implicitly met) | Device Performance (reported) |
|---|---|
| Appearance | Tested, results met essential performance. |
| Cleanliness | Tested, results met essential performance. |
| Leakage | Tested, results met essential performance. |
| Puncture force | Tested, results met essential performance. |
| Stiffness | Tested, results met essential performance. |
| Resistance of needle tube to breakage | Tested, results met essential performance. |
| Corrosion resistance of needle tube | Tested, results met essential performance. |
| Particle contamination | Tested, results met essential performance. |
| Flexible properties | Tested, results met essential performance. |
| Flow | Tested, results met essential performance. |
| Compatibility and performance with endoscopes | Tested, results met essential performance. |
| Luer lock hub | Tested, results met essential performance. |
| EO residual | Measured to meet criteria defined in ISO 11135 and AAMI/ANSI/ISO 10993-7:2008(R)2012. |
| ECH residual | Measured to meet criteria defined in ISO 11135 and AAMI/ANSI/ISO 10993-7:2008(R)2012. |
| Shelf-life (3 years) | Validated in accelerated testing per ASTM F1980-16 (2016). Packaging requirements per ISO 11607-1 and ISO 11607-2 were also met. |
| Biocompatibility | Tested by a GLP laboratory following ISO 10993-1:2018; results are qualified (implying compliance with ISO 10993-4, -5, -10, -11, -23, and USP <151>). |
2. Sample Size Used for the Test Set and Data Provenance:
The document
does not specify the sample sizes
used for each individual non-clinical performance test. It only states that "Performance testing was conducted."
Regarding data provenance, the document indicates that Promisemed Hangzhou Meditech Co., Ltd. is the manufacturer, located in Hangzhou City, China. The biocompatibility testing was conducted by a "third GLP laboratory," but its location is not specified. All tests described are retrospective in the sense that they were conducted for the purpose of this 510(k) submission, likely in a controlled laboratory environment.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications:
This information is not applicable as the provided document details non-clinical, benchtop performance testing, not studies involving human subjects or expert assessment of clinical data to establish a "ground truth" as might be done for diagnostic devices. The acceptance criteria for these tests are based on established engineering standards and specifications rather than expert consensus on medical conditions.
4. Adjudication Method for the Test Set:
This information is not applicable for the same reasons as point 3. Benchtop performance tests typically involve objective measurements against predefined specifications, not subjective assessments requiring adjudication among experts.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done:
No, an MRMC comparative effectiveness study was not done. The document explicitly states: "No clinical test is included in this submission." and "No reference devices were used in this submission." This type of study is relevant for diagnostic imaging devices where human interpretation is involved.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done:
No, a standalone algorithm performance study was not done. This device is an Endoscopic Injection Needle, a physical medical instrument, not a software algorithm. Therefore, the concept of "standalone algorithm performance" (without human intervention) is not applicable.
7. The Type of Ground Truth Used:
The ground truth for the non-clinical tests described is based on:
- Engineering specifications and design requirements for the device.
- Established national and international standards for medical device testing (e.g., ISO 11135, AAMI/ANSI/ISO 10993-7, ASTM F1980-16, ISO 11607-1, ISO 11607-2, ISO 10993 series, USP <151>).
- Comparison to the predicate device's performance characteristics to establish substantial equivalence.
8. The Sample Size for the Training Set:
This information is not applicable. As this is a physical medical device and not a machine learning or AI-driven system, there is no "training set." The device's design is based on engineering principles and prior knowledge.
9. How the Ground Truth for the Training Set Was Established:
This information is not applicable for the same reason as point 8.
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(245 days)
Single use injection needle is to be used in conjunction with an endoscopic injections, such as for the treatment of esophageal and gastric varies and for submucosal dye marking in the GI tract.
Endoscopic Injection Needle consists of Handle, Rod, Needle, Needle holder, Sheath, Catheter, Adapter, Sheath holder, Sheath protection pipe, Tube cap.
The Endoscopic Injection Needle is available in three needle sizes (20 gauges 22 gauge and 25 gauge), five needle lengths (4mm,5mm,8mm and 10mm),five working length(1200mm,1600mm, 1950mm,2000mm, 2300mm). There are 5 series (SN18-05 series, SN18-07 series, SN18-09 series, SN19-05 series and SN19-07 series) total ninety (90) specification injection needles.
The Endoscopic Injection Needle is sterile, single-use device. It is expected to be used in conjunction with an endoscope to perform endoscopic injections into tissue in the GI tract during an endoscopic procedure.
The Endoscopic Injection Needle is designed to pass through the endoscope's forceps to mark the lesions of the digestive tract and use it for injection. Compatibility with endoscopes, working lengths are 1600mm, 1950mm,2000mm, 2300mm, and the minimum working clamp channel is φ 2.8 mm.
The provided text describes the Endoscopic Injection Needle (K213239) and its acceptance criteria, along with a summary of the testing performed to demonstrate its safety and effectiveness.
Here's a breakdown of the requested information:
1. Table of Acceptance Criteria and Reported Device Performance
The acceptance criteria are generally implied by the successful completion of the tests listed. The "Reported Device Performance" column indicates that the device met these criteria through successful testing.
| Test Item | Acceptance Criteria (Implied) | Reported Device Performance |
|---|---|---|
| Integrity Checks | ||
| Appearance | Integrity, cleanliness, and hygiene | Confirmed to be integrity and cleanliness and hygiene |
| Dimension | Complied with company's requirements | Complied with company's requirements |
| Leakage | No gas leakage | No gas leakage |
| Needle Protection | Needle shall not be exposed when pulling rod back | Needle not exposed when pulling rod back |
| Material/Mechanical Properties | ||
| Resistance to Corrosion | No corrosive marks in immersed part of the needle | No corrosive marks found |
| Stiffness | Needle tube is not easy to deform | Confirmed not easy to deform |
| Resistance to Breakage | Needle tube is not broken during use | Confirmed not broken during use |
| Penetrating Force | Needle tip is sharp (implies sufficient sharpness) | Confirmed needle tip is sharp |
| Connection Strength | All joints are rigid connect | Confirmed all joints are rigid connect |
| Luer Lock Connectors | Meets the requirement of ISO 80369-7 | Meets ISO 80369-7 |
| Functional Testing | ||
| Basic Functional Testing | Successfully inserted and withdrawn into/out of endoscope; stylet passes syringe successfully | Successfully inserted and withdrawn, stylet passes through |
| Chemical/Sterilization Properties | ||
| Chemical Properties | pH, Total content of heavy metals, Potassium permanganate reductive substance, Evaporative residues and Ultraviolet Absorbance meet related requirements | Met related requirements |
| Sterility | Device shall be sterile (SAL: 10-6) | Sterile (by ethylene oxide, SAL: 10-6) |
| EO Residue | ≤10 μg/g | ≤10 μg/g |
| Pyrogen | No pyrogen | No pyrogen |
| Biocompatibility | Conform with ISO10993-1, -4, -5, -10, -11 (Hemolysis, cytotoxicity, sensitization, intracutaneously irritation, acute systemic toxicity, material medicated pyrogenicity) | Verified with ISO 10993 (non-toxic and biocompatible) |
| Shelf Life | Maintain sterility and performance for 2 years | 2-year shelf life established |
2. Sample Size Used for the Test Set and Data Provenance
- Test Set Sample Size: The document does not explicitly state the sample size used for each specific bench test item. It generally refers to "bench testing" being performed.
- Data Provenance: The data is from "Summary of non-clinical and performance testing- Bench testing" carried out by Beijing ZKSK Technology Co., Ltd. The tests were performed according to recognized consensus standards and the company's technical requirements. This is retrospective testing performed by the manufacturer on its own device prototypes/production samples. The country of origin for the testing is implied to be China, where the manufacturer is located.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications
Not applicable. This device is a physical medical instrument, not an AI/software device that relies on expert interpretation for ground truth in its performance evaluation as described in the context of AI/ML devices. The "ground truth" for the bench tests is based on objective measurements and adherence to engineering and biological standards.
4. Adjudication Method for the Test Set
Not applicable. As noted above, this is not an AI/ML device requiring human adjudication for performance evaluation. Adjudication methods are typically relevant for subjective expert assessments or when there are disagreements in interpretations.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done
No, a Multi-Reader Multi-Case (MRMC) comparative effectiveness study was not done. The device is an Endoscopic Injection Needle, a physical instrument, and its evaluation focuses on bench testing and mechanical/biocompatibility performance, not on AI-assisted human reading.
6. If a Standalone (i.e. algorithm only without human-in-the loop performance) Was Done
Not applicable. This is not an algorithm or AI device; it's a physical medical instrument. Therefore, the concept of "standalone performance" for an algorithm doesn't apply.
7. The Type of Ground Truth Used
The ground truth for the performance testing is based on objective measurements, adherence to recognized consensus standards (e.g., ISO 7864, ISO 9626, ISO 10993 series, ISO 11607-1, ISO 80369-7), and the manufacturer's internal design requirements and specifications. For biocompatibility, the ground truth is established by the biological responses observed against the criteria in ISO 10993.
8. The Sample Size for the Training Set
Not applicable. This is not an AI/ML device that requires a training set. The device's safety and effectiveness are established through physical and biological testing as described above.
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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(29 days)
The Endoscopic Injection Needle is an accessory for currently marketed endoscopes to allow delivery of injectable materials into tissue during an endoscopic procedure.
The Endoscopic Injection Needle consists of a luer lock hub, flexible cannula and retractable stainless steel needle at the distal tip. The hub is designed to accommodate a standard syringe. The device is supplied sterile and is for single patient use.
This document is a 510(k) premarket notification for an Endoscopic Injection Needle. The device is an accessory for endoscopes used to deliver injectable materials into tissue during endoscopic procedures. The notification concludes that the device is substantially equivalent to a predicate device (Carbon Medical Technologies Endoscopic Injection Needle K042615).
Based on the provided information, there is no study proving the device meets specific acceptance criteria in the sense of an effectiveness or performance study with a numerical outcome on efficacy, sensitivity, specificity, etc. The document focuses on demonstrating substantial equivalence to a predicate device through technological characteristics, risk assessment (FMEA), and various validation and testing activities related to manufacturing and safety.
Therefore, many of the requested items (e.g., acceptance criteria for clinical performance, sample size for test set, number of experts, adjudication methods, MRMC studies, standalone performance, training set details) are not applicable or not present in this type of submission for this particular device. This 510(k) is for a Class II endoscope accessory, and the focus is on demonstrating that the new device is as safe and effective as a legally marketed predicate device, rather than proving novel clinical efficacy.
However, based on the technological characteristics and performance section, we can infer the "acceptance criteria" and "study" are related to manufacturing, safety, and equivalence to the predicate.
Here's an attempt to answer the questions based on the available information:
1. A table of acceptance criteria and the reported device performance
| Acceptance Criteria (Implied) | Reported Device Performance |
|---|---|
| Technological Equivalence to Predicate Device | The technological characteristics are equivalent to the predicate device. |
| Risk Management (FMEA) | A Failure Modes and Effects Analysis (FMEA) was performed to assess risks associated with modifications. (Implied: Risks were assessed and deemed acceptable, or mitigated). |
| Sterilization Efficacy | Sterilization adoption validation confirmed effective sterilization. |
| Ethylene Oxide (EO) Residual Levels | EO residual testing confirmed acceptable levels. |
| Distribution Simulation/Packaging Integrity | Distribution simulation confirmed the integrity of the device during transport. |
| Shelf Life Stability | Shelf life testing confirmed the specified shelf life. |
| Functional Performance | Functional testing confirmed the device operates as intended. |
| Biocompatibility | Biocompatibility evaluation confirmed the device materials are safe for patient contact. |
| Sterile Barrier Packaging Integrity | Sterile barrier packaging evaluation confirmed the packaging maintains sterility. |
| Substantial Equivalence (Overall) | All conducted tests and evaluations "confirmed that the modified device, Endoscopic Injection Needle, was substantially equivalent to the predicate device." (This is the ultimate "performance" goal for a 510(k) for this type of device). |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- Sample Size for Test Set: Not explicitly stated. The document refers to "validation" and "testing" (e.g., sterilization validation, functional testing), which would involve samples, but the specific number of units tested is not provided in this summary.
- Data Provenance: Not specified, but likely from in-house lab testing and potentially third-party testing facilities engaged by Carbon Medical Technologies, Inc. It's a technical submission, not a clinical study involving patients, so "country of origin for clinical data" is not relevant here. The studies mentioned (e.g., sterilization, shelf life) are prospective laboratory/engineering studies.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)
- Not Applicable. This submission does not involve clinical "ground truth" derived from expert interpretation of medical data (like images or pathology). The "ground truth" for these tests are objective measurements and established standards for engineering, manufacturing, and safety (e.g., sterility, material properties, functional integrity).
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Not Applicable. This is not a clinical study involving subjective interpretation that would require adjudication. The "tests" are objective and based on established protocols and standards.
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
- No. An MRMC study is completely irrelevant for this device. This is a physical medical device (an injection needle), not an AI-powered diagnostic or assistive tool.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- No. This is not an algorithm or AI device.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
- For the validation and testing mentioned, the "ground truth" is based on:
- Established scientific and engineering principles: (e.g., for functional testing, material properties).
- Regulatory standards and guidelines: (e.g., for sterilization, biocompatibility, EO residuals, packaging).
- Predicate device characteristics: For demonstrating technological equivalence.
8. The sample size for the training set
- Not Applicable. This is not a machine learning or AI device that requires a training set.
9. How the ground truth for the training set was established
- Not Applicable. This is not a machine learning or AI device.
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