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510(k) Data Aggregation

    K Number
    K192421
    Device Name
    EpiFaith Syringe
    Date Cleared
    2019-09-27

    (23 days)

    Product Code
    Regulation Number
    880.5860
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    EpiFaith Syringe is intended for use with an epidural needle for detecting a loss of resistance, which aids a clinician in verifying needle tip placement in the epidural space.

    Device Description

    The EpiFaith is a loss of resistance syringe with spring loaded piston, which can provide a means for detecting entry into the epidural space. Based on the principle of LOR technique, the piston will simultaneously move forward when the pressure drop occurs due to the spring force. The moving of the piston can provide a visual signal to indicate the LOR as well as verify the needle tip placement in the epidural space. The EpiFaith syringe is compatible to a 16-18 gauge epidural needle with Luer or NRFit connector. The user can push the plunger to increase the pressure after the syringe is connected to an inserted needle. Then, the user can advance the needle until the visual signal occurring. Because the piston is spring loaded, the automatic ejection of the syringe will happen when the LOR occurring, resulting in the movement of the piston. There are two different models of EpiFaith Syringe. The proposed models are listed below. The only difference between two models is the type of the connector.

    AI/ML Overview

    This document, K192421, is a 510(k) summary for the EpiFaith Syringe. It describes the device, its intended use, and a comparison to a predicate device (K182268) to demonstrate substantial equivalence.

    It's important to note that this 510(k) submission is for a medical device (a syringe), not an AI/ML-enabled medical device. Therefore, the questions related to AI/ML performance, ground truth, human readers, and training/test sets are not directly applicable to this document. The "Performance Data" section discusses traditional non-clinical tests for a medical syringe.

    However, I will extract the available information as best as possible, interpreting "acceptance criteria" and "device performance" in the context of a non-AI/ML medical device.

    1. Table of Acceptance Criteria and Reported Device Performance

    For this medical device, acceptance criteria relate to its physical properties and functional performance as a syringe, not diagnostic or predictive accuracy. The performance data is based on non-clinical tests.

    Acceptance Criterion (Type of Test)Reported Device Performance (Summary from document)
    Risk assessment (ISO 14971: 2007)Conducted, suggesting risks are assessed and managed.
    Friction forces test (ISO 7886-1: 2017)Conducted, implying the device meets the standard for plunger movement.
    Liquid leakage test (ISO 7886-1: 2017)Conducted, implying the device meets the standard for fluid containment.
    Biocompatibility Assessment (ISO 10993: In vitro cytotoxicity, Skin sensitization, Intracutaneous irritation, Acute systemic toxicity, Pyrogen test, Limulus amebocyte lysate endotoxin)Meets guidelines, indicating the materials are safe for biological contact.
    Sterility (Sterile assurance level)10^-6 (E.O gas sterilization), indicating a very low probability of non-sterile product.
    Packaging Integrity"Tyvek and PET", implying standard medical packaging.
    Compliance with ISO 80369-6 (NRFit)Yes (for NRFit model) - indicates connector compatibility.
    Compliance with ISO 80369-7 (Luer slip)Yes (for Luer slip model) - indicates connector compatibility.

    The document states: "Design Verification activities were performed on subject device and all necessary tests were verified to meet the required acceptance criteria." and "the material change of syringe piston meets the requirements that are considered essential for its intended use".

    2. Sample size used for the test set and the data provenance

    This document does not specify exact sample sizes for the non-clinical tests (e.g., how many syringes were tested for friction or leakage). The tests are typically performed on a statistically relevant sample size according to the respective ISO standards. The data provenance is from Flat Medical Co., Ltd., Taipei City, Taiwan, the device manufacturer. The tests are non-clinical (bench testing), not retrospective or prospective human subject data.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    This is not applicable as the validation is for a physical medical device (syringe) performing mechanical and biocompatibility functions, not an AI/ML model requiring expert review for diagnostic ground truth. The "ground truth" for these tests are objective measurements (e.g., force, leakage presence/absence, biochemical reactions).

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    Not applicable. Adjudication typically refers to expert consensus in diagnostic studies, which is not relevant here. The tests are based on objective, measurable criteria defined by international 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

    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 a physical medical device, not an algorithm.

    7. The type of ground truth used (expert concensus, pathology, outcomes data, etc)

    The "ground truth" for this device's performance is based on objective measurements and adherence to established international standards (e.g., ISO 7886-1 for syringes, ISO 10993 for biocompatibility). For example, a "friction force" reading compared against a defined maximum in the standard, or absence of leakage as per the standard.

    8. The sample size for the training set

    Not applicable. This is a manufactured physical device, not an AI/ML model that undergoes a "training" phase.

    9. How the ground truth for the training set was established

    Not applicable. See point 8.

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    K Number
    K182268
    Date Cleared
    2019-04-05

    (227 days)

    Product Code
    Regulation Number
    880.5860
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    EpiFaith Syringe is intended for use with an epidural needle for detecting a loss of resistance, which aids a clinician in verifying needle tip placement in the epidural space.

    Device Description

    The EpiFaith is a loss of resistance syringe with a spring-loaded piston, which can provide a means for detecting entry into the epidural space. Based on the principle of the LOR technique, the piston will simultaneously move forward when the pressure drop occurs due to the spring force. The moving of the piston can provide a visual signal to indicate the LOR as well as assist in verifying the needle tip placement in the epidural space. The EpiFaith syringe is compatible to a 16-18 gauge epidural needle with Luer or NRFit connector. The user can push the plunger to increase the pressure after the syringe is connected to an inserted needle. Then, the user can advance the needle until the visual signal occurs. Because the piston is spring loaded, the automatic ejection of the content of the syringe will happen when the LOR occurs, resulting in the movement of the piston. There are two different models of EpiFaith Syringe. The proposed models are listed in Table 4.1. The only differences between two models are the type of the connector and color.

    AI/ML Overview

    The provided text describes a 510(k) submission for the EpiFaith Syringe, a loss-of-resistance syringe used for detecting entry into the epidural space. This document is a summary and primarily focuses on demonstrating substantial equivalence to a predicate device (AutoDetect Syringe K041590) through characterization and non-clinical performance testing.

    The document does not include information on a clinical study (MRMC, standalone, or otherwise) involving human readers or expert consensus for establishing ground truth from clinical images. The performance data described are exclusively non-clinical bench tests and compliance with recognized standards.

    Therefore, many of the requested items related to clinical study design, sample sizes for test/training sets, expert consensus, and human reader performance are not applicable or not present in this 510(k) summary.

    Here's a breakdown of the information that is available based on the provided text:


    Acceptance Criteria and Device Performance (Non-Clinical)

    The performance data for the EpiFaith Syringe are entirely based on non-clinical bench testing and adherence to recognized standards. The acceptance criteria are implicitly defined by compliance with these standards.

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria (Defined by adherence to standards)Reported Device Performance
    ISO 7886-1:2017 (Sterile hypodermic syringes for single use – Part 1: Syringes for manual use)"The EpiFaith Syringe complies with the FDA recognized consensus standards: ISO 7886-1:2017... Results of the testing demonstrate that the subject device met the acceptance criteria sufficient for its intended use." (Implies successful performance across all relevant parameters of the standard, e.g., dimensions, capacity, sterility, luer connection, plunger operation).
    ISO 80369-6:2016 (Small-bore connectors for liquids and gases in healthcare applications – Part 6: Connectors for neuraxial applications)"The EpiFaith Syringe complies with the FDA recognized consensus standards: ... ISO 80369-6:2016... Results of the testing demonstrate that the subject device met the acceptance criteria sufficient for its intended use." (Implies successful performance related to the NRFit connector specifications).
    ISO 80369-7:2016 (Small-bore connectors for liquids and gases in healthcare applications – Part 7: Connectors for intravascular or hypodermic applications)"The EpiFaith Syringe complies with the FDA recognized consensus standards: ... ISO 80369-7:2016, as outlined within this submission. Results of the testing demonstrate that the subject device met the acceptance criteria sufficient for its intended use." (Implies successful performance related to the Luer slip connector specifications).
    ISO 80369-20:2015 (Small-bore connectors for liquids and gases in healthcare applications – Part 20: Common test methods)"Conformity to these standards demonstrates that the proposed EpiFaith Syringe met the standards' established acceptance criteria for the device." (Indicates application of common test methods and successful results.)
    ISO 10993-1, -4, -5, -7, -10, -11 (Biological Evaluation of Medical Devices – various parts)"The biocompatibility evaluation for the EpiFaith Syringe was conducted in accordance with the FDA Guidance Document... and International Standard ISO 10993-1... Testing included the following: Hemolysis, In vitro cytotoxicity, Skin sensitization, Intracutaneous irritation, Acute systemic toxicity, Material-Mediated Pyrogens, Limulus amoebocyte lysate endotoxin." (Implies all these tests passed per the ISO 10993 standards).
    **ASTM F1980-16, ISO 11135, ASTM F1140, ASTM F1608-00, ISO 15223-1, ASTM F756-17, USP , USP , USP , ISO 28590, ASTM F88, ASTM F1886, ASTM F1929, ISO 11737-2, ISO 14971, USP ** (Sterilization, Packaging, Labeling, Pyrogenicity, Quality Mgmt, Particulate Matter, etc.)"A battery of tests was performed based on the requirements of the below recognized consensus standards and guidance, as well as biocompatibility, sterilization, and packaging standards and guidance. Conformity to these standards demonstrates that the proposed EpiFaith Syringe met the standards' established acceptance criteria for the device." (Implies successful performance across all listed standards).
    Performance Bench Testing: Visual indicator response time, Needle protruding length and visual indicator activation on an epidural simulator, Resistance of the O-ring, Human Factors and Usability Testing on an epidural simulator"Results of the testing demonstrate that the subject device met the acceptance criteria sufficient for its intended use." (Implies these specific bench tests were successfully completed and met internal acceptance criteria to support intended use).

    Information Not Present in the Provided Document:

    The following requested items are typically associated with clinical studies, especially those involving AI/imaging devices, and are not found in this 510(k) summary as it pertains to a mechanical medical device (syringe):

    1. Sample sizes used for the test set and the data provenance: Not applicable; no clinical test set data presented.
    2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable; no clinical ground truth established from expert readings.
    3. Adjudication method (e.g. 2+1, 3+1, none) for the test set: Not applicable; no clinical test set.
    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: No MRMC study was done, as this is a mechanical syringe, not an AI/imaging device.
    5. If a standalone (i.e. algorithm only without human-in-the loop performance) was done: No standalone algorithm performance provided, as this is a mechanical syringe.
    6. The type of ground truth used (expert consensus, pathology, outcomes data, etc.): Not applicable for clinical ground truth. The "ground truth" for this device would be defined by the physical and material properties meeting the specifications of the listed international standards.
    7. The sample size for the training set: Not applicable; no training set data relevant to AI/machine learning.
    8. How the ground truth for the training set was established: Not applicable; no training set ground truth relevant to AI/machine learning.

    Summary of the Study Proving Device Meets Acceptance Criteria:

    The study proving the EpiFaith Syringe meets its acceptance criteria is a series of non-clinical bench tests and evaluations demonstrating compliance with a comprehensive list of international and consensus standards for piston syringes, biocompatibility, sterilization, packaging, and specific functional performance metrics (e.g., visual indicator response, O-ring resistance, human factors on a simulator). The document states that "Conformity to these standards demonstrates that the proposed EpiFaith Syringe met the standards' established acceptance criteria for the device." The rationale for substantial equivalence relies on these non-clinical tests showing the device performs comparably to the predicate and meets its intended use. No clinical trials or studies involving human patients or complex data interpretation (like AI in imaging) were conducted or are required for this type of device and submission.

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